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March 2008
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WORD ON THE STREET
RISK OF OVERHEATING IN AIR-EXCHANGE SYSTEMS
Venmar Ventilation, based in Drummondville, QC, “has received several
reports of major home fires where [sic] the suspected cause is a
heat-recovery system. Burlington fire officials determined that two
fires in Burlington have been attributed to Venmar units. However,
Venmar’s own investigation of these incidents and their causes is not
yet completed.
“Therefore, Venmar Ventilation is continuing its
efforts to contact the owners of affected heat-recovery
systems as these systems can fail and pose a potential
fire hazard to homeowners.” According to Venmar’s press
release, “this program covers models manufactured between
1991 and 2001, as well as between October 2006 and August
2007.
“Owners of air-exchange systems that are covered by
this Safety Upgrade Program must immediately turn their
unit off and unplug it, and contact Venmar as soon as
possible by phone at 1 866-441-4645, by visiting their Web
site at www.venmar.ca, or by mail at SUP, 550 Lemire Blvd,
Drummonville, QC, J2C 7W9.” GREEN’S NEXT
DIRECTION “Even for those remaining skeptics,”
wrote Christopher P. Hodges, P.E., CFM, LEED AP, IFMA
Fellow, “there is little argument that we can produce
buildings and design workplaces that are energy-efficient
while minimizing their impact on the environment. ... Now
that the design process is recognized as a major tool of
sustainable practices in facilities, we should turn our
attention to existing facilities.”
Hodges’s article, “Sustainable Facility Management is
the Next Wave,” points out that while green building has
become a new paradigm in construction, managers of
existing facilities have so far resisted green retrofits.
“Facility managers face a different set of problems,”
he wrote. “Shrinking operations and capital budgets make
it difficult to implement sustainable practices that cost
even minimally more than current practices [and] capital
replacement cycles are out of sync with the aggregation of
greening projects required to meet certification
standards. ... Although there is gathering evidence of the
financial benefits of sustainable practices in existing
facilities, there is still a perception of high cost to
achieve a green or high-performance facility, especially
in existing buildings. That concern is justifiable, given
the large gap that still exists between ‘doing what you
can’ and achieving LEED certification.”
Hodges found the answer to his own question, “How do we
overcome these gaps in existing buildings,” by writing,
“The answer to the problem is to take existing building
improvements one step at a time and work on the education
of the facility manager in the ways of sustainability.”
CARB’S LATEST ANTI-GAS STRIKE The
California Air Resources Board, fresh off its ban on
ozone-emitting air purifiers in the state, is taking on
nitrogen dioxide, a key component of every Californian’s
favorite airborne entity – smog. Based on “review and
final recommendations for the NO2 standard ... released in
a final staff report on Jan. 5,” the Office of
Administrative Law “approved amendments to the regulations
for the State Ambient Air Quality Standard” for the gas on
Feb. 19. The amendments “reduce the current 1-hour-average
standard of 0.25 ppm to 0.18 ppm, not to be exceeded, and
establish a new annual-average standard of 0.030 ppm, not
to be exceeded. The new standards become effective on
March 20, 2008.”
Board staff first presented their recommendations to
amend the standard “based on a review of the scientific
literature on the health effects of NO2 that was conducted
by staff from the Air Resources Board and the Office of
Environmental Health Assessment,” on Feb. 22, 2007. For
more information, visit
www.arb.ca.gov/research/aaqs/no2-rs/no2-rs.htm.
GREEN AWARDS SHOWS The major
entertainment-industry awards shows are known for pomp,
high fashion and instant controversy. Preening stars and
executives congratulate themselves for jobs well-done. In
all, the shows are entertainment at its finest. But that
hasn’t deterred organizers from adding a little green to
gala gold: In February, both the Grammy and Academy Awards
went a little green. After the Oscars were handed out,
Hollywood’s famed Kodak Theater was cleaned with Seventh
Generation’s All-Purpose Cleaner. Paper products, from
napkins to toilet tissue, also came from Seventh’s line of
post-consumer, non-chlorine-bleached recycled papers.
