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February 2008
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Word on the Street
OSHA CITES TWO VIOLATIONS
In a pair of actions, the U.S. Department of Labor’s Occupational
Safety and Health Administration attacked indoor health failures at
military facilities in Martinsburg, W.Va. and White Sands, N.M.
OSHA’s inspection at the White Sands Missile Range began in July,
2007 at the instigation of the New Mexico Environment Department,
which alleged that employees were removing underground concrete pipe
containing asbestos from a military housing site without using
appropriate protective clothing or an enclosure to contain airborne
particles. A press release dated Dec. 31, 2007 reported a $324,000
fine on 12 violations for Balfour Beatty Construction LLC and C.F.
Jordan LP.
This followed another administration action from earlier that same
month, against the Veterans Affairs Medical Center in Martinsburg.
In that case, three health and safety violations connected to mold
removal in 2006 led to a notice of “Unsafe or Unhealthful Working
Conditions.”
ANTIMICROBIAL HEAVY METAL
Although some might argue that liberal, high-volume doses of
Metallica and Fear Factory peel the paint off walls, actual
elemental metals are gaining increased attention for their
antimicrobial properties.
A release from the Copper Development Association touts the
association’s receipt of congressionally appropriated funds “to
continue clinical trials determining the antimicrobial effectiveness
of copper, brass and bronze” in two separate studies.
One study focuses on “the ability of copper alloy surfaces to kill
deadly pathogens and impede cross contamination. The monies will be
used to complete the pilot conversion of touch surfaces in
healthcare facilities in New York City and Charleston, S.C., where
extensive clinical trials have begun.”
Based on the same premise, the second study “is designed to
demonstrate the effectiveness of copper components in heating,
ventilating and air-conditioning systems in reducing the incidence
of harmful microbes that spread through buildings and other indoor
air environments.”
Lest anyone doubt such utilities, research on copper’s antimicrobial
properties has been ongoing in various clinical and laboratory
settings for several years, often with the funding of the U.S.
government. In fact, a previous study conducted by ATS Labs in
Eagan, Mich. under test protocols established by the U.S.
Environmental Protection Agency showed copper alloys to be more than
99.9 percent effective “on five pathogens commonly found in
healthcare facilities,” according to CDA.
LEAD POISONING WITH A BULLET
People visit firing ranges to practice marksmanship, try out a new
firearm or even just to let off some steam. Safety precautions are
serious business. But for regular visitors, it turns out that errant
shots are the least of their worries.
A story from the Fairbanks Daily News-Miner in Fairbanks, Alaska
reported on one range that was forced to take steps to reduce
airborne lead dust when blood tests on rifle team members from
nearby Delta High School showed “dangerously high” lead blood
levels. An investigation revealed that the students were
dry-sweeping the range’s floors.
With funds provided by the National Rifle Association and the Delta
Junction city council, the range is installing a new ventilation
system capable of filtering lead dust and uses a new floor cleaner
to prevent its release. Additionally, rifle team members are using a
hand soap crafted to wash away latent dust so it doesn’t follow them
home.
HEALTHY HOMES AWAY FROM HOME
Trips for business or vacation tend to involve hotel stays. Staying
in what amounts to high-use residential space tends to mean exposure
to a host of pathogens and allergens that can go much further than
simply ruining the trip. In fact, one widely circulated TV news
report on hotel drinking glasses showed how not-diligent hotel
cleaning practices can be.
Fortunately, according to a story in the Chicago Tribune, “ever so
slowly, hotels are recognizing that travelers who suffer from severe
asthma and allergies triggered by dust mites, mold, smoke, pollen,
chemicals and animal dander might like to stay in hypoallergenic
rooms.”
Pure Rooms and Enviro-Rooms have entered the lodging market as safe
places for the allergic, asthmatic and germophobic. “Both are
cleansed by different to rid a room of disgusting germs and keep it
allergen free,” reads the Tribune, “but finding a
bacteria/virus-free, mite-free, pollen-free, dust-free,
chemical-free, dander-free room is a challenge because the number of
hotels that offer these special rooms is miniscule.”
For instance, Pure Rooms currently number only about 400 nationwide.
Wyndham Hotels & Resorts is the largest chain to commit to Pure
Rooms. NYLO, which offers mid-priced rooms, plans on having 50
properties outfitted with Pure Rooms by 2010.
Altruism isn’t the reason, though. As NYLO CEO John Russell told the
Tribune, market research directed the chain to implement
allergy-free rooms.
But, as the Tribune story points out, you may only be able to do so
“for a price.” “Pure Rooms can command a higher rate because people
are willing to pay a little more to have that amenity – a $10
premium. It does cost more to maintain these rooms.”
UPS AND DOWNS OF PRISON AIR
Going to prison is serious business – no freedom, constant danger.
Working in a prison can be just as dangerous. What few people
consider, though, are the dangers of a prison’s indoor environment.
Eastern Ohio’s Vindicator reported on “dangerously toxic levels of
cadmium and lead” at the Federal Correctional Institution in Elkton,
Ohio, according to a preliminary report from the U.S. Justice
Department’s Office of the Inspector General. The DOJ’s
investigation, which included other federal agencies, concluded that
“people were exposed at levels 450 times ... allowable by [OSHA].”
“The exposures took place while changing air-handling filters in the
ventilation system at the inmate work factory known as UNICOR,”
reads the Vindicator.
The good news is that efforts to improve indoor environmental
quality have spread beyond residential and commercial spaces. An
expansion of the La Crosse County Jail in Wisconsin is being
discussed as “environmentally friendly,” as reported by La Crosse’s
WKBT News. Potter Lawson Architects, which is designing the
expansion, said the jail could “use water more efficiently or
optimize its use of solar energy.” Also recommended was an increased
ventilation system “to improve the indoor air quality for inmates
and staff at the jail.”
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Wide World of LEED By Jonathan Miller
Building green and implementing green features into existing
structures has gained considerable popular and economic traction in
the last several years. At the forefront of the movement, setting
standards and certifications by which such changes are made, is the
U.S. Green Building Council’s Leadership in Energy and Environmental
Design Green Building Rating System. Despite critics, LEED is
positioned as a sustainability leader in a world steadily moving to
a greener future.
Work on LEED first began in 1994, when Robert K. Watson, former
senior scientist of the National Resources Defense Council and
founder of EcoTech International Inc., spearheaded a consensus
process on green building standards by including such stakeholders
as non-profi ts, government agencies, manufacturers, architects,
engineers and builders. From its initial standard for new
construction, the LEED program grew to include six standards
governing all aspects of development and construction by 2006, lead
by Watson as chair of the steering committee until that same year.
The program currently operates under the aegis of USGBC.
How It Works
LEED utilizes a rating system focused on sustainable sites,
water efficiency, energy
and atmosphere, materials and resources, innovation and design
process and indoor environmental quality. Points are earned for
meeting standards. Currently existing rating systems cover new
construction, existing buildings, commercial interiors, core and
shell, schools, retail, healthcare and homes. A rating system for
neighborhood development is in its pilot period.
Within the rating system exist core goals, set at the program’s
genesis: To define “green building” by establishing common
standards; promote integrated, whole-building design practices;
recognize environmental leadership in the building industry;
stimulate green competition; raise consumer awareness of the
benefits of green building; and transform the building market.
To gain certification, a building must earn at least 26
non-innovation points. “Silver,”
“gold” and “platinum” levels are attained by reaching 33, 39 and 52
points, respectively. Comparative standards, like ASHRAE 90.1, form
important aspects of how points are awarded. Some buildings
currently certified are New York City’s 7 World Trade Center,
Pittsburgh’s David L. Lawrence Convention Center, Mexico City’s HSBC
Tower and, having reached platinum status, the Bank of America Tower
in New York City and the University of California Santa Barbara’s
Bren Hall, a research laboratory.
The Canadian Green Building Council has introduced its own version,
LEED Canada-NC v1.0, based on LEED-NC 2.0.
LEED’s Place in Environmental, Green Industries
“Overnight,” wrote Auden Schendler and Randy Udall in a 2005
article in Grist, “LEED has become a dominant brand.”
“Today,” said LEED committee member Russell Perry in a 2007
interview with Building Design+Construction, “for a client or design
professional not to be aware of LEED, they’d have to be living under
a rock.”
With so much public attention and the ever-keen ears of
manufacturers and politicians listening in, LEED has vaulted to a
high place in the world of sustainability. Deservedly so, according
to a study by the U.S. General Services Administration that found
LEED “the most credible” of the five green building rating systems
it evaluated. The city of Chicago went so far as to mandate that all
new public buildings in the city meet LEED standards. Some federal
politicians intend to push for LEED-based standards on all new
federal buildings and to likewise retrofit existing structures.
While designers push to meet LEED standards, the marketplace has
responded in kind – a host of products designed to earn LEED points
for the buildings incorporating them have hit or will soon hit the
market. For instance, in response to water-saving credits, Zurn
Engineered Water Solutions has introduced its EcoVantage Pint Urinal
System.
