ACGIH Sets 5-year Goals in Revised Strategic Plan

Voices/Word on the Street

IICRC Pledges to Drop Claim to IEP Trademark

EEF Ignores Federal Demand to Cease and Desist

Publisher’s Perspective: Tribute to an IAQ Pioneer, Visionary

Breaking the Mold: When Silence Isn't Golden

Ask Dr. Burge: Can We Use Heat to Remediate Mold Contamination?

Unfinished Business: State of the Industry Address

How Effective, Safe and Legal is Treating Articles?

 

Teachers: Schools in Disrepair, Lack Needed Funds
By Steve Sauer

A report by the Washington, D.C.-based American Federation of Teachers draws attention to poor indoor environmental conditions plaguing schools in the United States and presents information about the ill effects of such conditions on the mission of schools.

The AFT report, which was endorsed by the Indoor Air Quality Association shortly after its release last month, summarizes more than a dozen sources on the effects of poor air quality on learning, health and staff retention. Also addressed in the report are the consequences of poor acoustics and overcrowding.

To illustrate the problem of “inadequate unhealthy and unsafe public school building conditions,” the report includes vivid photographs taken inside schools by AFT members who are not identified. One published photo depicts a neglected air vent, while another image shows an HVAC system that has been patched up with cardboard and duct tape.

Yet another shows desks that have been lined up to face learning aids inside a janitor’s closet. The overcrowding of schools often results in a shift of the learning environment into poorly ventilated areas not designed for occupancy.

A U.S. Department of Education statistic highlighted in the AFT report says a lack of space in schools is forcing some teachers to share classrooms with others; this was true in 28.7 percent of public schools in 2003–2004, says a statistic found in a report issued last year by the department’s National Center for Education Statistics.

Quotes from teachers and school staffers all around the United States throughout the report also help to document that the problems are more than just isolated incidents but represent a widespread problem in need of action. One teacher in Guam, responding last year to a survey AFT conducted of its members, spoke of a particular problem at school: “I believe learning is affected when it rains in the room.”

The technology coordinator of a school computer lab in Minnesota wrote of “leaks and even the occasional icicle from my computer lab ceiling, asbestos coming up off the floor,” and that “the exterior walls are crumbling.” The technology coordinator added, “We feel forgotten by our community and state and federal funding.”

The AFT presents possible solutions at all three levels, calling first for the passage of federal legislation it says would “make $24.8 billion in school modernization bonds available for construction of new schools, and renovation and modernization of existing schools.”

The report also credits three states for their recent actions in improving school IAQ, such as California’s research into the IAQ problems in portable classrooms and the state’s requirement for annual HVAC inspections at schools. Also according to the report, Connecticut has mandated that school boards adopt IAQ maintenance programs, and both states as well as Maine require routine inspections of school facilities.

AFT’s report compiles a history of government documents and other sources issued between 1995 and 2006. One recent source is an article from the April 2006 issue of American School & University magazine conveying that “as the nation’s school buildings age and deteriorate, spending on maintenance and operations remains paltry, especially when compared with historical figures.” Based on a questionnaire of business officials at public school districts across the United States, the magazine reports that in 2003–2004, “the median school district spends 7.58 percent of total district expenditures” on maintenance and operations, compared to expenditures of 9.59 percent 10 years ago.

Another recent citation in the AFT report comes from a 2004 Department of Education report by Mark J. Mendell, which finds “the overall evidence strongly suggests that poor environments in schools, due primarily to effects of indoor pollutants, adversely influence the health, performance, and attendance of students.”

The release of this report on Dec. 4 kicked off a week that would also include a pair of annual meetings concerning IAQ in schools that took place in the nation’s capital. On Dec. 6, the first of these two was of the Coalition for Healthier Schools, coordinated by Claire L. Barnett of the Healthy Schools Network. This meeting included a two-hour panel discussion on the health effects of mold, featuring John Bonnage, a Council-certified mold remediator, who presented a broad discussion of what mold is and how it affects people.

The other event, held Dec. 7–9, was the seventh annual Indoor Air Quality Tools for Schools National Symposium hosted by the U.S. Environmental Protection Agency. The EPA presented Excellence Awards to seven school districts in six states during the event. AFT was among organizations endorsing a Nov. 27 letter expressing concern with the selection of one Excellence Award winner because, it said, the district includes a school fined $22,000 earlier in the year by a state health department for an asbestos violation.
 

ACGIH Sets 5-year Goals in Revised Strategic Plan;
Revised Ethics Code for CIHs to Be Approved by July
By Steve Sauer

A long-range strategic plan released last month aims to position the American Conference of Governmental Industrial Hygienists as the “dominant resource for the integration and exchange of scientific and technical knowledge” for its members. The two other main goals outlined in the professional organization’s plan are to become “a leading source for information and knowledge about occupational and environmental health” and “a powerful force for creating an environment to improve worker health.”

To realize these goals, ACGIH gives itself three to five years beginning with implementation this year. The plan intends to ensure the organization’s success in continuing in its mission of “advancing occupational and environmental health.” Strategies to be employed include an overhaul of professional membership categories, a reevaluation of committee structure, increased member involvement in committees, enhanced visibility at professional conferences, and better uses of technology.

The strategic plan is a collaborative effort involving the work of ACGIH’s senior organizational staff, invited members and the Board of Directors, who met July 15 with Bud Crouch of Tecker Consultants LLC, a professional consultant to voluntary association boards.

“The existence of this strategic direction and its successful implementation signals the Board’s desire to lead ACGIH via a more formal strategic planning leadership approach,” reads the plan. “Developing a strategic direction is not a one-time event, but an ongoing commitment and process to lead the Association in a strategic orientation. The strategic direction represents a compass that will be used to guide ACGIH’s future strategic decision making and ongoing operational work.”

Trends inside and outside the industrial hygiene profession are listed as having shaped planners’ strategies for resurging membership and leadership. For instance, the plan cites a U.S. Bureau of Labor and Statistics estimate expecting overall employment of industrial hygienists to stagnate over the next eight years. Meanwhile, the plan reports that the responsibilities of health, safety and environmental professionals are broadening.

In calling for ACGIH to “review and update professional membership categories,” specifically identifying three ways to do so. These are “evaluating the anticipated impact to the organization of a change in professional member categories; educating and engaging in discussion of the need for review and possible change; and developing position/recommendation for professional member category or categories.”

In addition, the plan observes that “the outsourcing of government jobs to contracting companies” is a trend that in turn “reduces the pool of professional resources available” to serve as ACGIH leaders. It also says that “federal agencies are not allowing employees to participate in ACGIH leadership roles.”

Strategies to combat such factors include “identifying more opportunities for members to participate” and “offering equal participation for all committee members,” the plan states. It also directs the organization to “offer tangible benefits for member participation” and to “increase ACGIH’s international reach through the better use of technology for meetings.”

Addressing the need for a technological “platform to readily deliver or provide access to members’ resource needs,” the plan poses the popular user-created Internet resource Wikipedia as a model. It says such a resource would provide for the “integration and exchange.”

The plan also includes an increase in “strategic partnerships to grow indispensable membership resources,” “non-dues revenue,” “ongoing membership scanning and market research,” and “positive member feedback concerning new programs and services.”

Board Chairman Robert D. Soule had placed improvement of the strategic plan as a major goal during his term. In a release last month, Soule thanked those who contributed to the plan’s completion. “I have been blessed with a dedicated Board of Directors who pitched in and helped me to accomplish a goal I had set just a little more than a year ago,” he said.