But the Grammy staff went even further. The event
itself was held in “the first and only LEED Gold
certified, eco-chic residential building in California,”
Elleven. Vernare provided decorations and furnishings and,
going beyond the awards show and its venue, proceeds were
donated to Brad Pitt’s Make it Right foundation, which is
“dedicated to rebuilding a green New Orleans in the Lower
9th Ward.” PAGING UPTON SINCLAIR
Last autumn, workers at Quality Pork Processors
in Austin, Minn., a major supplier for Hormel, came down
with a mysterious neurological condition that has doctors
at the famed Mayo Clinic baffled. As reported by the New
York Times Feb. 5, symptoms included “fatigue, pain,
weakness, numbness and tingling in the legs and feet.”
“A man whom doctors call ‘the index case’ – the first
patient they knew about – got sick in December, 2006 and
was hospitalized at the Mayo Clinic for about two weeks.
His job at Quality Pork was to extract the brains from
swine heads. ... Tests showed that the man’s spinal cord
was markedly inflamed. The cause seemed to be an
autoimmune reaction: His immune system was mistakenly
attacking his own nerves as if they were a foreign body.”
Despite not understanding the condition, doctors were
able to treat the man, but he kept getting sick. By
November, 2007, “other cases had begun to turn up.” Plant
doctors and its owner called in the Minnesota Department
of Health and the Centers for Disease Control. Studies of
the ill workers revealed no mad cow disease, no
trichinosis and no person-to-person spread – only
employment “at or near the ‘head table,’ where workers cut
the meat off severed hog heads,” and where the practice
known as “blowing brains” occurred.
Despite some shielding, the “blower” could be
splattered and “there was enough space for brain tissue to
splatter nearby employees.” Minnesota state epidemiologist
Dr. Ruth Lynfield said, “You could see aerosolization of
the brain tissue.”
Tests revealed no viral, bacterial or parasitical
cause, but a theory formed – that inhaled brain tissue
created an immunological reaction by which the body
created antibodies to combat the foreign materials that
just so happened to closely resemble, on a molecular
level, human nervous tissue.
Almost immediately, plant owner Kelly Wadding ordered a
stop to brain harvesting and scores of other
slaughterhouses have followed suit. Lynfield and others
are on the case for a medical cause, but, in the meantime,
it sounds as if the meatpacking industry could use a few
industrial hygienists.
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Are There Really “Outdoor” and “Indoor” Spores?
No, in fact, all fungi originate outdoors, although a few have
become especially adept at utilizing man-made materials. For the sake
of argument, however, let’s create some categories that might be
useful in interpreting spore trap data:
- Strictly outdoor fungi that never grow on man-made materials.
- Outdoor fungi that may grow on natural indoor materials.
- Outdoor fungi that have developed the capability of using a few man-made materials
- Outdoor fungi that are omnivorous with respect to natural and man-made materials.
One group of strictly outdoor fungi is those that
require living plants, fungi or animals on which to
complete their life cycles. This group includes the
“rusts,” powdery mildews, downy mildews and many other
fungi. Spores in this group, which are very common in
outdoor air, include many ascospores and hyphomycetes
(filamentous fungi producing asexual spores not in
fruiting bodies). Cercospora is an example of a common
fungus that releases an abundance of airborne conidia into
the outdoor air.
A second group of strictly outdoor fungi is those that
require complex ecosystems for the completion of their
life cycles. Notable here are the mushrooms, most of which
live in close association with higher plants and do not
reproduce without this association. Many of the very large
number of basidiospores that often fill the outdoor air
fall into this category.