Criticisms
Like any program, LEED is not immune to critics. Some in the
industry point out that local environmental factors do not vary the
points system. Others frown at certification costs that could, they
contend, be used to take a green project even further.
Schendler and Udall listed in their 2005 article five points of
contention – high costs; a points system that can shift focus from
basic, good design; “arcane” energy modeling; a “crippling
bureaucracy” that creates an overly long certification process; and
“overblown claims of green-building benefits.”
“Perhaps the world doesn’t need a green building certification,”
they wrote, “as much as it needs a green building specification
[italics in original]. Instead of a wild goose chase for points ...
maybe LEED certification should require getting 26 points, 20 of
which are mandatory.”
Russell pointed out that the checklist approach to earning points
“appears very arbitrary.” He stated a desire to “set the bar high
... but make it rational.”
Other industry organizations worry about points awarded for
potentially suspect inclusions: American IAQ Council executive
director Charlie Wiles called the award of a LEED Innovation in
Design credit to a building that incorporated UVC lights in air
handlers “an example of LEEDs gone wild.”
Current USGBC president/CEO Richard Fedrizzi responded to Schendler
and Udall in a Grist article by Ted Smalley Bowen by saying, “I
didn’t like the ‘LEED is broken’ part, but I did like the ‘Let’s fix
it’ part.”
Beyond LEED
To a great extent, evinced by the success of LEED in the
marketplace and general knowledge of the program in the population,
the goals are at least in the process of being met. Companies and
buildings tout their LEED status as a marketing tool and consumers
are showing a growing taste for LEED and its green brethren.
LEED or not, the green marketplace is growing, including the built
environment. As reported in this newspaper [Nov., 2007], consumer
attitudes are shifting, in greater preponderance each year, in favor
of green buildings, green cleaners, green toys. “Efficiency” has
become a key word for consumers as they seek to trim costs and
provide an iota of sustainability to the greater environment while
protecting their health.
With potential buyers leaning more and more toward green products,
major companies are seeking to harness the market. Clorox, for
instance, is introducing a new line of plant-based cleansers, Green
Works, to complement its current line of chlorine-based bleaches and
antibacterials. Procter & Gamble and Unilever are aiming to reduce
emissions. Wal-Mart has worked to eliminate certain suspect
chemicals from its shelves.
But thinking green and being so certified are two different things,
and LEED is but one of a host of certification programs worldwide.
And according to Chemical & Engineering News, the U.S. government
has begun a series of hearings to prepare for Green Guides, a set of
environmental marketing guidelines from the Federal Trade
Commission. The Environmental Protection Agency has its Design for
the Environment program that seeks to reduce pollutants indoors and
out. Even Congress is getting into the act with Nancy Pelosi’s (D-Calif.)
recent efforts to green the Capitol.
Communities, not just companies and individuals, are beginning to
think greener. Some pass standards, often based on LEED, for new
buildings; others provide grant and loan programs to retrofit
existing structures. Should government itself not support green
initiatives, local non-profits can apply for grants from companies
like Rockwell Collins.
The glut of standards, particularly across national borders, makes
figuring out just what counts as green that much more difficult,
which has lead some companies, such as Clorox, to create standards
of their own based on market expectations. “We decided that because
we are Clorox,” vice president of research and development in the
company’s cleaning division Suzanne Thompson told Chemical &
Engineering News, “we had to set a higher bar for ourselves.”
Next Steps
The USGBC has not pretended that LEED is perfect; indeed,
revisions and expansions are commonplace. LEED-NC 3.0 is currently
in the works with the expectation that it will include a requirement
for a building’s carbon footprint and reduced greenhouse-gas
emissions. Russell stated in his interview that the Green Guide for
Health Care will provide some guidance on the new version.
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Fragranced Products: Truly a Surprising Package By Barbara Rubin
Public concern continues as more unwelcome ingredients, such as
asbestos and lead in children‘s toys, are discovered in a variety of
imported products. A longer-running dispute continues domestically
between consumers and vendors of many products boasting undisclosed
ingredients.
Among them is the class of widely marketed products known as
synthetic fragrances. The older question about consumers’ right to
know about the contents of any purchase is now entering a new realm
of debate about the need to know all about the chemically laden
manufactured goods on the market.
As reports about the adverse health impacts of commonly encountered
products mount, the current American version of “free” enterprise
seems to be traveling a collision course with the growing public
outcry for greater regulatory oversight. Basic marketing philosophy
for materials concocted in modern laboratories appears to be in
conflict with the original vision of capitalism as a consumer-driven
process, in which demand shapes supply. What happens to the nature
of consumer demand in an era of consumer ignorance regarding the
items they buy? Let’s examine this question using as a microcosm the
debate surrounding the production of synthetic fragrances.
As many as 5,000 different chemicals are incorporated within various
fragrance formulas, according to the American Academy of
Dermatology. Industry asserts that fragrances have been used safely
for hundreds of years. Such claims are belied by the fact that
chemical compounds appearing in the products (e.g., benzaldehyde and
linalool found to be present in a 1992 EPA laboratory study), have
not been known for very long. Today’s fragrances rarely contain only
those natural ingredients used in earlier centuries; hence the
adjective, “synthetic.”
The public is prone to assume that all these chemicals have been
thoroughly vetted for their safety prior to sale. Many chemicals
have multiple uses across industries, appearing in cosmetics,
medications, cleaning products and even food flavorings. The
intended use of a product determines what agency, if any, has
jurisdiction for inquiring into its business.
For instance, the U.S. Food and Drug Administration states that it
has no oversight duties with regard to the ingredients used in
cosmetics. These consist of products intended to enhance
attractiveness whether the product is ingested, topically applied or
inhaled. The only exception is with colorants (as in hair dyes).
Otherwise, unless some claim is made regarding benefits to health,
as opposed to self-esteem, there is no requirement for registration
of these products with the FDA. This means that recalls of products
suspected of containing potentially harmful ingredients are
essentially a voluntary act on the part of vendors.
How complex is the task of developing appropriate testing protocols
for fragrance chemicals? There are multiple avenues for their
internalization apart from direct application and absorption through
the skin. Fragrances are intended to be inhaled, which would seem to
make assessment of their potential as respiratory irritants or
sensitizers a priority at least equal to the more commonly cited
skin testing. Once airborne, fragrance chemicals are going to be
absorbed by all in their vicinity, not just the intentional user. A
class of secondary, unintentional fragrance consumers is created via
the same mechanisms by which secondhand cigarette smoke has become
an issue before the general public. Therefore, the societal impact
of these products is far greater than basic consumer demand
summarized in sales statistics.
Measurable reductions in lung function, to a moderate degree, have
been observed upon exposure to the chemical 1,4 dichlorobenzene,
which is commonly found in deodorizing compounds. Ninety-six percent
of subjects in a 2006 study (Elliot et. al.) showed evidence of
exposure via blood sampling. Exposure by persons with pre-existing
respiratory problems or by healthy individuals in combination with
other common environmental irritants would have an even greater
impact upon intentional and unintentional consumers.
A thoroughly tested synthetic chemical can provide data accounting
for factors of carcinogenicity, central nervous system effects,
reproductive and developmental toxicity, cardiovascular and
endocrine effects, and specific organ vulnerabilities (e.g. liver or
kidney damage). While the industry may have dispensed with a few
harmful substances formerly incorporated in fragrances,
manufacturers do not speak of the thousands currently in use. These
include petrochemicals, aldehydes, phenols and esters, which are all
known to have wide-ranging adverse effects when studied in
isolation. Their effects in combinations have yet to be addressed in
research models.
A newer area of concern is that of “mutagen” effects, or how
chemicals around us alter the ongoing activity of our genes, cuing
them to turn themselves on or off as they go about the daily
business of regulating our bodily functions. The interactions of the
environment with gene functions (referred to as gene expression),
indicates that one need not have a genetic predisposition or defect
for harm to occur.
The identification of hazardous or potentially hazardous ingredients
in a product is usually followed by assurances that the amount
present is negligible. Unfortunately, the determination of how much
is too much is highly variable. Relevant factors include age,
gender, weight, general health status and cumulative levels of
exposure to multiple chemicals.
Practically speaking, this position is irrelevant to the very large
numbers of people who report that a product has harmed, rather than
enhanced, their quality of life. Science has also progressed beyond
the old saw “the dose makes the poison.” It is now recognized that
small amounts of a substance can sneak under the radar of one’s
physical defenses while larger amounts of the material would alert
the body to implement damage control procedures.
The American Academy of Dermatology also informs us that fragrance
ingredients, along with preservatives, are respectively the first
and second most frequent causes of contact dermatitis. Physicians
warn us that contact can be from airborne particles and not just
occur in primary users of a product. Between 40 and 50 million
Americans (20 percent of the population) have allergies to one or
more substances. Health care costs and losses in productivity are
estimated at $6 billion annually from this widespread problem.
Approximately 35 million Americans suffer from some form of chronic
lung ailment. The majority are diagnosed with asthma (over 22
million) and a majority report fragrance as being a common trigger
for attacks. Asthma costs the public over $19 billion per year in
direct healthcare costs and lost productivity. It is the most
frequent cause of missed school days in children.