An earlier announcement last month said certified industrial hygienists would soon be bound by revised ethical standards that would be easier to enforce than the current code. A letter dated Dec. 1 informs members of ACGIH and the American Industrial Hygiene Association that the organizations representing their profession would be pursuing the development of “a new, enforceable Code of Ethics for all who are certified by ABIH [the American Board of Industrial Hygiene].”

The leaders of all three organizations signed the letter alongside Dr. John R. Mulhausen, president of the Academy of Industrial Hygiene. Newly proposed changes to the code of ethics shared by these four societies since the 1980s would mark the first revision of them since 1995. The new changes are to take effect before July. The code is mandatory for all ABIH-certified industrial hygienists and associate industrial hygienists.

Professional ethics was among the top five issues of overall importance identified in a survey of AIHA members, according to results released Dec. 8. AIHA’s biannual policy survey pertains to issues within the association, with Occupational Safety and Health Administration regulations, and legislative issues.

ACGIH, AIH and AIHA are to “develop guiding membership or professional conduct principles that do not include an enforceable process,” according to their joint letter with ABIH. For that organization, which – unlike the others – is a credentialing body, a separate path of developing “new, enforceable membership ethical standards and complaint procedures,” was selected.

ABIH said it is developing a code “that will identify appropriate professional conduct standards” and also “bind all ABIH certificants to specific, minimum rules of behavior.” The proposed changes would stop short of creating a disciplinary system, the letter said.

“To support the mandatory ABIH ethics system, the IH professional associations and AIHA’s Academy of Industrial Hygiene have determined that a complementary, and more general, set of guidelines should be implemented to assist all association members in understanding their ethical responsibilities,” the announcement states. “The primary goal of these principles of responsible conduct will be to educate members, the profession, and the public concerning acceptable behavior norms in harmony with ABIH requirements, rather than to create a disciplinary system.”
 

WORD ON THE STREET

VOICES

“Play-Doh, apple cider and paint.”

— Sixth-grader Lina Sheremet of Baker School in South Brookline, Mass., describing for a Brookline TAB reporter the lingering smell that remained in the school a day after health officials cleared the air inside, following an antifreeze leak in the basement that had prompted an evacuation and sent 36 students to seek medical treatment

TOXICITY ASSESSMENT LACKING IN MONTANA
Sen. Max Baucus has threatened to call for a congressional hearing into an asbestos cleanup in his home state of Montana in which the U.S. Environmental Protection Agency did not follow its own internal guidance. In Libby, Mont., the EPA failed to complete a comprehensive amphibole asbestos toxicity assessment, said Bill A. Roderick, the agency’s acting inspector general, in a report last month. Such an assessment is necessary to determine the safe level for human exposure, he said; without it, people in the area might have become ill or, if ill already, gotten worse. “Heads should roll at the EPA,” Baucus said as the report was released on Dec. 5. Roderick requested that EPA Region 8 Administrator Robbie Roberts respond to the report within 30 days. Baucus is a senior member of the Senate Environment and Public Works Committee, which oversees the EPA.

FREE GAS BOILER REPAIR OFFERED
Some gas boilers designed for indoor installation have been recalled after their manufacturer received a report of high carbon monoxide levels in the flue gases. Crown Boiler Co., the Philadelphia-based manufacturer of the Bermuda BSI and Cayman CWI series gas-fired boilers, is offering free repairs to consumers due to a possible poisoning risk, a news release said on Dec. 19. No injuries were reported, the U.S. Consumer Product Safety Commission said. Machines impacted by the recall were sold between October 2002 and October 2006. Consumers not already contacted by their contractor were instructed to contact their installer or Crown Boiler Co. immediately. The company can be reached online at www.crownboiler.com or by phone at (877) 597-3321.

The EPA reissued its advice on protecting against carbon monoxide exposure last month because, it said, “recent power outages caused by bad weather have prompted people to turn to generators and other alternative sources of power, heat and light.” It warns against using fuel-burning appliances inside or within 10 feet of air intakes including windows and doors. The EPA advice also says to check vents and chimneys “to assure that debris does not block or impede the exhaust from water heaters and gas furnaces.”

TEST KIT TECHNOLOGY PERKS UP
Four companies in the IAQ industry recently collaborated on a new line of allergen and mold test kits for use in homes by homeowners, physicians, real estate professionals, home inspectors or anyone concerned about air quality. The aptly named Examinair is a do-it-yourself kit that can be used to take accurate and professional air samples using a volumetric air sampler. Following instructions provided with the package, users collect three indoor and one baseline outdoor air sample, which are then sent to an accredited laboratory using a prepaid shipping container. The sampling pump automatically collects the proper volume of air with the push of a button, and air samples are drawn into Micro 5 air-monitoring cassettes. The lab analyzes for potential indoor air contaminants such as dander, skin cells and hundreds of species of mold before returning a full analysis report to the customer. Each client also receives a 20-minute phone consultation with an IAQ professional about air quality concerns and result interpretation. Examinair results from a partnership among Environmental Monitoring Systems, QLAB, SanAir Technologies and My Healthy Home LLC. For purchasing or business development, Caroline Blazovsky of My Healthy Home can be reached by e-mail at caroline@myhealthyhome.info or by phone at (866) 743-8563. For product information, Marilyn Jordan of Environmental Monitoring Systems can be reached by e-mail at marilyn@emssales.com.

EPA REOPENS PUBLIC REVIEW OF MATERIALS
Two EPA offices worked in December to gain more feedback from concerned individuals regarding agency initiatives. A second 60-day review period of the EPA’s pesticide product review and re-registration procedures was expected, said Tracy Lantz of the EPA’s Office of Pesticide Programs. Records show that only 12 comments during a 60-day public review of the proposed new federal rule, which would distinguish antimicrobials intended for use on HVAC systems from products not specifically intended for such use. Lantz said reopening the comment period would allow the agency to hear from stakeholders who did not comment during that previous 60-day period, which expired in November. Official details of the second comment period had yet to be announced by press time, but Lantz said the new comment deadline could be as early as Feb. 25.

To view the proposed rule or to comment, reviewers must visit www.regulations.gov, click on “Advanced Search” and then “Docket Search,” and input EPA-HQ-OPP-2006-0351 into the “Docket ID” form, and then scroll down to click on the “Submit” button. For further assistance, Lantz can be reached by e-mail at Lantz.Tracy@epa.gov or by phone at (703) 308-6415.

Proposed moisture-control guidance released by the EPA’s Indoor Environments Division was re-released last month, although the comment period may have already ended before readers received this newspaper. The division’s Eric Werling describes the document as “practical, ‘how-to’ guidance and information for designers, construction trades, and facility managers on controlling moisture in non-residential buildings.” The document is titled “Moisture Control in Public and Commercial Buildings: Guidance for Design, Construction, and Maintenance Professionals.” Werling requested that professionals provide their feedback to “help ensure the final guidance document and website are accurate, informative, practical, and useful.” However, an e-mail on Dec. 15 says feedback would be accepted only through Jan. 19.

In case the deadline has not passed or was extended, a look at the proposed moisture-control guidance was available to reviewers by visiting www.cadmusgroup.com/dev/moisturecontrol/splash.html and submitting the case-sensitive username CadmusGuest and password Steelhead* (including the asterisk).

WHY BROKE COLLEGE STUDENTS CLEAN THEIR HANDS ON THE FRIENDLY SKIES
Think aircraft cocktails cost too much? There may apparently be a cheaper way to get your alcohol buzz when you’re at cruising altitude aboard a commercial jetliner. When you open up a pack of those alcohol-moistened wet wipes designed to clean your hands, you could be releasing unacceptably high levels of acetaldehyde in cabin air, according to a study that was scheduled for publication in the Jan. 1 issue of Environmental Science & Technology.