Of course, there are some mushrooms that can grow and
release spores indoors. These are the Group 2 fungi. The
brown-rot fungus Serpula lacrimans is a good example. This
fungus lives on wood, which is really a natural material
that is brought into our interiors. Fungi common on jute
and straw may also become abundant indoors because these
materials are their natural outdoor food. These include
Torula, Stachybotrys, Epicoccum and many others. Group 3
fungi are those that can readily utilize some types of
man-made materials. The most familiar of these are the
cellulose-decaying fungi. Stachybotrys, Chaetomium,
and Trichoderma, for example, readily colonize highly
processed cellulosic paper materials. Also included in
Group 3 are fungi that have become adapted to specific
man-made conditions. Some Cladosporium species grow well
on face cream, polyethylene and crude oil. Species in the
genus Aspergillus have similarly learned to colonize
man-made environments like oil-storage tanks in the North
Sea. In some cases, these fungi have developed a taste for
the unusual material and fail to grow well in simple
culture media.
Group 4 includes the omnivorous fungi. These fungi are
adaptive with respect to food sources and can use a very
wide variety of different materials in different forms.
The ubiquitous Penicillia and some species of Aspergillus
and Cladosporium (among many other fungi) belong to this
group. Remember that these fungi are just as happy
outdoors as in, so are not truly “indoor” fungi.The
following table outlines some of these relationships. Note
that some names are listed in several groups. This is
because nutritional requirements do not necessarily follow
generic lines and a single genus can have different
species with wide-ranging nutritional requirements.
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Group 1 |
Group 2 |
Group 3 |
Group 4 |
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Puccinia Ustilago |
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| Ascomycetes |
Leptosphaeria |
Leptosphaeria |
Chaetomium |
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Didymella |
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Pyronema |
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| Basidiomycetes |
Rusts and smuts |
Serpula |
Sporobolomyces |
Rhodotorula |
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Boletus |
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| Hyphomycetes |
Cercospora |
Torula |
Scopulariopsis |
Penicillium |
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Polythrincium |
Stachybotrys |
Stachybotrys |
Aspergillus |
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Alternaria |
Alternaria |
Alternaria |
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Cladosporium |
Cladosporium |
Cladosporium |
Cladosporium |
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Road Warrior Part 2 -IEQ Needs an Update
After attending my fourth medical conference in the past six
months, I have concluded that the term “indoor environmental
quality” is slightly misguided and out of date. But not for lack of
specifics or lack of cooperation with doctors as previously reported
in Part 1. My epiphany began during the first panel discussion at
the Integrated HealthCare Symposium in New York City and has
strengthened with time.
These practitioners of integrative medicine were
enthusiastic and confident that conventional medicine
could be expanded, improved and made more cost effective
with subtle but powerful changes. Their conceptual
framework can best be identified by the term “functional
medicine.” Conventional medicine collects information
about a patient to create a diagnosis, which leads to a
treatment plan. For example, the patient complains about
headaches. The doctor asks questions and may conduct some
tests. A cause is diagnosed and treatment is prescribed.
Perhaps aspirin is used, or an aspirin substitute. Maybe
the symptoms and test results indicate a tumor or an
infection. Regardless of the specifics, treatment is
started and adjusted until the symptoms stop. Case closed.
This is time-tested and proven millions of times every
day in doctors’ offices across the country. So why tamper
with what works?
Integrative medical practitioners don’t dispute the
success of conventional procedures. But they quickly point
to all the issues, conditions and syndromes in which
conventional medicine has not been successful. They don’t
use this evidence as arguments against conventional
medicine, but rather to indicate that one size may not fit
all. What about trying alternative methods to see if
better results can be obtained in some instances?
But they don’t stop with alternatives. These pioneers
insist the old can be integrated with the new, the mature
science with the developing research. They emphasize the
integration of philosophies, research, concepts and
practices. They want to expand from the strict limits of
evidence-based medicine to include more of a systems
approach.
This is where their message strongly connected with me.
Building science, for example, recognizes built structures
as a dynamic meta-system composed of interacting smaller
systems. A change in one parameter can affect the whole
structure and the people occupying it. In other words,
buildings are not static objects like piles of rocks.
The integrated-systems approach to medicine and health
views the human body as a complex biological system
composed of interacting smaller systems. A change in one
parameter can affect the whole structure, including the
health of the person occupying the body. In other words,
human bodies are not static objects like rocks. Neither
are they to be confused with “the public” as a pile of
rocks.