Migraine headaches are experienced by some 28 million Americans at
an annual cost of $14 billion in medical costs and lost
productivity. Among the majority, who report triggering events for
their attacks, a sizable percentage count olfactory stimuli among
them (perfume and/or strong odors).
Subgroups of chronically ill persons like those on chemotherapy and
people who became ill following incidents of exposures to toxic
chemicals are particularly vigilant in attempting to avoid such
products. There is a sizable body of evidence that synthetic
fragrances are a burden upon very large numbers of people.
According to sufferers, reactivity ranges in severity from annoying
to disabling. Advice by vendors to individuals with adverse
reactions to such products has simply been to avoid them. These
consumers may choose to leave fragranced products untouched on store
shelves, yet are still exiting stores, offices, hospitals, schools
and libraries with molecules from these products left adhering to
their nasal passages and lungs. These particles may later be
deposited in other organs or stored in adipose (fatty) tissue and
subject to gradual release over time. The indoor air of our typical
environments is heavily laced with fragranced products emitted from
store merchandise, cleaning products, air fresheners and the
individuals we encounter throughout the day. Residues from various
laundry and personal care products cling to their skins and clothing
articles. Products may now include phthalates, those plasticizers
which can act as perfume “fixatives,” making them longer lasting.
The FDA plans to assess their safety in the near future, although
other researchers classify them as endocrine disruptors.
Since general avoidance of fragrance chemicals is frankly
impossible, consumers are left to try to identify key offending
ingredients. This, too, is impossible, since industry is legally
permitted to label the often-complex conglomeration of ingredients
with a single term, namely “fragrance.” This does not allow
individuals to collaborate with their physicians and isolate causes
for environmentally triggered problems. It does not allow proactive,
health-conscious individuals to discriminate among the varieties of
fragranced products on the market today.
Only disclosure of ingredients offers consumers the opportunity to
select preparations which are truly benign. The absence of such
information makes it impossible to select products best suited to an
individual’s particular health challenges, even by the expensive
process of trial and error. Some adverse effects may be delayed and
therefore not easily recognized.
Ostensibly, this withholding of information from consumers is done
to protect trade secrets. One wonders what consumers are expected to
do with such revelations if they became available. Certainly,
competitors already analyze one another’s products in their own
laboratories as a matter of course. In Europe, where labeling is
required, companies do not appear to be going out of business
because of competition from the man (or woman) on the street, who
might choose to make such products at home!
Clearly, we need greater assistance from the fragrance industry to
help consumers make appropriate selections from among thousands of
fragranced products. These were created to enhance the quality of
life rather than detract from it. Patents serve to protect industry
interests, but only full disclosure of product ingredients will
allow consumers to protect their own interests. Of course, this
raises the question of why the interests of consumers and vendors
would ever truly come into conflict with one another. Satisfied,
healthy consumers generate more disposable income. This in turn
enriches the makers of products that satisfy the demand for that
level of quality in composition. If competition relies less on
consumer ignorance and more on informed consumer preference, the
marketplace can only become a source of healthy competition in a
capitalist society.
Barbara Rubin holds an MA in speech/language pathology and worked
in the field of developmental disabilities for 25 years within
educational and medical settings. In addition to her role as a
therapist and supervisor of clinical programs, she also taught in
several colleges and universities in her field of expertise.
Following her retirement in 2000, Rubin became a freelance writer
about the human health effects of pollutants commonly encountered
within indoor settings. She has published several magazine articles
and numerous commentaries in various newspapers and journals. She
would like to thank Barb Wilkie and Alison Johnson for their
gracious editorial assistance with this article.
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ALA’s State of the Union Association Lists Best, Worst U.S. Indoor Smoking Environments By Jonathan Miller
Since the very beginning of the smoking habit, the inhalation of
tobacco smoke has been identified as a health hazard. With medical
evidence mounting over the years about the addictiveness of
tobacco-based nicotine and the damage done to lungs by smokers and
those around them, steps have slowly been taken to reduce the risk
of exposure to tobacco smoke. Age limits were placed on the sale of
tobacco, advertising was regulated and, with increasing public
support, even smoking in enclosed public spaces has been banned in
some areas.
While some U.S. states and numerous counties, cities and towns
across the country have banned smoking in or near buildings, a
spectrum of smoking opposition has been created. With that in mind,
the American Lung Association released in January its “State of
Tobacco Control: 2007” report, detailing efforts, or lack thereof,
to curtail and ban smoking in an effort to protect non-smokers from
the effects of smoke and nicotine exposure.
Tracking “progress on key tobacco control policies at the state and
federal level [sic] and [assigning] grades to tobacco-control laws
and regulations,” the “report is a call to action for national and
state elected officials: Meet the challenge and enact strong
tobacco-control laws so that everyone in the United States can
breathe easier.”
Both the federal government and states were graded on a letter scale
according to fixed criteria with details provided to explain the
evaluations. The full reports for each state and the federal
government can be viewed at
www.
stateoftobaccocontrol.org.
States Graded on Tobacco Control
The states, as well as Puerto Rico and the District of Columbia,
were graded according to “Tobacco Prevention & Control Spending;”
“Smokefree [sic] Air;” “Cigarette Tax;” and “Youth Access.”
The preponderance of states yielded mixed grades. California, for
instance, received an F for prevention and control and a D for its
cigarette tax, but was also awarded A’s for relatively smoke-free
air and youth access. Texas failed in spending and smoke-free air
and received a C for its tax, but nonetheless attained an A for
youth access. Other states with mixed grades were Maryland, Florida,
Illinois, Wisconsin, Oregon, Arizona, Ohio, Massachusetts, Arkansas,
Wyoming, the District of Columbia and Puerto Rico, among others.
Overall failing grades, for those states with at least one F and
lower scores across the board, were largely distributed in Plains
States and the tobacco-growing South, including North Carolina,
Kentucky, Alabama, Georgia, Virginia, Tennessee, Nebraska, Kansas
and Missouri. Pennsylvania and Washington stood out as
extra-regional states with poor scores. The worst were Mississippi,
South Carolina and West Virginia, all of which failed in all four
categories.
Five states with exceptionally high marks were New York, Vermont,
Hawaii, Maine and Washington. All but New York, which scored A’s in
spending, smoke-free air and youth access and a C for its tax,
received two A’s and two B’s.
Each state report includes a summary of each grade, a list of
smoking facts and pending governmental actions, a petition to
request one’s state to join the Smokefree Air 2010 Challenge and a
full report on the state’s tobacco and smoking environment.
Federal Tobacco Control
The federal government, judged on different criteria, scored
among the worst overall grades: an F in “Food and Drug Regulation of
Tobacco;” an F in “Cigarette Tax;” an F in “Cessation;” and a D in
“Framework Convention on Tobacco Control.” Specifically, ALA cited
inaction in the House of Representatives on a Senate-approved bill
authorizing the regulation of tobacco products by the Food and Drug
Administration; a low per-pack tax on cigarettes; and lack of Senate
ratification of the Framework Convention on Tobacco Control, an
international treaty singed by President Bush in 2004.
In terms of efforts toward smoking cessation, ALA listed its reasons
as “Nationwide:
Minimal; National Media Campaign: None; Federal Coverage of
Cessation Services: Minimal; Smokers’ Health Fund: None.”
Like the states, the federal government’s report included a summary
of its grades; statistics; pending legislation and regulation; and a
petition to pass the Family Smoking Prevention and Tobacco Act in
2008.
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NYC Proposes Law to Regulate Monitoring Equipment Public and Private Opposition Stalls Passage By Jonathan Miller
Citing advisement by an official with the U.S. Department of
Homeland Security, the New York Police Department has moved to
“license private biological, chemical and radiological detectors,”
according to the New York Daily News.
The proposed bill, known as “Int. No. 650: A Local Law to amend the
administrative code of the City of New York, in relation to permits
for atmospheric biological, chemical and radiological detectors,”
“would require environmental monitors to have their radiation and
biochemical detectors registered and approved by the NYPD,” as
reported by New York Public Radio. Additionally, permit holders
would be required to report chemical exceedances to NYPD.
Richard Falkenrath, NYPD’s deputy commissioner for counterterrorism,
told the New York city council’s Public Safety Committee on Jan. 8
that DHS had approached NYPD “some months ago” about the growing,
widespread use of private environmental sensors since the terrorist
attacks on Sept. 11, 2001. The locations and reliability of the
sensors are little known.
Claiming that endemic use of such devices could lead to false alarms
that could trigger “massive emergency response with all sorts of
problems,” Falkenrath told the committee that the bill’s intent is
to stem such unregulated proliferation to ensure “that they are
appropriate and reliable.”
Falkenrath sought to assuage critics by claiming that routine
detectors would be exempted from licensing, “including meters that
measure noise or are used in radiation-exposure badges, laboratory
detectors in universities or hospitals and Con Ed’s [Con Edison, the
city’s main electric company] propane-gas sniffers,” according to
the Daily News.
“We’re interested mainly in sensors which [sic] will alert someone
to a possible chemical, biological, radiological or nuclear weapons
attack,” Falkenrath said.
