EPA has extended the comment period on its draft final report, Healthy Buildings, Healthy People. A downloadable version of the document is available at the EPA's website www.epa.gov and you can send your comments by fax to Pauline Johnston at (202) 565-2039 or Dan Fort at (202) 260-0816.

Four questions should be answered in your comments:

1. Do the vision and goals capture the themes that are essential for improved indoor environments?

2. Are there opportunities for improvement which remain unaddressed in the potential actions?

3. Which potential actions are most critical for EPA to undertake, which can others implement, and which can you engage in?

4. Are there scientific, technological, health, economic or administrative issues that have yet to be addressed?

What's In The Report

The report is divided into three chapters, Overview, Visions & Goals, and Potential Actions (which correspond to the goals of chapter 2). The report concludes with two appendices.

Chapter 1, titled Why Study Human Health Indoors? is a decent overview, most relevant to the novice to indoor environment issues. The statistics and information on health effects and suggestions for building design will be new to few readers of this newspaper; however, it provides a solid foundation for the following chapters to build upon. The reproductive and developmental effects of environmental tobacco smoke (ETS), radon, molds & fungi, chlorinated solvents, polycyclic aromatic hydrocarbons (PAHs), lead and pesticides are the most useful information presented in the overview section. The assertion for studying health impacts of chemical and biological pollutants for which there is little or no toxicological and exposure data is sound; however, it leaves the reader begging the question, "what are these pollutants?" as they are not listed here.

The most interesting information in this section is conspicuous by its absence. According to the "End Notes" of the first chapter, "EPA firmly maintains that the bulk of scientific evidence demonstrates that secondhand smoke - environmental tobacco smoke, or "ETS" - causes lung cancer and other significant health threats to children and adults. EPA's report was peer-reviewed by 18 eminent, independent scientists who unanimously endorsed the study's methodology and conclusions." The footnote goes on to state that, "A U.S. District Court decision has vacated several chapters of an EPA scientific risk assessment document that served as the basis for EPA's classification as a Group A carcinogen…The ruling was largely based on procedural grounds. EPA is appealing the decision." It does not say who the plaintiff in this case was. Can you say Big Tobacco?

The second chapter, Visions and Goals, outlines EPA's blueprint for attaining their stated objective, "To achieve major human health gains over the next 50 years by upgrading Indoor Environments."

This blueprint consists of five far-reaching, albeit accomplishable goals. They are:

1. Achieve major health gains and improve professional education

2. Foster a revolution in the design of new and renovated buildings

3. Stimulate nationwide action to enhance health in existing structures

4. Create and use innovative products, materials and technologies

5. Promote health-conscious individual and consumer awareness.

The first goal regarding health gains is further broken down to specific objectives such as, "significant reductions in the spread of infectious diseases…" or "major productivity gains from improvements in worker and student performance." It is in the specifics, however, where the terminology becomes less clear with the use of vague phrases like "significant reductions" and "major gains." Although these concerns are addressed in greater detail in the Potential Actions chapter, more concrete language or statistical objectives are needed in this section. The emphasis of integrating healthy indoor environments into professional curricula and training for health, science, manufacturing, and building professionals is solid.

The next two goals are the most ambitious, but [go hand in hand]. "Fostering a Revolution in building design of new and renovated buildings" and "Stimulating nationwide action to enhance health in existing structures" are clearly easier said than done. This "revolution" calls for new buildings to be planned and constructed using an, "integrated design process that looks at whole-building systems." It also calls for new buildings that are highly functional and energy efficient. EPA suggests that cost-effective building rehabilitation, renovation and remodeling strategies be developed and implemented. The agency sees compliance with these to-be-developed healthy building maintenance and operation standards as the best way to improve indoor environments. In addition to these measures, building managers and engineers, maintenance and custodial workers, trash handlers, recyclers, renovators and others responsible for clean, healthy indoor environments must be properly trained and educated on the benefits of maintaining these healthy indoor environments.

The fourth goal, to "create and use innovative products, materials, and technologies" seeks to educate the consumer, thus allowing the consumer to make informed decisions and vote with his dollars in the marketplace. EPA envisions a "green labeling" system, low-toxicity products, as well as easily attainable and affordable testing kits to help achieve this goal.

The fifth goal seeks to, "promote health conscious individual behavior and consumer awareness." The EPA's goal of communicating the importance of healthy indoor environments to the individual via easily accessed information about health effects, environmental impacts, pollution prevention strategies and environmentally friendly products supports the other objectives that EPA puts forth. Information must be made in multiple languages and available to all socio-economic levels. This effort will require developing a massive communication program to educate the individual, utilizing public service announcements via print and broadcast media as well as educational material made available in pamphlet form and on the Internet. Developing curricula for elementary school aged children to become more aware of the environments they inhabit and the measures that can be taken to ensure that they are pollution-free, could also be effective.

The "Goals" chapter is concluded with a thought provoking section titled "Principles for the Future." Some of them such as "Whole-Systems Thinking," "Protecting Our Children," and "Pollution Prevention" are a rehash of ideas already stated in the goals themselves. Others present interesting paradigms for the future. "Environmental Justice" is a concept focusing on the fact that some populations - "especially low-income and minority citizens - are exposed to a disproportional amount of environmental" pollution. It is often hard for these people to improve their housing and workplace conditions, even though they are deserving of equal protection. "Federal Integration" calls for better coordination within and among federal agencies. "Creative Partnerships" suggests the creation of private-public cooperative efforts among private enterprise and federal, state and local agencies to more swiftly create profitable solutions and foster research for indoor environmental issues.

The document now gets to the heart of the issue by turning its attention to the Potential Actions that the EPA suggests to realize its visions and goals. Although the authors do not estimate the overall cost to taxpayers, there are some fine suggestions included.

EPA recommends the development of risk assessment methodologies, further research, along with the development of public health metrics to achieve public health gains. The metrics could be used to demonstrate improvements in overall health of the public.

Facilitating competitions for recognition of achievement in integrated building design is a novel suggestion for creating awareness and interest in this form of building design and construction. The development of university and continuing education curricula, like those in place at institutions such as Purdue University or University of Tulsa can help "foster the revolution" in the way we construct and operate new buildings. Creation of incentives for builders to use integrated building designs are mentioned, but not fully elaborated.

The creation and use of innovative products and technologies will be the hardest goal for EPA to control. In light of this, the authors suggest the creation of a database prioritizing those products and materials that present the greatest threat to indoor health. The potential health risks versus possible benefits should be weighed carefully, and the results made available to the general public. This is approach will be beneficial to the public only if the data is continually reviewed and updated as new information becomes available. Providing leadership as well as market incentives to "drive manufacturers to develop new products and new technologies" is another way EPA hopes to create demand for cleaner indoor products.