Existing air-filtration systems in aircraft cabins are said to remove airborne particles but not volatile organic compounds that may cause eye and nose irritation. In simulated seven-hour flights in this study, scientists tested two prototype air cleaners that combine existing filtration technology with photocatalytic oxidation that may additionally remove those VOCs. The scientists’ verdict on the technology? Go back to the drawing board. However, Dr. Armin Wisthaler of Leopold-Franzens University in Innsbruck, Austria, and colleagues in Denmark and the United States reported that seemingly trivial events like the opening of moist towelettes or other hygienic products can have adverse effects. They added that alcohol also can get into cabin air from alcoholic beverages, cosmetics and medicines.

The Institute of Inspection, Cleaning and Restoration Certification is to give up its possession of a trademarked term used in the S520 mold-remediation standard, under a plan approved twice last month: first by the S520 Standards Revision Consensus Committee and then by IICRC’s Executive Committee.

This latest development, announced just days after the committees voted in favor of it, is widely viewed among various industry factions as having removed a hurdle from the path toward gaining industry acceptance of the “Standard and Reference Guide for Professional Mold Remediation.”

Under the IICRC’s agreement, the term “indoor environmental professional” and its acronym, “IEP,” will continue to be present in the document when the next revised version is made available to the public. IICRC said that a chapter titled “Indoor Environmental Professional” would remain. The currently published version of this chapter identifies the various duties of an IEP, which include microbial assessment and post-remediation verification.

The consensus reached on this point has curtailed speculation that IICRC, in seeking to trademark the two terms, would attempt to create a certification program administered by the Institute with required courses taught by IICRC training providers. Some individuals who either had participated on the S520 Committee or were outsiders commenting on last year’s public review had perceived IICRC’s successful 2005 acquisition of a trademark on the term “indoor environmental professional” as the first step toward implementing a program to certify IEPs.

Some had further argued that if the standard specified a specific certification program, it could be accused of violating a rule set by the American National Standards Institute against promoting commercial interests, thereby jeopardizing the possibility that ANSI would approve a revised S520.

Instead, under the approved plan, the revised S520 document is to contain a statement that “negates the ability to trademark the terms and the ability of anyone to use the terminology as a designation or certification,” says IICRC. The statement would be “developed and approved by the S520 Consensus Body for insertion into the IEP Chapter, or possibly the Foreword. ... This language is intended to remove any economic incentive associated with use of the terminology, to the extent possible.”

U.S. Patent and Trademark Organization records show that IICRC had filed on Oct. 1, 2003, to trademark both terms. A page on the IICRC Web site that appeared for a few months in 2005, detailing an “IEP Certification/Designation” was used in the two separate filings to demonstrate both terms being used in commerce. Records accessed on Dec. 21 showed that the registration of “indoor environmental professional” was granted on Sept. 27, 2005, and that the registration of “IEP” was pending.

“Thousands of IICRC registrants are engaged in mold remediation projects around the world, and in order to best serve the consumer, they need strong working relationships with IEPs,” IICRC President Ruth Travis said in a news release issued Dec. 13. “It is my hope that qualified IEPs across the industry will step forward in a proactive effort to work with IICRC registrants to perform the services needed to help consumers return to safe, clean environments and to achieve this important industry goal.”

Various industry stakeholders’ reactions to the IICRC announcement were overall positive –including Indoor Air Quality Association President Bob Baker, who said in a statement on Dec. 13 that he was pleased to learn of IICRC’s latest move.
“IAQA commented during the S520 peer review that the terminology ‘indoor environment professional’ and ‘IEP’ be removed from the standard,” said Baker. “We had more than one basis for this position, but our key concern was IICRC’s [trademark] of the terms. By relinquishing the trademarks and simultaneously taking steps to protect the misuse of the IEP terminology by others, IICRC appears to satisfy some of IAQA’s major concerns on this issue.”

Baker, who is the chairman of BBJ Environmental Solutions in Tampa, Fla., resigned as chair of the S520 Committee on Nov. 28, citing the controversy over the terms’ trademark status, and subsequently declined IICRC’s invitation to attend the S520 Committee meeting held Dec. 7–9 in Tampa.

It was during the second day of this three-day meeting that the committee’s discussions regarding the IEP issue took place, sources on the committee said. The meeting was led by IICRC’s standards consultant Larry Cooper, who was appointed as interim chair following Baker’s departure from the position and from the S520 Committee at large.

In his statement, Baker said he would reserve his final judgment on the revised standard until he sees a copy. “IAQA has not received an official reply from IICRC on its comments to the draft S520, nor has IAQA been provided with the latest draft,” he said. “Until these actions have taken place, it is not possible to say if the association’s concerns have been adequately resolved.”

A spokesperson for the American Industrial Hygiene Association, speaking to IE Connections in an interview on Dec. 20, said he was satisfied overall with the results of the Tampa meeting. “As to the trademark issue, I am sure many others agree with AIHA when I say that we are pleased they recognized the problems created when trade marking the IEP,” said Aaron Trippler, director of governmental affairs for AIHA. “This issue was one of the most controversial with many stakeholders and IICRC recognizing that there was considerable concern. To allow the trademark to disappear, provide clarification within the standard, and have all stakeholders agree to keep the term free and clear is a good decision.”

In the eyes of Charlie Wiles, executive director of the American Indoor Air Quality Council, the latest from IICRC could represent an olive branch extended to industry stakeholders that might have previously felt alienated. In a one-sentence statement provided to IE Connections on Dec. 17, Wiles said, “While the American IAQ Council doesn’t believe IICRC’s recent actions represent a consensus of the industry, we do believe they are a great first step to rebuilding bridges.”

As a result of the approved plan, IICRC said a written clarification would be “developed to specify the qualifications necessary for a competent IEP” and published separately from the S520. Also according to the plan, the revised standard would also fall short of listing specific designations or certifications “deemed equivalent to the definition of IEP.”

Trippler expressed his reservations with the portion of IICRC’s announcement that says the qualifications for an indoor environmental professional term could be defined at a later date. “While I am pleased that they are going to specify what the qualifications are for the IEP, I am somewhat concerned about what the qualifications will be and who will determine the qualifications,” he said.

Another point of contention for Trippler, he said, lies with the way the term is being used. “I do wish they would have gone one step further and considered making the term ‘indoor environmental professional’ more of a generic term rather than having it defined as a ‘title,’” Trippler added. “Perhaps moving the term to the reference portion of the standard would have been a step in the right direction.”

One further point under the approved plan says that IICRC and other industry organizations are to collaborate on protecting the term from being misused. In making this statement, IICRC revealed that it had earlier been approached with a draft memorandum of understanding with that goal in mind. IICRC said it would “seek to enter into a revised memorandum of understanding (MOU) with IEP stakeholders that establishes an agreement to mutually defend against third parties attempting to trademark the IEP terminology.”

“IAQA certainly expects to be among the stakeholders convened by IICRC to develop the MOU on IEP,” said Baker. “That’s a critical part of the IICRC plan, and it must be carried through with support from major organizations in the IAQ and restoration industries like AIHA, ASHRAE, IAQA, ASCR and NADCA.”

Don Manger, executive director of the Association of Specialists in Cleaning and Restoration, told IE Connections on Dec. 15 that his association “is encouraged by this affirmation of the consensus process. For more than a year, the issue of IICRC’s 2003 trademark application for the IEP name has been a subject of discussion in the back channels of the industry. The decision of the S520 Consensus Committee will allow the standard to move forward free of this encumbrance and with greater confidence in the integrity of the standard. ASCR has expressed to IICRC its willingness and enthusiasm to work with all of the interested industry organizations in helping IICRC accomplish the intentions of the Consensus Committee.”