In addition to NYPD, the administration of New York Mayor Michael
Bloomberg supports the bill, the first of its kind in the United
States. Criticism of NYPD’s proposal came from city government
officials and private organizations on several fronts, including
contention that the bill is vague on which devices must be licensed
by regulations to be written by NYPD after the law’s passage.
The Daily News recounted statements by Councilman John Liu
(D-Queens), who responded that NYPD is asking for “a blank check” on
regulating private detectors. Manhattan Borough President Scott
Stringer, recalling federal and city agencies that “repeatedly lied
about the quality of the air” after Sept. 11, added that “the
measure could stifle the independent collection of environmental
data.”
“Residents should also be empowered to hold the government
accountable and confirm for themselves, in a timely fashion, that
their air is free of hazardous chemicals,” Stringer said.
New York Public Radio also reported that Stringer added criticism
that “[the bill] responds to a problem that does not exist.”
“There is no emergency,” Stringer said. “There aren’t hundreds of
people running around the borough testing everything. This is a fake
emergency. It doesn’t exist, and there is no problem. Let’s not try
to create one.”
Joel Kupferman, executive director of the New York Environmental Law
and Justice Project, warned of “a very bad, slippery slope” in
giving the police such a broad licensing function, according to the
Daily News.
John Glass, past president of the New Jersey chapter of the American
Industrial Hygiene Association and current chair of AIHA’s
environmental issues special interest group, testified before the
committee that AIHA “is opposed to enactment of this legislation.”
Aaron Trippler, AIHA’s director of government affairs, forwarded a
draft copy of Glass’ testimony to IE Connections.
Citing the bill’s first section, which states that “the city of New
York has an interest in insuring [sic] that [detectors are] reliable
and effective so [they] will not lead to excessive false alarms,”
Glass stated that a potential for misconception that “the equipment
in question are new and unique toxic monitors” is at risk and that,
“based upon the definitions provided later in the document, they are
the same tools that industrial hygienists have been using for
decades.” He also pointed out that, based on language in the bill,
regulation “would also include some common household items that no
one would ever have considered.”
Glass listed his concerns as: “How will five-year permits ensure
daily and annual equipment calibration; how will it be determined in
what configuration a unit will be used in during future events; how
will the reporting of exceedances be accomplished when no such level
exists at this time; how will the monitoring of all ‘toxic’
materials be accounted for; how will emergency plans be reasonably
created for situations that do not exist yet;” and “who will be
evaluating the required exceedences reports?”
He testified as to the difficulties and costs associated with proper
equipment calibration; the surprising, accidental and commonplace
incidents of exceedence and the unreliability of mandatory reports;
and how multiple exceedence levels in a multi-purpose device may “be
unaccounted for” in cases for which exceedence was determined in a
device’s intermediate uses.
“Two definitions have the impact of making this an unusable
standard,” Glass continued.
The first pertains to exactly what constitutes a “biological agent”
as, “under the definition of a chemical hazard, even water is
determined to be a toxin. ... [Toxicity] depends on the specific
conditions of the site, the types of organisms, the comparable
concentration of the organisms, etc. ... The number of variables
[is] far too great for a city agency to consider in drafting this
type of bill.”
Secondly, “the definition of detectors is also designed so liberally
that each homeowner in the city will need to file for a permit for
each of their smoke detectors” and “the rules ... determines a
radioactive substance as any substance that ‘emits ionizing
radiation including alpha, beta, gamma and/or neutron radiation.’
Nearly all detectors on the market today are sourced with a small
radioisotope.” Additionally, the bill’s language suggests that even
carbon monoxide detectors would require licensure.
Glass also criticized the requirement of “emergency response plans
for use with the detectors,” wryly suggesting that 911 exists as the
de facto emergency plan for people and that “any greater information
than that would merely be superfluous and intended only to satisfy
the permit requirement and provide no greater security. There is no
way to determine what emergency plan could possibly be needed for
situations that have not yet arisen.”
He further questioned how exceedence data reported to NYPD would “be
evaluated, responded and recorded [and] ... perhaps more
importantly, what will occur when the reviewer comes to a different
conclusion than the site professional.” He cited ethical and
liability concerns for practitioners behind his objections.
“For your consideration,” Glass said, “I would like to suggest a
more general approach to this rule. It may be advisable to require
all entities offering professional consulting in this arena to have
properly credentialed consultants overseeing the evaluations. ...
This will ensure that the individuals responsible for the final
interpretation of data are qualified to make those decisions and
reduce the occurrences of untrained individuals creating unnecessary
hysteria.”
According to New York Public Radio, committee head and Queens
council member
Peter Vallone postponed a vote on the bill until “the council
[narrows] the scope of the administration’s bill.”
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Publisher’s Perspective: Welcome to the 100th Issue of IE Connections By Glenn Fellman
For the last 99
months, I’ve had a crappy job. Day after day without relent I have
been challenged by issues like excess moisture and its huge
consequences, bacterial infections, noxious fumes and confusing
healthcare advice. It’s not pretty stuff.
To add insult to injury, those I tried to help often kicked and
screamed in resistance to my work. Though it wasn’t in my nature
beforehand, I quickly learned to assert dictatorial authority,
ignoring their cries to make sure my work succeeded.
For the last 99 months, I feel like I have been changing diapers.
And I have. Literally. Well, my wife and I have been changing them.
Okay, mostly her, but I did my share. The last diaper left a rear
end in our house in January, 99 months after the birth of the first
of our three children. By my calculations, we changed more than
30,000 disposable diapers (costing nearly $9,000). My family alone
contributed 5.66 tons of disposable diaper waste to landfills. Our
carbon footprint could be confused for that of a Sasquatch.
As every parent knows, that crappy job is a labor of love and it so
pales in comparison to the glory of parenthood that it’s really not
so bad. Either that, or I’m already trying to rationalize surviving
the 99 months. In any event, while I was changing diapers, I was
also a part of something else that took place with remarkable
regularity over 99 months – the publication of Indoor Environments
Connections, which was first published in November, 1999. This is
our 100th edition.
The two 99-month milestones have more in common than time. Like
having a baby and raising it into childhood, launching a newspaper
and shaping its persona is fraught with the unknown, requiring
difficult, well-informed decisions balanced by gut reaction.
Publishing, like childrearing, has also delivered moments of great
joy and tremendous accomplishment.
For 99 months we’ve delivered the IAQ industry its only newspaper.
Although there are many publications with content similar to ours,
none compare to Indoor Environment Connections. Our industry news is
cutting-edge and original and brings readers information they learn
here first and often only within these pages. Our coverage of
industry associations and events isn’t your typical trade rag
pabulum – it’s timely and interesting. And our technical section now
constitutes an impressive collection of hundreds of IAQ articles
covering everything from Aspergillus to radon zones, written by a
Who’s Who of industry experts.
We don’t publish press releases and we don’t reprint articles. We
research, we write, we report, we edit, we create. And with this
edition, we’ve done it 100 times in a row. We have never submitted
our newspaper for a publishing award, though I’m confident we could
get several. Our pride of accomplishment comes from the positive
feedback of our readership and advertisers.
There are a lot of people who have been instrumental to this
newspaper’s success and I’m going to exercise my right as publisher
to take up lots of space and thank a bunch of them.
In all fairness, thanks begin with my wife, Lisa, for allowing me to
go out on a limb and dangle our livelihood on the creation of a new
publication. Without her, there would be no Indoor Environment
Connections. Without two other women, this newspaper would most
likely not exist as well. Diane Chester, who in the autumn of 1999
sold a newspaper’s worth of advertising for a newspaper that didn’t
actually exist, has not only ensured our financial viability but
also our technical excellence. She’s the consummate salesperson, a
true industry insider who knows everybody and has a great eye for
recruiting the finest contributors. Susan Valenti, who for a short
time shared my role as publisher, was the one who developed the
original concept of the newspaper and talked me into being a part of
the venture. She was also our first editor.
Steve Sauer’s five-year run as our editor helped solidify our
position as the IAQ industry’s newspaper. His questions were Larry
King-penetrating, delivered with Stuttering John-brazenness. More
recently, editor Jon Miller has taken the newspaper into uncharted
territory with excellent, in-depth research and analysis of topics
as diverse as bed bugs, moldy airport control towers endangering
health and safety, and where presidential candidates stand on IAQ
issues.
Our personnel have been propped up by an editorial board we cannot
thank enough for its contributions and sustenance. Their writing,
review of articles, news tips and insider insights help give our
publication content, credibility and authority unparalleled among
trade newspapers.
The majority of our readers are the members of the non-profit
organizations we call our industry partners. These organizations and
their constituents are our staunchest supporters. Their logos have
proudly taken the bottom section of our front page since our first
issue. Association memberships, including those organizations with
the closest ties to IAQ, deliver a readership that advertisers have
found consistently receptive.
The loyalty and support of our advertisers and industry partners has
been phenomenal and paramount to our success. Many advertisers have
graced our pages since the first year’s editions. Besides being our
primary revenue source, they’ve been some of our biggest promoters.