Here is where the integrative-medicine approach becomes
really fascinating because it leads directly to how subtle
changes to IEQ could result in a quantum leap instead of
an evolutionary stage: The experts at the Integrative
HealthCare Symposium didn’t stop with their systems
approach (after all, traditional analysis based on
cause-and-effect symptoms will work just as well with a
systems approach) – they came full circle and took us to
the next level. Instead of focusing on the results of the
systems, they looked at why the system produced those
results. In other words, they are more interested in
supporting and optimizing the functioning of the systems
to produce health rather than illness and disease. Thus
the term “functional medicine.”
This is not that different from the approach of
building scientists, as indicated above. Although they
care greatly about end results such as temperature,
humidity and ventilation rates, they don’t focus
fundamentally on them. Instead, they build and modify the
complex systems to produce a healthy building rather than
a sick building. They are concerned with functional
buildings in the same way the integrative health
professionals are concerned with functional bodies.
So let’s take a closer look at IEQ.
Current IEQ activity evolved from the roots of
industrial hygiene. Emphasis is on determining exposure by
measuring “stuff.” The results are then compared two ways:
Inside-exposure data is compared with outside non-exposure
data; and inside-exposure data is compared to laws,
regulations and permissible exposure levels. IEQ is
primarily driven by compliance with regulatory evidence,
much like evidence-based medicine is driven by compliance
with peer-reviewed evidence. This has worked well over the
years and continues to work thousands of times every day
across the country. So why tamper with success?
Tampering is needed because traditional industrial
hygiene methods haven’t directly translated well to
non-industrial environments. This simple fact is stated
unequivocally by Robert F. Herrick in the foreword to “Bioaerosols:”
“In retrospect, it is clear that we were wrong ...” His
suggested remedy, however, is similar to the first stages
of the alternative doctors: Keep the same procedures, but
modify how they are used. But both practitioners of
medicine and practitioners of indoor environmental quality
continue to fail in critical areas. Not by a failure of
science, but by a failure of the focus of the science.
Shift the focus from forcefully correcting what the
system produces (symptoms and measurements) to identifying
what the system naturally produces. Once the expectations
and the realities are aligned, productive results can be
attained. Why struggle to force a hut on stilts to
maintain a constant temperature in the arctic when an
igloo does so naturally? Let the hut on stilts function
naturally just as the earth-couple cave functions
naturally. Anything else is unnaturally forced, even if
the regulations and medical evidence dictate otherwise.
If we are to change our focus about the functioning of
the meta-system we call the indoor environment and the
meta-system we call the human body, what is the parameter
that will integrate the two?
The integrating unit is what is naturally common to
both building systems and the body systems: An individual
person, not the public, but each individual.
The logic may be better understood by considering the
disconnects between people, medicine and buildings. We may
know something is happening in the built environment,
despite our inability to measure it. Medicine can’t
explain or validate it because of the lack of a mature
body of peer-reviewed evidence. Simply expanding the
knowledge base of each to create an overlap has not and
will not succeed, despite the best efforts of our most
brilliant minds. And none of the above lacks of proof
changes the irrefutable fact that the interactions of the
various systems resulted in something happening to the
individual.
My proposal is to shift our focus from the results of
medicine and the results of the indoor environment to the
function of each system. For health, it becomes the
susceptibility profile of the individual rather than a
catalog of symptoms. For indoor environments, it becomes
the exposure profile of the building rather than an
inventory of measurements. The unifying principle is what
happens to the occupant. Is the building functioning in a
manner supportive of its purpose? That determination
cannot be made without an evaluation of the occupants. Are
the people functioning in a manner supportive of their
purpose? That determination cannot be made without an
evaluation of the building.
Look for the crossover points of the ranges of
parameters by integrating both sets of scientifically
derived data points. But keep in mind the data does not
determine the results. The functioning of the integrated
systems, as demonstrated by the experience of the
occupants, is what tells the tale.