Tom Yacobellis, who had served as the National Air Duct Cleaners Association’s official representative to the S520 Committee until his resignation from that position in late November, did not participate in last month’s Tampa meeting. John Schulte, executive director of NADCA, said the association had not yet replaced Yacobellis with anybody and was therefore not represented at the meeting.
“NADCA has expressed our interest in appointing a new representative to the S520 Committee, and we look forward to continuing to support development of the S520 Standard,” Schulte told IE Connections in a statement received Dec. 19.

David Fetveit of the Indoor Environmental Standards Organization provided hopeful comments to IE Connections on Dec. 13. “I applaud the IICRC for their proactive approach to resolving a potentially divisive issue,” he said. “Their desire to build working relationships with multiple organizations on this and future issues will continue to improve the industry. As a fellow ANSI-accredited standards-making body, IESO looks forward to cooperation on the IEP issue and perhaps other standards activities.”

AIHA’s Trippler said he was pleased that IICRC paid attention to the concerns of his association. “Obviously they agreed with some of our points and disagreed with others,” he said. “But the discussion was one where everyone had an equal input.”

Other invitations extended to industry organizations, according to IICRC, were to the American Conference of Governmental Industrial Hygienists, the Indoor Environmental Institute, and the Society of Cleaning and Restoration Technicians.
“I think it’s a start,” said Trippler. “Where we go from here will be the key.”

IICRC said Cooper will continue to chair the S520 Committee until a successor is named. The committee’s vice chair is Clifford Grost.

An attempt by the federal government to curtail the spread of allegedly misleading information regarding the U.S. Environmental Protection Agency’s past contract with an IAQ industry organization has been ignored, an EPA official said last month.

A letter sent Oct. 3 by Geoffrey Cooper of the EPA’s Office of General Counsel in Washington, D.C., directs the Environmental Education Foundation to “immediately cease and desist from implying a misleading connection to the Agency and from using any EPA mark in its advertising or other public displays or in soliciting business.”

The letter, a copy of which was obtained by IE Connections on Dec. 11, says that EEF’s placement of the EPA logo on its Web site “in a way that implied that EPA sponsored EEF’s services” violates EPA policy that “prohibits the use of the mark in connection with the sale of commercial products or services.”

The letter further alleges that this use of the EPA’s seal violates a federal law and opens EEF up to a civil lawsuit. “The use of the EPA name and its seal in this manner is improper,” Cooper states in the letter. “It confuses the public about EPA’s connection to EEF and infringes EPA’s rights under the Lanham Trademark Act.” It cites an excerpt of that law, stating, “Any person who ... uses in commerce any word, term, name, symbol, or device ... which is likely to cause confusion as to the origin, sponsorship, or approval of his or her goods ... shall be liable in a civil action.”

The attorney representing EEF, Terry Fong of Wilson-Goodman & Fong, P.C., did not respond to a Dec. 11 e-mail from IE Connections requesting comment on the EPA’s cease-and-desist letter. EEF also disregarded instructions to comply or to respond within 30 days of receipt of the letter, said Dr. David Mudarri, the contact within the EPA’s Indoor Environments Division who one year ago brought attention to EEF’s failure to perform satisfactorily on its one-year contract with the EPA.

EEF’s contract with the EPA began on March 29, 2004, and ended, after a request for an extension was granted, on Aug. 31, 2005. In January 2006, IE Connections published Mudarri’s comments that “EEF received an unsatisfactory rating because they failed to satisfactorily meet the performance requirements of the contract.” Mudarri, who this month is set to retire from his position with the EPA’s Indoor Environments Division, also said EEF received a partial payment for work performed under contract “but full payment was not made because of their unsatisfactory performance.”

A Freedom of Information Act request fulfilled for IE Connections last January revealed that EEF’s contract with the EPA was originally worth $49,984 and that the total amount paid to EEF was $43,678.

EEF has not refuted Mudarri’s statements but instead said the EPA had forced the organization into a near-impossible situation. In a posting to the Yahoo! IE Quality Group on Feb. 7, an EEF spokesperson named Emma Chastain said, “True, Mudarri isn’t happy with the final product, the final product that IS what the industry wants and approved.....but EEF works for its members and the people who are effected [sic] by poor environmental management. We do not and will not act as a rubber stamp for the government. When it came down to either having a program the lenders, insurance companies and industry want and approve OR tow the government line and try to force the use of some pre conceived format the EPA wanted - well, we stuck with the industry professionals.”

Chastain did not expound on this claim publicly, but instead closed the post with what amounted to a gag order directed at EEF supporters. “Last, we are asking that EEF Members and Partners refrain from commenting on this issue or issuing any posts on this chat site,” Chastain’s post concluded.

Some of the partners that EEF recruited to participate on an “advisory group” in 2004 and 2005 revealed to IE Connections between December 2005 and January 2006 that EEF provided little guidance and sparsely required contributions from members. In February 2006, this newspaper quoted individuals – spanning the U.S. Department of Housing and Urban Development, the Medical University of South Carolina, the Air & Waste Management Association, and the Association of School Business Officials – who went on the record describing their dealings with EEF as minimal.

The cause of Mudarri’s concern with EEF, he told IE Connections in the interview published last January, was the long-term problem of EEF making statements regarding its contract with the EPA that could not be backed up. He said characterizations of EEF’s contracted work in public statements amounted to “a continuing problem throughout this contract. EPA repeatedly admonished EEF for going beyond the statement of work in their outreach activities.”

Mudarri posted similar comments to the Yahoo! IE Quality Group on Jan. 17, 2006, stating that “EEF is in no way associated with EPA. EPA does not endorse or approve of their services, and EPA has asked EEF repeatedly to desist from making such misleading statements and solicitations.”

EEF’s promotion of the contract with the EPA continued throughout 2006, culminating in an advertisement in the November/December issue of Mold and Moisture Management magazine that included the EPA logo and announced “the completion of this contract and the availability of the related training program.” The same message appeared on the home page of the organization’s Web site as early as November 2005 and remained unchanged as this issue went to press in December 2006. EEF included the same message in several promotional mailings throughout 2006, including in an e-mail dated Dec. 7, and the EPA logo appears on an EEF Web page listing “Partners.”

Other partners listed, symbolized on EEF materials by their logos, include the United Nations, the State of Colorado, the Texas Department of Health, and the City of Houston.

Fong’s sole contact with IE Connections on behalf of EEF was a letter dated Jan. 20, 2006, threatening legal action for reports on EEF he called “defamatory, misleading and untrue.”

IE Connections would like to recognize the contributions of an individual whose success in working to improve indoor air quality rivals that of our industry’s most distinguished colleagues. Dr. David Mudarri retires from his leadership position at EPA’s Indoor Environments Division after a career spanning more than 25 years with the agency. Mudarri is credited by many as the founder of the division.

In the early 1980s, Mudarri’s analysis of data from EPA’s Office of Research and Development led to findings of high health risk from human exposure to indoor-air pollutants. With permission granted by the assistant administrator for Air and Radiation, Mudarri and his colleagues developed a program of voluntary initiatives to protect the public from indoor pollution. Mudarri recognized IAQ as an emerging issue early – to call him a pioneer is not exaggerations – and the small Indoor Air staff he led in the mid ’80s was later expanded and restructured as EPA’s Indoor Air Division. Not long after, IAD combined with the Radon Division, and the present Indoor Environments Division was born.