Advertisers help distribute thousands of newspapers every month at
tradeshows they attend, courses they put on and to customers seeking
an IAQ news source. We thank them all.
Literally hundreds of people have contributed articles to Indoor
Environment Connections. I was advised to name none of them for fear
that I might accidentally exclude someone and come to regret it. All
the same, I can’t resist singling out a few of the people whose
contributions have been extraordinary.
Besides our staff, Indoor Environment Connections only has three
true columnists: Douglas Kladder, Carl Grimes and Harriett Burge.
Doug’s monthly column, “Radon Corner,” has kept our readers’
attention on one of the most dangerous – and preventable – IAQ risks
we know. Carl’s activism and unyielding spirit have delivered some
of our most entertaining, informative and controversial material.
Harriett’s IAQ advice column gives readers the opportunity to get
rock-solid answers to the toughest queries. Writing a monthly or
bimonthly column for several years in a row is remarkably
challenging. Finding fresh material and delivering interesting
content is something Doug, Carl and Harriett have mastered.
What we refer to as our “back-half” articles are the technical
contributions that typically begin around the center page of the
paper. Of the hundreds of people whose work has been published in
this section, none have appeared as frequently – nor received such
enthusiastic reader response – than Bill Turner and his colleagues
from Turner Building Science LLC. Their articles on schools alone
make up a resource library that every school facility manager should
have on their shelf.
During the last 18 months, we’ve worked hard to solicit a technical
contribution from every member of our editorial advisory board.
While many of its members have contributed several articles over the
years, some of them stand out not only for being truly prolific, but
also for assisting us by providing technical review of articles
submitted by others. Board members Robert G. Baker, George Benda,
Barney Burroughs, David Governo, Jim Holland, Joseph Hughes, David
Krause, Joe Lstiburek, Larry Robertson, Richard Shaughnessy, Alan
Veeck and Charlie Wiles fit this description well.
In addition to editorial board members, there are others whose
frequent and excellent contributions warrant appreciation.
Consistently high-quality, informative, lively content for our
readers has come from Jim Akey, Andrew Äsk, Bernt Askildsen, Hollace
Bailey, John Banta, Walt Black, Bob Brandys, Gail Brandys, Dan
Bridge, Michael Bowdoin, Greg Burnett, Christopher Capobianco, Mike
Casanova, Stacey Champion, Charlie Cochrane, Leigh Daniel, Quentin
Danziger, Frank Dean, Jeff Deuitch, Bob Dwyer, Aaron Engel, Chuck
Felland, Randall Fike, Dave Gallup, Clair Grant, Michael Greene, Jon
Heidelberg, Kevin Held, Tim Hoysradt, Wally Kowalski, Paul Laurenzi,
King-Teh Lin, Shelly LeVick Masters, Jeffrey May, Steve Nicholas,
Bill Palmer, Chris Ranwell, Erik Rasmussen, Jim Rosenthal, Mike
Schell, Dave Shagott, Frank Spevak, Dan Stih, Jeff Stines, John
Tiffany, Tim Toburen, Lance Weaver, Chris Willette and Steve Willis.
I wanted to single out two people in particular for their support
not only in contributing and reviewing content, but also for
providing advice, commentary and opinion regarding our newspaper’s
overall content and direction. A few years into our publishing, Tom
Yacobellis told us to drop the vanilla trade newspaper stuff, do
some serious investigative reporting and chase after stories that
make a difference in people’s lives. We listened. In subsequent
years, our reporting on the activities of agencies including the
FAA, EPA and OSHA, and associations including IAQA, EEF, NADCA,
IICRC, ASHRAE and ACGIH, included the good, the bad and the ugly.
Another of our editorial board members, Irving Brown, has been
steadfast in his encouragement for our efforts. His frequent,
handwritten missives boost morale and help us remember both the
importance of our work and the need to keep life’s activities at an
even pace.
Well, now that I’ve used almost 1,500 words to express appreciation
to all and sundry, it’s time to thank the one most important to
Indoor Environment Connections – you, the reader. It’s your support
that sustains us. Your letters, phone calls and comments make sure
our staff remembers the importance of its work and how well it is
appreciated. No matter where we go, people stop us to say how much
they love this newspaper. I’ve been a part of a lot of publishing
ventures before, but none so well-received as Indoor Environment
Connections. We look forward to bringing you the next 100 issues.
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Ask Dr. Burge – How Can I Tell if the Outdoor Spore Aerosol Is “Normal?”
Dr. Harriet Burge
Director of Aerobiology
EMLab P&K
San Bruno, Calif.
This question arises when an outdoor bioaerosol source is present that may be
impacting adjacent homes or other buildings. A few examples of this kind of
source are municipal composting and sewage treatment facilities, municipal
landfills, construction sites and, of course, farming activities. I am sure you
could expand this list from your personal experiences.
So how do you know whether activities at these facilities are changing the
outdoor aerosol in nearby (or even distant) locations, given that we are always
saying the outdoor aerosol varies naturally by orders of magnitude over very
short periods of time? Well, although you cannot prove that the facility is not
impacting the community, you can develop a hypothesis-driven sampling strategy
that will either tell you that it is or give you an indication of the
probability that it is not.
Before developing a testable hypothesis, you have to understand the nature of
the source. Is it a yard waste-composting facility, which is likely to release
thermotolerant organisms such as Aspergillus fumigatus and thermophilic
actinomycetes? Is it a sewage-handling facility where you are concerned about
the release of enteric pathogens? Is it a big harvesting operation releasing a
huge cloud of dust blowing toward the air intakes of a large building? There
are, of course, many other possible examples. The point is that you must know
what kind of organisms you are looking for, and if you don’t already know, you
will have to sample the source to find out.
Once you understand the nature of the source, which means not only knowing the
kinds of organisms, but what kinds of activities are likely to lead to aerosols,
then you can begin to develop a hypothesis and sampling strategy.
Let’s say you are dealing with yard-waste compost (since I have the most
experience in that area). The organisms likely to be released vary with the age
of the compost and the activity going on at the facility. Mushrooms are the
first invaders and activity is not necessary for aerosol formation. As the piles
heat up, Aspergillus fumigatus takes over, causing further heating, then the
thermophilic actinomycetes invade. Both organisms require disturbance for
aerosol production. Your hypothesis is, then, that basidiospores, Aspergillus
fumigatus spores and thermophilic actinomycete spores are traveling to adjacent
communities and generating unusual exposure conditions. Unusual, in this case,
means unusually high concentrations of these particular organisms in outdoor
air.
Now let’s develop a sampling strategy. For basidiospores, spore traps are the
best choice. Given that there can be massive concentrations of basidiospores in
the ambient environment, it is important to collect samples of the mushrooms
from the site so the analyst can focus on that particular type for the
spore-trap analysis. Next is Aspergillus fumigatus. It may be possible to use
spore traps here as well, although you cannot be sure you have this species
without culture. I would suggest a combination of culture-plate and spore-trap
sampling. At any rate, you must use culture-plate sampling for the actinomycetes.
Their spores are too small to be identified on spore traps. When submitting the
samples for analysis, you should request specific counts for the organisms of
concern.
Alternatively, you can request data on all organisms and select the ones of
interest yourself. To decide when to sample, you need to evaluate the kinds of
activity that occurs at the facility and develop a plan to sample during the
time when activity maximizes the probability of capturing aerosol. You can also
do control sampling when there is no activity, although it is not required. You
also will need to consider wind direction and speed and sample when the air
movement is toward the area of concern (i.e., when the area is downwind from the
facility).
Where to sample is also an important consideration. Of course, you need to
sample at the facility so you know you have a source at the time of the
investigation. You also need to sample at the site of concern, and you should
also sample upwind as a control.
How many samples should you collect? As usual, the more the better. The absolute
minimum I would suggest is five replicate or sequential samples at each sampling
site. This is because conditions can change rapidly and you don’t want to miss
any clouds that might pass by quickly. I generally do a minimum of 10 at each
site under each activity condition of concern.
Now, how are you going to interpret all of this data? First, you are looking for
increases in the specific organisms of concern. At least initially, I would
ignore all the other organisms recovered and make graphs displaying all data for
each organism (separate graphs) for each site. These graphs are useful both for
evaluating your hypothesis and for communicating your finding to the client. I
would also calculate the median and range for each organism for each site. If
the hypothesis is true, the downwind graph should show higher concentrations of
the organisms than the upwind graph and the median concentrations should be
lower at the upwind site. The degree of difference can be estimated by how much
the upwind and downwind ranges overlap. There are, of course, other tests that
can be used, but these simple ones will often be enough.
Finally, if you know that Aspergillus fumigatus and thermophilic actinomycetes
are rare in your area, why can’t you just sample in the affected community
without all the fuss? Well, if you have a database that actually documents the
absence of these organisms in your environment, you can do this. Most of us do
not have such databases
and it is not sufficient in these cases to assume that other people’s databases,
collected
in other areas, are sufficient for your purposes.
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 – Measuring Low Levels of Radon Inexpensively
Douglas Kladder
Director
Center for Environmental Research & Training
Colorado Springs, Colo.
This past December, Dr. William Fields posed the seemingly simple
question of “What is the maximum period after exposure ends that
[charcoal] labs can provide reliable results?” Like many simple
questions, the answers are not equally simple and at times can
reveal some answers we may not want to know. This simple question
may indeed be such a question. To understand the import of this
question, one needs to understand how charcoal canisters, which have
become a mainstay of the short-term radon-measurement industry,
work.
Charcoal Devices Are Like Leaking Sample Bottles
Simple charcoal devices, regardless if they are diffusion-barrier,
open-face or whatever, function as collectors of radon in the air.
These collectors are then transported to a lab where the radon can
be sampled. In some respects, they are like a sample bottle used to
collect water in that they can be shipped to an analytical facility.
However, this is where the similarity ends.
Unfortunately, unlike filling a bottle with water that is held
within the bottle until it is
analyzed, the radon collected on the charcoal device will dissipate
due to its short half-life of 3.8 days. If several days go by from
when the sample was taken to when the laboratory analyzes it, there
may be little radon, or perhaps even no discernible radon at all,
for the lab to analyze without a lot of guesswork, which is what
gives rise to the simple question raised by Dr. Field.
Returning to the sample bottle analogy, the decay of radon in the
charcoal device would be like having a hole in your water bottle and
needing to get it to the lab while there is still some water in the
bottle to sample. I suppose the answer depends on how large the
original sample was and how large the hole is as to whether there
would be a sufficient quantity for the lab technician to perform an
analysis.
In the case of radon, it is not a leak that is necessarily causing
its time sensitivity in returning it to the lab, but rather that the
radon trapped within the charcoal devices is radioactively breaking
down to a smaller and smaller sample as time goes on. For example,
if a laboratory claims to be able to measure to a lower level of
detection (LLD) of 1 pCi/L, a sample taken in an environment of 100
pCi/L that arrives at the lab four days after the end of the test
will contain a radon equivalency of 50 pCi/L, which is well above
the LLD. It could take an even longer period of time (up to 25 days)
to be returned to the lab and still be above the LLD for the sample.
However, if the environment was initially 4 pCi/L in the home being
tested, then taking eight days to get the sample to the lab could be
problematic. So the first answer to Dr. Field’s questions is, “It
depends on the initial sample. The higher the radon, the more
forgiving the delivery period can be.”
Background Activity
The lower level of detection for charcoal canisters is also a
function of the minimum detectable activity level for a laboratory.
I spoke with Shawn Price, National Radon Manager for Air Check, a
long-experienced and well-respected charcoal laboratory, about what
MDA is and what factors can influence it. According to Mr. Price and
his colleague,
Mike DeVaynes, charcoal laboratories measure the gamma bursts
released from radon-decay products that are created from the radon
collected on the charcoal during deployment. These gamma bursts, the
frequency of which is the activity of the sample at the time it is
analyzed and knowing the amount of time elapsed from when the sample
was collected and the analysis performed, are counted and the lab
can back-calculate to the amount of radon activity that was in the
room, knowing the decay rate for radon.
Sounds simple, right? It would be simple if one could just measure
the activity emanating from the charcoal device rather having to
differentiate this from other gamma in the lab. Since there is gamma
from sources all around us other than the radon sample, the lab has
to be able to discern the gamma from the radon daughters on the
charcoal separately from the gamma around us. This background gamma
comes from the earth, the sun and the universe and can mask the
gamma signal that the lab is attempting to measure from the
radon-charcoal device. If the activity from the device is much
higher than the background gamma, the amount of signal is easy to
measure.
However, if the gamma from the sample is equal to or less than the
background, all bets are off.
According to Price and DeVaynes, the ability to have a sample
activity level in excess of the MDA is directly a function of how
high the sampled radon environment was and how fast the sample is
sent to the laboratory after deployment. But it is certainly
possible to have a situation in which the amount of activity on a
delayed sample or low-environment sample is less than the background
level, and that is where concerns arise as to how this is reported.
For example, if the background gamma at a lab is equivalent to an
activity reading of 0.5 pCi/L, a sample set in an environment of 6
pCi/L would have an equivalent activity level of less than 0.5 pi/L
if it took two weeks to get to the laboratory. Does this mean, since
the activity level is not discernible, the lab would report
“non-detectable?” If so, this would be very misleading, since the
radon at 6.0 was greater than the guidance level of 4.0 pCi/L.
When I asked this question of Price, he indicated that their
laboratory reports, in which any activity less than the MDA and were
returned to the laboratory over 12 days later, were “non-reportable”
rather than being less than their LLD, which is an entirely
different result. Although we can compliment Air Chek on this
approach, one has to wonder how prevalent this same approach is
within the entire charcoal-laboratory industry.
The minimum detectable activity level is not a number carved in
stone, either. Every lab is different in its ability to both measure
background and also to minimize its effects. Most labs go to great
lengths to shield out gamma from the earth and sky with lead
shielding. Even so, some background gamma enters the detector, which
has to be measured regularly, since gamma from solar flares and
whatnot is variable. Price indicated that they measure background
many times a day to ensure that their detectors are functioning
properly and that proper gamma-correction factors are being applied.
Transporting the Device
Adding to the issue of measuring at lower levels is the environment
in which the devices are being shipped to the laboratory. Since
radon is a gas and will want to desorb from the charcoal when
heated, the temperature of the truck in which it is transported can
also make a difference if the device is not sealed.
Price indicated in our discussion that his lab has conducted tests
in which a significant amount of radon can escape a sampling device
if simple sealing instructions are not followed. In this case, the
loss of radon is like the water leaking from a sample bottle. When a
device returns to a laboratory, the lab assumes the activity on the
device is specifically due to the exposure when the device was open
and not after it was presumably closed – in which radon could leak
out or perhaps leak into the device if stored in a high-radon
environment.
Why Is This an Issue?
Since the ability to measure radon levels above a minimum
detectable activity is a function of the amount measured and the
time to return it to the lab, recent interest in measuring lower and
lower radon levels is beginning to push the envelope for charcoal
devices not immediately returned to a laboratory. With new
Environmental Protection Agency and state documents recommending
post-mitigation levels to less than 2.0 pCi/L, the need to measure
reasonably well at these low exposures is becoming more and more
important.
DeVaynes indicated that, barring transportation and deployment
issues, a device exposed to 2.0 pCi/L and analyzed two days after
the completion of the test would have a variance of 0.2 pCi/L. If
the same sample instead had been measured eight days later, the
variance would more than double that, at 0.5 pCi/L. This amount of
variance may not be a big deal when concerned about a criterion of
acceptance of less than 4.0 pCi/L, but if a homeowner wants their
radon exposure to be less than 1.5, it could make or break a
mitigation contractor guaranteeing these kinds of results.
It may appear that our ability to reduce radon levels may not only
be challenged by our mitigation technology but also by our
measurement technology to validate such reductions. Alternatively,
we may need to turn to more sophisticated devices than charcoal,
which, according to Price, was initially developed to quickly and
inexpensively provide a means for consumers to easily identify
significantly elevated levels. They are not designed to measure very
low radon levels and perhaps not even to the precision of a tenth of
a pCi/L, which real estate transactions have moved to mistakenly
expect.
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 in Schools – Maintaining Good IAQ During the Winter
William A. Turner, MS, P.E.
President/CEO
Steven M. Caulfield, P.E., CIH
Senior Vice President
Turner Building Science & Design LLC
Harrison, Maine
As you read this, it has been rather cold and snowy in many areas
of the United States. In previous issues, we have focused on energy
and IAQ. In this one, let’s look at possible health issues during
winter operation.
To provide a healthy learning environment with good indoor air
quality, a building should be reasonably clean and comfortable, not
have mold growing inside it, not be over-ventilated, not be
under-ventilated and have planned air flows in critical areas.
The goal is energy efficiency, good IAQ, good occupant
comfort/productivity and reduced carbon dioxide emissions, or at
least be carbon-neutral. Let’s discuss each of these.
Reasonably Clean
The visible dirt and dust that comes into a facility comes
almost entirely from feet. A tiny fraction may come from open
windows or from occupant activities. Schools are very high-traffic
places without huge cleaning budgets, so there must be a system in
place for daily removing the tracked-in dirt and not just making a
dust cloud. This principle is very important with hard-surface
flooring as well as soft. Whatever is used – treated dust mops,
microfiber, autoscrubbers, wet mopping, near HEPA-filtered vacuums –
must remove the dirt, not just redistribute it. Burnishing or
buffing that creates dust clouds is also not desirable.
With textile flooring, the hidden dirt needs to be periodically
removed with deep extraction of some sort, or you build up soil for
a garden that germinates during high-humidity weather dampness at
room temperature for more than 24–48 hours.
No one I know expects the HVAC system to clean the floor (you could
do it, but the energy use would be very high and the cold-draft
effect unacceptable – imagine a dust-collection system with huge,
noisy fans and you get the picture). If the diffusers are dirty,
they should be cleaned periodically; however the dirt on them
originally came from the floor. This said, HVAC air filters should
be a minimum of MERV 8 or better. If your air-filter supplier does
not know what a MERV is, find a new supplier. There are lots of good
ones around. The same principal applies to your homes, too.