My first introduction to David Mudarri was in 1990, at a meeting of IAQ stakeholders convened in Washington to talk about standards, education, training and a host of related IAQ issues. That meeting was the result of EPA’s 1989 landmark Report to Congress on Indoor Air Quality. Mudarri personally authored Volume II of the massive report. The report and others produced at that time still serves as the foundation for EPA’s program to improve IAQ through public information and voluntary action.

Mudarri authored and helped produce numerous publications and tools to advance IAQ knowledge and technique, as well as to promote action for improved public health. In 1991, he oversaw development of the influential program “Introduction to Indoor Air Quality.” It includes a self-paced educational course and reference manual.

By 1994, Mudarri’s time was primarily spent creating policy documents to exemplify the best technical analysis available on IAQ. This was during the peak of the tobacco wars, when municipal, state and federal officials were seriously considering bans on indoor smoking while fighting seemingly insurmountable resistance from the tobacco industry. As lobbyists worked both sides of the aisle, Rep. Henry Waxman requested a detailed analysis of costs and benefits attributable to smoking restrictions then under consideration. With a tight deadline, Mudarri produced a superior report. It was released by Waxman and the EPA administrator at a joint press conference on Capitol Hill. Over time Mudarri’s analysis has stood up to even the most critical reviews, as evidenced by the elimination of smoking from so many public spaces today.

Mudarri was the primary author of 2000’s “Energy and IAQ Performance of Ventilation Systems and Controls,” a seven-volume study on the relationships between energy efficiency and IAQ in commercial buildings and schools. His work showed that improving energy efficiency without sacrificing IAQ in commercial and public buildings is certainly attainable.

In 2001, Mudarri created the extraordinarily influential Indoor Air Quality Building Education and Assessment Model, or I-BEAM, a computer program that delivers outstanding information and resources for managing IAQ in commercial and institutional buildings. The quality of the materials and their easy access on the Internet has resulted in the adoption of I-BEAM by building managers nationwide.

Most recently, Mudarri once again contributed another luminous work to the essential library of IAQ guidelines. “Maintenance for Healthy, Efficient, and Reliable Buildings” is a document that embraces the newest technology in a web-based guide for integrating indoor air quality, energy efficiency, and reliable building performance through practical, cost-effective operation and maintenance programs.

In the 16 years since I first met David Mudarri, I have never ceased to be impressed by his quiet dignity and the respect accorded to him by his colleagues both within EPA and industry. Few visionary leaders in IAQ can lay claim to so many monumental accomplishments. It’s not an exaggeration to say that lifespans have increased, public health has improved, and the world has been made a better place because of the work of a single man, Dr. David Mudarri.

In her interview, she claimed to have read court documents that their “evidence-based” statement was intended from the beginning as a legal defense argument. Further, that the writers of the document were outsiders to ACOEM and were in fact from Big Tobacco. Major clues she cited for initially suspecting non-science in the guise of science were tone and pattern of documents.

So, I decided to conduct some of my own research. I’m no investigative reporter and am not qualified to evaluate the science of the report, but perhaps I could find other patterns to support either ACOEM or Mrs. Kramer.

I started by going back to a source article I identified in my May 2006 Breaking the Mold column on causality; that article, published in Environmental Health Perspectives, was called “Causality and the Interpretation of Epidemiological Evidence.” (The abstract and full article are available at www.ehponline.org/docs/2006/8297/abstract.html for free.)

Its author is Dr. Michael Kundi, with the Medical University of Vienna, Austria. Dr. Kundi discusses what has been called the “criteria of causation” for disease. To summarize the professor, there are five possible definitions of causality, each with a fatal flaw. The flaws include circular logic, criteria so loose they cannot differentiate diseases, and criteria so restrictive that they exclude known diseases.

Even without a useable definition of causation, wrote Dr. Kundi, causation can still be utilized within what he identified as the Bradford-Hill criteria. To paraphrase, any of the five possible arguments for causation cannot prove a cause (only strengthen support of a relationship), nor can they dismiss a factor as a cause (only weaken support of a relationship).

While the ACOEM’s conclusion of not plausible may fit the Bradford-Hill criteria, Kramer asserted that defense witnesses don’t stop at “not plausible,” but instead claim “not possible.”

Simultaneously, I was aware of a court case and a workman’s compensation case where the ACOEM paper was cited by the defense. In both instances, it was reported to me that the defense witness invoking the document gave testimony that included unequivocal conclusions of “no causation” rather than “not plausible.”

My next step as an amateur investigative reporter was to Google “health consensus statements.” This opened a whole new world to me that for several hours distracted me from my task of specifically exploring ACOEM.

The first major find was the Vallombrosa Consensus Statement on Environmental Contaminants and Human Fertility Compromise, October 2005. See www.healthandenvironment.org/infertility/vallombrosa_documents/.

At first glance, this seems to have nothing to do with our industry of the indoor environment. But closer examination led to direct statements implicating building materials, cleaning products and personal care products as containing the very chemicals their consensus statement implicated as impacting human fertility.
Even more revealing was how they identified and considered information that was known versus information they needed to know. The pattern and tone was exactly like Sharon Kramer identified in her interview as a science-based statement rather than a legal- or marketing-based statement.

Other Google results led me to numerous documents all with similar tone and pattern about school athletes, mental health and tobacco hazards. You have to read this one: www.annals.org/cgi/content/full/0000605-200612050-00141v1/. It strongly reinforces the Surgeon General’s recent report.

And then I found, right on the ACOEM Web site: www.acoem.org/health_productivity/consensus.asp – Consensus Opinion Statement, Health and Productivity.

As I read through this document, I mentally compared it to the documents above and to the ACOEM mold statement. As I read them, I developed an additional appreciation of Mrs. Kramer’s words. To my layman’s mind, the ACOEM mold statement is unlike any of the others I read, including those from ACOEM itself.

So, what have I proven so far? Not a thing, at least in terms of the type of evidence that would stand up in a court of law. My information was composed entirely of gossip and reports I’m not sure I fully comprehended. But it certainly raised questions in my mind about how much trust I might be willing to place in the ACOEM document or others with similar tone and pattern. I’d first want more authoritative opinions.

And then, as luck would have it, I struck gold. It started with a conversation in Nashville at the Indoor Air Quality Association conference – if you weren’t there you missed a show and half! – and the ACOEM paper was mentioned. Several people were all vociferously arguing but in a strange way. It took me several minutes to realize they were not disputing each other; they were trying to outdo each other on what were the most critical flaws of the study.

Over the next couple of weeks, I called a variety of legitimate experts and asked them their professional opinion of the ACOEM position on mold. Their professional opinions and insider specifics ranged from “strong doubts,” at best, to unprintable diatribes.

Aha! Now I had specifics from qualified experts that I could report. No more laymen’s self-interpretation, no more third-hand gossip. I now had the “smoking gun” of exactly how they would demolish the farce. With each interview, my adrenaline was pumping, and I was ready for my first journalistic scoop! All I needed was permission to quote them.

Thud.

That’s the sound of a lead balloon solidly hitting an impenetrable surface. No one, not a single expert, would go public. In fact, as soon as they denied me permission to identify them, they would quickly specify which key facts to leave out because they might be clues that would identify them.

But, I’d ask, how can you stand by while the harm continues if you feel so strongly about it? The answers could all be generally summed up as “fear of reprisal.”

It was then I remembered a quote or a phrase from somewhere that I can’t quite place, that goes kind of like this: Evil does not perpetuate evil. Silence does.