Reasonably Comfortable
One of the best ways we know of to make people complain of poor IAQ
is make it too cold in an all-air system in a cold climate area,
then make it too hot each afternoon. Add in over-ventilation to
contribute to the dryness, and poor cleaning practices, and you have
a great recipe for IAQ complaints.
If one looks at the ASHRAE comfort chart, running an all-air
building at 66–68 F with 10 percent relative humidity should be
expected to keep nobody comfortable short of an exercise class
gulping water. (By the way, an all-air system delivers both heating
and cooling through the air and tends to be somewhat drafty with all
of that air movement.)
If you are concerned about wasting energy operating the facility at
72 F during the occupied period, hire a good infrared camera
contractor to find and plug the gross air leaks that heat the
outdoors. This does the occupants and the planet a favor, saves lots
of fuel and reduces the heating and cooling of the outdoors.
No Mold Growth Indoors
As many roofs and wall systems leak, this is an ongoing
challenge. For the most part, porous materials that get wet need to
be dried in 24 hours or you get mold growth. There are all kinds of
water tarps now available with garden-hose barbs that capture leak
water from roofs, expansion joints and other local areas, and direct
it to a bucket or trash barrel to keep the wallboard paper, wood and
fiberglass sponges from getting wet.
If you have textile flooring in places that routinely get wet, you
likely need to stop this via a hard-surface fix or eliminate the
wetting, or you get mold growth indoors.
Utility trenches and crawlspaces are the other typical sources, or
cold walls in portable classrooms where someone left out the
insulation or failed to seal the floor joint when they bolted the
classrooms together on-site (see Planned Air Flow below). Lots of
really cold surfaces in winter sometimes leads to lots of
condensation.
Don’t Over-ventilate
In the absence of identifiable pollutant sources other than the
occupants, ASHRAE and most others recommend about 15–20 cfm of
outdoor air per person during the occupied period. In most settings,
this gives one a carbon dioxide reading of about 800–1,000 ppm. In
an occupied facility, readings much less than this at 11 a.m. likely
mean you are just plain over-ventilating, which provides little if
any benefit and, in the heating winter mode, likely means excess
dryness (more dry eyes and noses), as well as wasted energy. Why do
it if there is no benefit?
Don’t Under-ventilate
Ventilating to control bioeffluents to acceptable levels is the
essence of the ASHRAE dilutions guidelines in Standard 62.
Ten-to-fifteen cfm of outdoor air per person, depending on the
setting, is recommended for dilution of non-point source pollutants
(people). In most settings, this gives one a carbon dioxide reading
of about 1,000–1,500 ppm. In an occupied facility, readings above
1,000 ppm at 11 a.m. likely mean you need to take a real close look
at what the ventilation systems are doing and why.
Point source pollutants, such as those generated by reprographics
equipment, bathrooms, art activities, etc. need local exhaust, not
general dilution, unless you really like to waste energy (see
below).
Planned Air Flow in Critical Areas
Planned air flow in critical areas is likely the key item for
overall good building IAQ. Air should be exhausted from areas where
irritating materials are likely to occur with negative-pressure
exhausts. Typical areas include bathrooms, reprographics activity
and boiler rooms.
All photocopying and most large printing activities involve heating,
melting and drying a mixture of carbon black, styrene and iron
particles onto paper. The fugitive byproducts, including ozone, are
often irritating, so why would you purposely expose occupants to
them? ASHRAE recommends exhaust at 25 air changes per hour.
Bathrooms require exhaust by law to keep sewer gas and other odors
out of normal building breathing air. In winter, dry traps in unused
showers, sinks and floor drains also need to be addressed.
Boiler-room air should move out of the building not into it. Boiler
exhaust must discharge well above the air intakes and out of the
wake of the building if there are rooftop air intakes.
Welding, painting, cooking and other activities in kitchens and
other vocational facilities require specialized systems to direct
materials away from others. These large exhausts also require, often
by code, planned make-up air systems that should be interlocked with
the exhaust so they function at the same time.
Dirty crawlspaces and utility trenches likely need to be isolated
with sealing and exhaust so the byproducts of the stuff growing
inside move out of the building instead of into it due to normal
stack effect or suction from unit ventilator returns. We should
stipulate that “stuff” almost always grows in crawlspaces and
utility trenches.
In most cold-climate designs, roofs are designed to stay cold. For
this to occur, building air must stay out of the roof-venting area
and cold outdoor air must flow in the vented space. Hot roofs are a
different approach and can work well with enough super insulation to
counter snow depths and suitable roofing materials where the lack of
venting does not void the roofing warranty.
In many parts of the country, radon gas is a known, naturally
occurring part of soil gases, and specialty suction systems are
installed to keep the gas from passing through the school on the way
to the atmosphere.
Conclusion
Winter is a challenging time for proper building operation to
minimize the likelihood of an IAQ incident. With diligence to the
above items and others the facility staff may have learned, some
good planning for crisis intervention and a little luck, things can
go well. If the building interior gets wet in the winter, the good
news is that it can usually be rapidly dried out with some heat and
dry outdoor air. In the cooling season, wet items are a lot harder
to get dry fast enough to prevent mold growth.
William A. Turner, MS, P.E., is president and CEO of Turner
Building Science & Design LLC. He has more than 25 years of
experience in IAQ, HVAC and energy evaluation and development of
solutions for building-system problems. Turner supervises a group of
engineers, industrial hygienists, commissioning agents and building
scientists who serve owners, architects, general contractors and
construction managers. He can be reached by e-mail at
bturner@turnerbuildingscience.com or by phone at (207) 583-4571
ext. 11.
Steven M. Caulfield, P.E., CIH, is senior vice president of Turner
Building Science & Design LLC. He can be reached by e-mail at
scaulfield@turnerbuildingscience.com or by phone at ext. 14.
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HVAC Systems and Building Design – A Case Study of Unintended Consequences
Timothy D. Toburen
Consultant
Indoor Environmental Technologies
Clearwater, Fla.
According to the Law of Unintended Consequences, every action has
more than one effect and these effects always include some that are
unforeseen. Indoor Environmental Technologies recently encountered
an example of this law as it applies to modifications made to
buildings to increase their energy efficiency.
The following changes interacted to create what IET has dubbed Cold
Attic Syndrome.
- Modifications made to reduce heat gain through the attic.
- Modifications to the HVAC system to increase its energy efficiency
and ability to control humidity.
This article discusses how these energy-efficiency designs and
improvements were employed in the home and how their interaction
created significant moisture and mold-growth problems.
Reducing Heat Gain Through the Attic
The case-study home is located on the Gulf Coast waterfront, where
humidity levels are high most of the year, especially from June to
September. During these months, the dew-point temperature in the
outside air averages above 70 F and occasionally climbs above 80 F.
These dew-point temperatures equate to 110 grains per pound and 156
gpp specific humidity, respectively.
Since indoor temperature is usually recommended to be set at 78 F
and indoor dew point should be maintained below about 60 F,
maintaining comfortable indoor conditions in the Florida environment
without using excessive energy is challenging.
In most of Florida, air temperatures rarely exceed 95 F. Heat gain
through walls is not
as high as in areas like the desert Southwest, where temperatures
routinely go much higher. However, the Florida sun is intense,
resulting in high radiant heat gain to the structure. Most of this
radiant heat load is absorbed by the roof, which heats the materials
and air in the attic, which in turn transfers the heat through the
ceiling to the occupied space below. Attic temperatures in Florida
often exceed 135 F.
Several approaches have been tried to minimize solar heat gain and
therefore the energy needed to maintain comfortable temperatures:
- Ventilation reduces attic heat by exhausting hot air and pulling
in cooler outside air. This can be done passively, by use of soffit
and ridge vents, or actively with electric fans.
- Insulation effectively slows heat gain from the attic or roof to
the occupied space. There are two locations where insulation can be
installed – on the underside of the roof and on top of the ceiling.
When installed at the roof line, the attic must be of an
unventilated type, which, as we will show, has other advantages.
When insulation is installed on top of the ceiling, the temperature
in the attic itself is not lowered, but heat transfer from the attic
into the occupied space is reduced.
- Radiant heat gain can also be reduced by modifying roof or attic
construction methods.
For instance, using tiles rather than shingles reduces attic
temperatures, particularly when
barrel tiles, which provide an insulating air space between the tile
and the roof deck, are
used. Using reflective or light-colored roofing materials also
reduces absorption of radiant heat. A separate radiant barrier can
also be installed in the roof or attic.
Increasing the HVAC System’s Energy Efficiency and Ability to
Control Humidity
There are numerous ways to accomplish this. The particular systems
chosen for the home in this case study used several approaches,
including two-speed motors for both the air handler fan and
compressor. With proper controls, these systems have the potential
to efficiently remove both heat and humidity over a larger
percentage of the operation cycle and also to effectively remove
humidity during periods when the heat load on the structure is
reduced during cooler periods.