Carl Grimes is president of Healthy Habitats LLC, an indoor-environmental consulting firm in Denver, Colo. He is the author of the book “Starting Points for a Healthy Habitat” and serves on the Editorial Advisory Board of IE Connections. Grimes can be reached by e-mail at grimes@habitats.com or by phone at (303) 671-9653.

Opinions expressed herein are the viewpoints of the individuals stating them. They do not necessarily reflect the views of the organizations, companies or institutions with which these people are affiliated. Their opinions also do not necessarily reflect the views of this newspaper, its publisher, its advertisers or its industry partners.
 

I have been asked this question at least five times during the past week, and my short answer is no. The reason is that while fungi can be killed by heat, as can every other living organism, there is no evidence to support the contention that heat treatment of a house will kill all the fungi present, nor will heat destroy all of the allergens and irritants that are a part of all fungal growth.

A very small amount of research has been conducted that supports the killing of some fungi with heat such as is associated with currently used heat treatment technologies. However, the research has been done only in the laboratory, and documentation that hidden mold in houses is killed by whole-house heat treatment is not available. In fact, some anecdotal studies indicate that hidden growth in walls remains culturable after heat treatment.

An equally limited amount of laboratory research has provided some indication that heat treatment will damage some fungal allergens. However, these preliminary findings were equivocal, and no follow-up research was conducted to document them. In addition, only one fungus, Aspergillus fumigatus, was used in the studies, and this is not one of the most common fungi found growing in residences.

Finally, I have said several times that heat treatment could dry out a structure, which should be helpful in slowing or stopping fungal growth. This may be true, provided sufficient ventilation is provided to remove the water vapor resulting from the heat treatment. This fact has been pointed out to me by several experienced mold investigators. It also seems noteworthy that traditional methods of drying, like using dehumidifiers and fans, can also dry a building with the advantage of not subjecting the entire building to the thermal stress heat treatment may cause.

The bottom line is this: Based upon the information and evidence that I have reviewed, if you want to prevent exposure to fungi and the agents they contain that may affect human health, you must physically remove any growth that is likely to lead to any human contact. Biocides (quaternary ammonium compounds, bleach, ozone, chlorine dioxide) and heat, while they may kill some fungi, do not prevent exposure to the primary agents of human disease. There are very few situations in which I would recommend killing fungi before their removal. All of these involve handling of fungal pathogens (e.g., Cryptococcus neoformans associated with pigeon droppings) or Aspergillus fumigatus or other opportunistic species in hospitals.

Obviously, you can use these fungal killing approaches if you want to, but you will still have to do standard remediation that involves actually removing fungal growth.

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.

The opinions expressed herein are the viewpoint of the individual author alone and do not necessarily reflect the views of this newspaper, its publisher, its advertisers or its industry partners.

The alphabet soup that represents all of the acronyms of trade groups, societies, and associations that lay claim to indoor environmental issues is endless. The result of our fractionated identity is that there is no 1,000-pound gorilla that can walk into a government agency or stroll up the legislative hill and declare, “My industry (or membership) represents X billion dollars of gross national product, and we require and expect your support because our products and services influence the productivity, health and well-being of every citizen of this country. Our products and service result in lower national health costs, enhanced industrial productivity and gross domestic product, and lowered energy utilization with lessened national dependency on foreign oil.”

What a story and what a powerful claim that we all know to be true! But we lack the unified voice to influence either the budgetary or policy issues, which also means that we lack the respect and acceptance of builders, building owners and managers, and financial institutions that support the construction paradigm in this country. It is time we shed the “turf” mentality and unify in our efforts to communicate who we are and how our goods and services enhance the health, welfare, and well-being of mankind.

Cage the Monster
The monster is moisture. Whether in the form of rainwater, groundwater, floodwater, water vapor, humidity or condensate, it is the enemy. It enables mold growth, causes degradation/destruction of structural components, and steals energy. Water intrusion is understandable when caused by flood or equipment failure, but it is unforgivable when condensate happens anyplace but in a drain pan. Most laymen do not understand the magic of dewpoint and cannot conceive of the amount of unseen water carried in warm air.

Yet, they understand that a few degrees’ difference in temperature on a hot summer day can bring on the thunderstorm that will deliver inches of rainfall and tons of water in a few minutes. That same air enters a building and does the same thing with the same few degrees of temperature change. That phenomenon should not come as a shock; yet, it does – to lay folk and engineers alike.
In some cases, we must do better in our design and operation for moisture management, but in most homes and buildings, we simply must apply better that which we already know how to do.

• Proper equipment sizing, and especially avoidance of oversizing, assures that HVAC equipment – particularly the newer, high-SEER (seasonal energy efficiency ratio) equipment – will properly dehumidify the treated airstream without short-cycling.
• Positive pressurization of the building provides air capture and avoids random infiltration of untreated, humid and unfiltered outdoor air. This is often easier to state than in high-rise construction where powerful internal forces prevail, like stack effect. But it is especially true when unducted return-air-distribution systems create a vertical sandwich of alternating pressure layers in a high-rise building.
• Appropriate vapor/moisture barrier components and techniques will avoid the subtle and devious intrusion of moisture through the pressure boundaries through vapor pressures and capillary action.
• Immediate maintenance response when a water problem does occur – whether roof or envelope failure, plumbing incident, or design flaw – will contain the damage and avoid amplification into a threat to the occupants and the asset value of the building. Delays in remediation for any reason – whether budgetary, political or scheduling – will enable the problem to magnify beyond control.

Recognize the Enemy in Disguise
In some role or another, I have been involved in the development and editing of multiple iterations of ASHRAE Standard 62. Part of that perspective includes an era of five-cubic-feet-per-minute-per-occupant ventilation rates; the first oil crisis in 1973–1974; the early incidents of TBS, or “tight building syndrome”; and the emergence of ventilation air as the defined or implied solution to all the IAQ issues. This has been taken to the extreme when over-ventilation of buildings is rewarded by sustainability criterion and qualifications. As in the fable of the emperor’s new clothes, we must “defrock” and expose the villain. Outdoor air that is introduced to our buildings is as much source as solution. It is the primary source of airborne moisture. It is the primary source of fine particles that smudge surfaces and coat the heat exchange surfaces – the same particles blamed by cognizant authorities for causing childhood asthma. It is the primary source of ozone and other harmful oxidants. It represents a primary source of heat load and energy burden on the building. It is the primary route of external sources of airborne toxic or criminally intended contaminants of concern. Even worse, because of these inherent problems, ambient urban air does not deliver on its ventilation obligation – to dilute interior pollutants with clean and fresh outdoor air.

It is time that we stop consorting with the enemy and work equally hard toward conscientiously minimizing, not maximizing, outdoor air levels, while still maintaining appropriate air capture and pressure barriers.

Let’s Define the Target
Acceptable IAQ should not be defined in the courthouse by self-serving plaintiffs’ lawyers and expert witness opinions. Neither should it be defined by the definition of polluted ambient outdoor air. Our industry is over three decades old, and it is time to define the target of acceptable IAQ with science and consensus rather than litigation and personal opinion. ASHRAE Standard 62 employs the term “Class I air” as their answer to the definition dilemma. Class I air is arbitrarily defined by the standard as being acceptable for recirculation into the occupied zone. But they define its quality by where it has last been rather than its contaminant load. ASHRAE members have been anchored too long with a mentality and a policy of, “If I can’t see sit and I can’t measure it, then it does not exist, and therefore, it is not my responsibility to deal with it!” The hidden bottom line of this thinking is, “Therefore, I can’t be sued because of it.” And that very thing, dear readers, is what forces litigation as an inevitable outcome: when there is no industry-wide consensus standard definition of the end product, acceptable indoor air quality.

My years in this industry have not left me so naïve or befuddled as to ignore and dismiss the powerful and complex issues that such a standard definition will encounter. Nor am I unaware of the mighty political mushroom clouds that would occur from the frenzied uproar of “gored oxen.” For example, the matter starts with an acceptable definition of “acceptable.” Does that mean comfortable as implied by the current Standard 62? Does it mean safe from an industrial hygiene exposure standpoint? Does it mean healthful from a medical viewpoint? Does it mean perceived or measured? Does it apply to occupants or visitors? Is it total dosage or short-term exposure? Or is it simply complaint-free? Do you start to get the idea?

But what if such a standard definition existed? It could be incorporated into Standard 62 and building codes and would enable “the IAQ Method” (more about this later). It becomes a criterion for specifications by architects and the mechanical engineering community. It becomes a measure of fulfillment as part of building commissioning. It defines a level of expectation by builders, building owners, their tenants, and their employees. It provides quantifiable thresholds for monitoring and control. It establishes mutually agreeable performance levels for continuous compliance and performance of the building stock. It provides a measurable baseline to establish building performance degradation. It provides criterion for due diligence in property transfers. And when incidents do happen and failures do occur, it provides the comparability guidance for appropriate diagnostics and establishes third-party targets for attainment of restored performance.

Who would benefit? Answer: the entire building construction community, including homebuilders, commercial building owners and operators, architects and engineers, contractors, maintenance staff and service companies; and occupants, including, tenants, employees, homeowners, PTAs and parents, school boards, and schoolchildren. Who would lose? Answer: the plaintiffs’ lawyers, expert witnesses who sell testimony, and the IAQ testing labs who work for them. Not a bad equation, in my opinion.

The question remains: How do we walk the talk? How can we deal with the unknowns and the imponderables, such as the linkages to health effects? How can we approach this monstrous task when so many experts say more research is needed? My response to those questions is we start with what we know – or, perhaps better stated, we start with what we think we know. And we must get on with it, because every day, the exposure grows – both literally, in the form of occupant complaints, and figuratively, in the form of liability. Attempts at the task have already been launched. In the early days of the predecessor to the Indoor Air Quality Association, a group of practitioners struggling with this dilemma in Florida drafted such a document. This became published later by the current group as IAQA 101-2000, “Recommended Guidelines for Indoor Air Quality.” Lacking a mechanism for industry-wide consensus development, the association board withdrew the draft, and there it languishes. A review of the document shows that it was a gutsy and forward-thinking draft. It also remains a good starting point for a consensus document because it designates all the conditions and contaminants of concern and applies target limit numbers. It includes the physical parameters of temperature, relative humidity, pressure, and air motion; particulate levels; chemical levels, both inorganic and organic; and biological levels, both fungal and bacterial. All that remains is for the industry to agree to review, debate, edit or amend, accept, and promulgate a final guideline or standard. From that debate and consensus process, meaningful research needs will emerge that can direct future revisions and refinements. It is time to get on with it!

Give Filtration and Air Cleaning a Little Respect
The technologies involved with filtration and air cleaning are over 50 years old. When properly applied, these products provide a long list of benefits, including the engineering ability to create contaminant-free indoor environments. Yet, this technology is not widely employed by designers and building owners. That must change, because filtration and air cleaning can also impact the energy budget and even come into play when dealing the monster moisture and enemy outdoor ventilation air. The vehicle for accomplishing this is “the IAQ Method” that has been published in ASHRAE Standard 62 since 1981. This method employs filtration and air cleaning to control indoor contaminants by extraction rather than dilution. This substitutes for and reduces the quantity of needed outdoor air, which in turn reduces both the moisture content and the energy load of that portion of outdoor air displaced by FAC. The economics are powerful and conclusive, including both capital and operating reductions, as well as reduced energy budget. Engineering teams are currently reticent to employ the IAQ Method due to the lack of defined acceptability of the resulting indoor environment. With the definition in place as discussed above, the primary stumbling block is removed for the full exploitation of the economic benefits of enhanced filtration and air cleaning.

The summary and the challenge: By no means do I hold up see-all-and-end-all answers for the above issues. If it were that easy, they would already be resolved. However, the perspective of four decades in HVAC; filtration and air cleaning; and IAQ building diagnostics – and more educational seminars and papers than I care to admit – has convinced me that it is time to take on these issues. It is the only way that we can grow through the issues of “turf”; fractionated interests; and ineffectual, splintered, and self-serving efforts. It will require committed leadership, it will require time and monetary support, it will take research, and it will take education – but it is time to solve our self-limiting problems.

H. E. Barney Burroughs is a past international president and fellow of ASHRAE, a founding member of IAQA, and an active member of technical and trade associations relating to IAQ, HVAC and filtration. He headed the ASHRAE Standard 52.2 committee on testing of particulate filtration, and has been a member of numerous industry committees on various topics, including a current position with the ASHRAE 62.2 residential ventilation committee. Burroughs held the patents for and founded Purafil Inc. and is currently the CEO of Building Wellness Consultancy Inc. He can be reached by e-mail at heburroughs@mindsprings.com or by phone at (770) 594-1877.

This sounds like a perfect strategy for getting rid of all of those pesky microorganisms that irritate us, damage surfaces and can be a health risk. But is it? The answer is far from a simple yes or no.

This article will explore some of the factors that should be considered when attempting to make a decision on whether or not to “treat” an object or surface. There are three questions that must be asked when considering an antimicrobial treatment (or adding an antimicrobial to a product or its surface):

• Does it work?
• Is it safe?
• Is it legal?

None of these questions has simple answers, so I will save the best for last and discuss them in reverse order.

Is It Legal? Regulatory
The U.S. Environmental Protection Agency, which regulates the use of antimicrobial products and the claims that can be made related to such uses, does recognize antimicrobial treatments and permits their use under tightly defined rules. These rules were reviewed and clarified in the late 1990s.

When the public began to be aware of the risks or bacteria, viruses and fungi on surfaces (especially viruses and bacteria) in the late 1980s and early ’90s, there was a significant interest in ways to protect from possible adverse health effects. Much of this concern was driven by the linking of a dental practice in Florida to the transmission of AIDS in several cases. As a direct result of this situation, hygiene practices in most healthcare, and especially dental offices, were dramatically changed. It became routine practice to disinfect surfaces after each patient left the treatment area. Hand washing, use of masks, gloves and covers for areas likely to become contaminated were put in place as normal procedure.

At the same time, the public began to show interest in ways they could be safer at home and in the workplace. A number of new products came on to the market along with claims that they would provide a higher level of protection from disease transmission. Many of these, including disinfectant sprays that could conveniently be used to disinfect surfaces and protective gloves to wear when handling possibly contaminated items, were clearly beneficial and provided value to consumers.

Unfortunately, others introduced at the time were of questionable value and soon attracted the EPA’s attention. One of the most notable of these was a cutting board manufactured with an antimicrobial additive; advertising suggested that a homeowner could use the cutting board to cut up chicken that may be contaminated with bacteria and then use the same cutting surface to cut up salad ingredients without worrying about the bacteria contaminating the salad. Another product was a treated pen that supposedly could be used by many different people without any risk that bacteria or viruses would be carried from one user to another.

Because such products had the potential for health risks if the claims were not valid, the EPA closely studied them and ultimately determined that although some reduction of levels of bacteria might be expected, a claim of absolute protection from disease by using these products was unreasonable. In August 2003, the EPA followed up this review, issuing a clarification of the Treated Articles Exemption.