A side effect of these more efficient systems is that the air
leaving the coils and traveling through the ducts is often at least
several degrees colder than in more “traditional” systems, is colder
through a longer percentage of the operational cycle and the system,
properly sized and controlled, runs for a greater percentage of the
day. These characteristics all contribute to greater energy
efficiency and humidity removal, but, as an unintended consequence,
the outer surfaces of the HVAC ducts become colder and remain cold
longer. This surface temperature drops low enough to cause
condensation. While the ducts are insulated, the temperature of the
air inside the ducts still eventually affects the temperature of the
exterior surface of the duct.
Case Study
The home in question was first occupied in the last week of July,
2007. About a month later, the owners discovered significant
condensation occurring on HVAC duct-system components in the attic.
Building materials were getting wet and mold growth was starting.
IET was retained to investigate and make recommendations to correct
the situation.
The home is a 7,000 square foot, three-story concrete-block
structure in a waterfront location on the Florida Gulf Coast. The
moisture problems were discovered in the attic above the third
floor, where the air handler and ducts for the HVAC system
conditioning the third floor are located.
Heat gain through the attic into the occupied space was reduced by:
- Roofing with light-color barrel tiles.
- Ventilation through soffit and ridge vents. However, the ridge
vents were never actually
installed, leaving only the soffit vents to provide ventilation.
- A foil radiant barrier on the underside of the top chord of the
roof trusses.
- R30 fiberglass batt insulation installed on top of the ceiling,
with the vapor barrier facing up.
See Figure 1 for a diagram illustrating the attic and HVAC layout.

Figure 1: Diagram of attic and HVAC
system components at time of inspection.
These methods were highly successful at reducing attic
temperatures. During a week of temperature-humidity data logging,
air temperature in the attic tracked outside air temperature
closely, never exceeding it by more than two degrees. During this
week, the peak temperature in the attic was 93 F and the low
temperature was 85 F. Because the attic was ventilated, attic
dew-point temperatures also tracked outside conditions closely,
varying between 69 F and 81 F.
As discussed above, the HVAC system used in this home tends to keep
colder air moving through the ducts for longer periods than many
other systems. This results in the surface temperature of the duct
boots (the insulated box above the ceiling that connects the fl ex
duct to the vent) being colder for longer than other systems.
Exacerbating the situation, a layer of R-30 fiberglass batt
insulation above the boots means that boot surfaces are
well-insulated from even the modest attic air temperature. During
the week we monitored conditions, the surface temperature of the
duct boot varied from 63 F to 72 F.
Fiberglass insulation is highly permeable. This allows humid attic
air to easily penetrate through it, where it comes into contact with
the surface of the duct boot. Although there is a vapor barrier on
the upper side of each strip of insulation, its effectiveness is
limited because the vapor barrier is not continuous. During the week
of data logging, the surface temperature of the duct boots was
almost continuously below the dew-point temperature of the attic
air, resulting in a signifycant amount of condensation, which then
ran down onto the ceiling drywall. (See Figure 2 below)

Figure 2: Thermal image (left) and visible
light image of duct boot under insulation.
Note surface temperature reading on
thermal image.
Condensation also occurred during this period on flex-duct
insulation where it attaches to the duct-board supply plenum. The
attachment was made with a clamp installed over the outer jacket,
compressing the insulation. As a result, the insulation lost
effectiveness and the surface temperature of the duct at this point
reached condensing levels for much of the period during which we
logged conditions. (See Figure 3 below)

Figure 3: Thermal image (left) and visible
light image of plenum to flex duct connection.
Note significantly colder surfaces where duct
insulation is compressed.
Results of Investigation
IET found that the low attic temperature, the colder-than-usual air
in the ducts and the high humidity of the attic air interacted to
produce significant condensation on duct-system components not
adequately insulated for the conditions. Condensation was especially
severe on the 14 duct boots located on the third floor. Given
sufficient time, this condensation would result in extensive mold
growth on drywall and other materials around the affected areas.
Options for Correction
Two approaches were considered:
- Significantly increase the surface temperature of the affected
duct components.
- Reduce the humidity of the air contacting the affected duct
materials.
Approach 1 can be achieved by significantly raising the temperature
of the air passing
through the ducts. However, this would require major modifications
to the HVAC system, which the homeowners wanted to avoid. Such
modifications would also be likely to reduce the energy efficiency
of the system.
Another way to implement Approach 1 is to add sufficient insulation
to the affected duct components. Due to the difficulty of access to
all affected points in the complex attic, this option was also
rejected.
To implement Approach 2, the attic must be isolated from the outside
air, the source of the humidity. IET’s research found extensive
documentation showing unventilated attics to often be more efficient
in hot/humid climates when properly designed and constructed.
Unventilated attic systems have been controversial in Florida, but,
after a 10-year battle, the local code authorities have recently
agreed to allow unventilated attics without a variance.
At present, the most effective way to insulate an unventilated attic
seems to be spray-foam insulation applied to the underside of the
roof system. This turns the attic into a semi-conditioned space
inside the pressure envelope. Having the ducts inside the pressure
envelope has the highly beneficial side effect of eliminating HVAC
duct-system leakage as a contributor to negative-pressure issues in
the occupied space. Negative pressure is a major cause of humidity
problems in hot/humid climates. Spray foam insulates well and
ensures thorough sealing against outside air penetration into the
attic. For the case-study home, implementing this approach would
require removing the radiant barrier and the batt insulation on the
ceiling. (See Figure 4 below)

Figure 4: Diagram of modifications needed
to seal attic and insulate at roof.
Application of the spray foam to the roof is a simple process
when done during construction, but can be quite challenging when
performed as a retrofit. Due to the complex nature of the attic in
this home and the resultant difficult access to some sections, spray
foam application to the underside of the roof was regretfully
abandoned
as an option, although it was recognized by all concerned as the
best solution.
The remaining option, in simplified terms, has been described as
“Seal the vents and stick a dehumidifier in the attic.” This
approach is not ideal. Even with soffit vents sealed, this attic was
not designed to be air-tight, so humidity will continue to
penetrate. The dehumidifier required to remove this humidity, when
operating, adds to the energy usage of the home. The pressure
envelope for the home remains at the ceiling, leaving the HVAC ducts
in the attic outside the envelope. This means any HVAC-system leaks
will contribute to negative pressure and humidity control issues in
the occupied space.
However, “seal and dehumidify the attic” was a viable approach in
this particular case, in which the owners wanted to avoid the
disruption that would be caused by major modifications to the home.
We expect this dehumidifier will operate primarily from June through
September, when average dew point in the outside air is above 70 F,
with less-frequent operation during spring and fall months.
Dehumidifier run time will primarily be a function of how airtight
the newly sealed attic will be, a factor which cannot be quantified
in advance. See Figure 5 for an illustration of this approach.

Figure 5: Diagram of modifications needed
to “seal attic and install a dehumidifier.”
Recommendations to the Client
IET’s recommendations to the client were as
follows:
- Seal the soffit vents. This work can be performed from the
outside, minimizing disruption for the residents. Also, seal other
accessible openings between the attic and
outside air.
- Install an energy-efficient dehumidifier in the attic. Initially,
set the humidistat at 65 percent. Ideally, the humidistat would be
controlled by dew point rather than relative humidity. However, we
have not yet located a reasonably priced humidistat of this type.
- Flex duct connections to the duct board plenum were relatively
accessible. Modify these connections to minimize compression of the
insulation, allowing it to retain its R-value.
- Monitor humidity conditions in the attic to ensure the dew point
remains below 65 F. As experience is gained with the system,
adjustments to the humidistat set point may be
needed, with the goal of minimizing energy usage while still
preventing condensation.
Preventing Cold Attic Syndrome in New Construction
Cold Attic Syndrome may develop in ventilated attics in hot/humid
climates when one or more of these factors apply:
- Ambient temperatures in the attic are unusually low.
- The HVAC system produces colder-than-usual air and/or runs for
longer periods than usual, resulting in colder surfaces on system
component surfaces for longer periods.
- Permeable insulation is installed at the ceiling, insulating
HVAC-system components from the heat of the attic, but still
allowing humid air to contact these components.
In most cases, the most effective way to prevent Cold Attic Syndrome
is to move the
pressure and thermal envelope to the roof by building an
unventilated attic and insulating
the underside of the roof with spray foam. If a ventilated attic is
desired, use more heavily
insulated duct-system components and install any fl ex-duct
components carefully to maintain their R-value.
All designs require careful consideration, or you may discover yet
another application of the Law of Unintended Consequences!
Timothy D. Toburen is a consultant for Indoor Environmental
Technologies, based in
Clearwater, Florida. He has worked in the restoration, remediation
and environmental consulting industries for over 35 years, serving
on the committees that produced both the IICRC S520-2003 mold
remediation and S500-2006 water damage restoration standards. Mr.
Toburen has also worked as an educator, teaching thousands of
students in mold-remediation and water-damage restoration
certifications courses in classes across North America. He can be
reached by e-mail at ttoburen@inevtec.com
or by phone at (727)
446-7717.
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