Under this clarification, claims for treated articles or substances are limited to the following statement: “This product contains a preservative (e.g., fungicide or insecticide) built-in or applied as a coating only to protect the product.” As an example, the agency provides the following statement: “Antimicrobial properties are built-in to inhibit the growth of bacteria that may affect this product. The antimicrobial properties do not protect users or others against bacteria, viruses, germs, or other disease organisms. Always clean and wash this product thoroughly before and after each use.”

The clarification also says that treated kitchen accessories or other food-contact articles – e.g., cutting boards, high chairs, conveyor belts that may come in contact with food – should carry an appropriately qualifying statement, such as: “This product does not protect users or others against food-born bacteria. Always clean and wash this product thoroughly before and after each use.”

The clarification also provides for another qualifying statement for treated products that involve potential human contact with bodily fluids (such as blood, vomit, saliva and urine) or excrement. For this reason, bedpans and toilet seats are among products that should carry an appropriate qualifying statement such as “This product does not protect users against bacteria, viruses or other disease organisms. Always clean and wash this product thoroughly before and after each use.”

As a result, a manufacturer of a treated article who wants to make claims beyond those that are stated above or does not want to include the required disclaimers must obtain registration for the specific product and label claims by developing extensive test data and submitting to the EPA’s Antimicrobials Division for review and decision. Only a few manufacturers have done this, and their products can be identified by looking for the EPA registration number on the product container. On these products, there will be clear directions for use and a statement of exactly what levels of microbial control and/or protection can be expected from their use.

There are also several treatment products that have been EPA-registered for consumers or commercial applicators to use for treating articles and/or surfaces to make them more resistant to microbial growth. In the same manner, the labels of these products will contain an EPA registration number plus detailed directions for use and a statement about what types of benefits and protection can reasonably expected from their use. It is important to understand the benefits as well as the limitations of these products and carefully read and follow label directions.

Finally, a number of products have not been registered by the EPA although they are marketed with claims that lead users to believe that they will control or inhibit microbial growth. Any such claims for these products cannot be relied on and may be illegal under federal law. Some of these products are cleaners and have no antimicrobial properties and are therefore technically not illegal, although the advertising is still misleading. Users need to be knowledgeable, to ask questions, and to know their suppliers and their reputation. Enforcement of the federal and state laws is sometimes slow, and improperly represented or illegal products can find their way to the market.

Are Treatments and Treated Products Safe?
Through long experience, I have come to know that safety is relative and not absolute. Nothing is completely safe. The classic example is pure water, which is about as safe as anything can be. However, many unfortunate swimmer has learned the hard way that you cannot breathe water. Even drinking water can be hazardous to your health: Many persons who force feed themselves huge amounts of it as part of dieting or other practices have endangered their health by upsetting their electrolyte balance. As an old saying goes, all things in moderation.

With the caveat that all things have the potential to be toxic, most of the substances and formulations used for growth inhibition and preservation tend to be low on the scale of toxicity. In addition, once an antimicrobial is incorporated into an object or applied to a surface, it tends to stay in place. Thus, exposure is unlikely, and no matter how toxic something is, you have to be exposed to it in order to be harmed. Silver, for example, is rather toxic but we do not hear about any real concern about this because not many people have figured out a way to run around eating silver.

In the case of EPA-registered products, regardless of whether they are finished products or treatments to be applied in the field, there will be a lot of toxicity information on the label – plus steps needed to minimize exposure to any risks. For treatment products that are not registered, there may not be much if any information available, and you may not be able to rely on what is provided as there is no third-party review of the data developed about toxicity, if any. The best advice is, buyer, beware.

Does Antimicrobial Treatment Work?
The answer here is yes, antimicrobial treatments work, but it is essential to understand what we mean when we say this. If you cut up a chicken that is contaminated with Salmonella bacteria on a treated cutting board and do not wash the surface, many and possibly all of the bacteria that are touching the surface of the board will die or be inactivated. The problem is that if you just cut up a chicken, quite a bit of organic material – such as bits of fat, skin and meat – is likely to remain on the cutting board. Except for the parts of these particles that are actually touching the board surface, many bacteria will still be alive and have the ability to infect. If, without washing the board, you then cut up lettuce and other ingredients for a salad on the same board, it is highly likely that the salad will be contaminated and anyone eating it will become sick. People eating the chicken are unlikely to get sick because cooking will kill all of the bacteria in the chicken.

When deciding to use a product treated with an antimicrobial or using an antimicrobial treatment, it is important to have a clear picture of what result you expect and what results you are likely to get. Antimicrobial treatments can be very beneficial and they have limitations. They can provide significant levels of protection but probably never absolute protection.

An excellent example was provided by a study performed several years ago at a daycare center in New Jersey. A careful record was kept of reported illnesses such as colds and flu both on the part of the staff and the children at the center. Days of absence were also tracked. Toys in one part of the center were replaced with toys that had been treated with an antimicrobial during manufacture. In another part of the center, workers received training in cleaning techniques and were instructed to clean a toy any time one child stopped using it and before another was allowed to play with the same toy. Illnesses and absences dropped in both areas but slightly more in the area using improved cleaning practices. Then, both treated toys and training in cleaning practices were introduced throughout the facility. The reduction in both absences and recorded illness was even greater.

This study is a great summary of what can be expected through using antimicrobial treatments. Even after the entire daycare center had been equipped with treated toys and the staff was using improved cleaning techniques, some of the children and staff members got sick and there were still absences. However, both indicators were dramatically lower. Protection was not perfect. At the same time, both the parents and the staff recognized a significant value, and the center continued to utilize both treated toys and enhanced cleaning practices.

Should Everything Be Treated?
The answer here is no (as much as it might benefit my bank account if it were yes), and the reasons are twofold: economic and common sense. Although antimicrobial treatments (both during manufacture and as surface treatment products) are relatively inexpensive compared to the total cost of the item or surface being treated, there is a cost. Treated items and surfaces are more expensive than those not treated. We should think carefully before we add a new cost to everything in our lives.

On the practical side, it makes no sense to add antimicrobial treatment everywhere when it serves no real purpose. It may make perfect sense to apply an antimicrobial treatment to the walls of a waterfront home in an area of high humidity where those walls may often be at dewpoint and, thus, there is a high risk of microbial growth. Likewise, it may make perfect sense to use treated wallboard when building such a home. At the same time, using treated products, or going to the bother of treating surfaces in a home that is in a dry area where the risk of fungal amplification is little or none, is of questionable value.

In addition, it makes sense to avoid overuse of anything. Although antimicrobial treatments are generally quite low in toxicity, they still represent some risk and, thus, overuse just does not make sense. Once again, the key is clearly understanding why you are considering using a treated product, applying an antimicrobial treatment or covering a surface with an antimicrobial coating. If you understand both the benefits and limitations of antimicrobial treatments and can see a positive benefit, go ahead. If not, give it a second thought.

One time, I asked one of my customers why he uses so much of our antimicrobial product. The answer that contractor gave was, “It adds 10 percent profit to every job.” Please do not make the mistake of deciding to use an antimicrobial for that reason; do it to bring added value to your customer.

Bob Baker is chairman of BBJ Environmental Solutions, which manufactures antimicrobial products and encourages their informed and sensible use. He is also president of the Indoor Air Quality Association and chair of the ASHRAE committee writing the new HVAC maintenance standard. He serves on the boards of three organizations and writes, consults and lectures widely. He can be reached by e-mail at rbaker@bbjenviro.com or by phone at (813) 622-8550.