The descriptive phrase “indoor environmental quality”
is slightly misguided and out of date. But the reason is
not because it is only a description and not a designation
or certification. Rather, it needs an update because of a
fundamental failing, as revealed by its historical roots
and disconnection from the people who depend on it.
Analytical measurements are part of the puzzle.
Analysis by the scientific method is another. Examining
the experiences of the occupants is critical. But none of
these in any combination supplies the answer. Instead, the
answers will be revealed as we learn the functioning of
the systems in an appropriate integration. Thus, IEQ
should be changed from indoor environmental quality to
integrated environmental quality.
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Award Recipient Shares Secrets of Working With Builders
It is always refreshing to see a member of the radon community’s
private sector recognized for his success and that is exactly what
happened this past January. Dan West, president of Radon Systems of
Westerville, Ohio, was awarded the American Association of Radon
Scientists and Technologists award for Excellence in Leadership
during a ceremony on Jan. 10, 2008 at Environmental Protection
Agency headquarters in Washington, D.C.
For those who know Dan, it is a well-deserved award. He
has not only provided an example of how to succeed in the
radon business, he has also been very willing to share his
experience through his efforts in training novices
entering the field and taking on individual mentoring
roles through our mitigation program at the training
center.
Although Dan has experiences in many aspects of the
radon field, this particular award was bestowed on him as
a result of the successes he has had in getting builders
on board to install radon-control systems during new home
construction (RRNC). True to his reputation, Dan was
willing to share some of his perspectives on how he has
been successful in penetrating the new-home RRNC market in
central Ohio.
Kladder: Dan, from your perspective,
does it make sense to consider installing radon control
systems in new home construction?
West: With our vast knowledge of why
radon-mitigation systems in existing homes do or do not
work, it only makes sense to build new houses with that
proven technology and based on those methods. It does make
them easy to fix!
Every new home in central Ohio should be built
radon-resistant. I know it, the builders know it, and we
are working hard to help create the consumer demand and
pressure all municipalities in central Ohio to adopt or
enforce Appendix F of the 1996 CABO Code, ASTM Standard
Guide for Design and Construction of Low Rise Residential
Buildings, E 1465 or the International Residential Code
2000.
Kladder: Are there special needs for
radon-mitigation contractors considering installing
systems as a subcontractor to builders?
West: New construction is a different
breed of cat! The builder will require liability insurance
with specific wording naming the builder as an additional
insured on the contractor’s policy. The builder will also
require worker’s compensation insurance and a copy of the
certificate. The contractor will also need a safety plan
on file with the builder and HAZCOM program up to date
with current MSDS sheets. After these items have been
submitted and approved, the contractor can work for
anyone.
Depending on the builders you are working with, we have
had as many as 38 houses called in at one time, ready to
install RRNC. Fortunately, you typically have some time
before other trades are scheduled. Do not think for a
moment that RRNC is cheaper during construction than after
the house has been constructed. Anticipate issues with
electric: You may need a generator because not all sites
have power available close by. Plan on at least two, and
probably more, trips to the site. Now, having said all
that, in my opinion, there is no reason why all
professional mitigators should not be installing RRNC for
the builders in their area. We are the experts, we have
the training and we are ready to provide the service.
Kladder: Can you expand on why
installing systems is more expensive when installed during
construction rather than after it is built?
West: RRNC services should always be
more expensive. Several trips are necessary, scheduling is
more stringent, more liability insurance is required, the
contractor will need a generator or power converter in
addition to a safety plan and HAZCOM program in place. The
reality is based on our experience. The cost to install
RRNC should not be comparable to an existing home, which
typically is mitigated in less than four hours. It is a
common misconception that RRNC is cheaper to install. If
the decision is made to wait for a test, it will be too
late.
Kladder: How have you been able to
develop a large market share of the RRNC work in the
central Ohio area?
West: By being the first to install
RRNC systems. If working in a subdivision, builders talk
and notice who is working there. If you have a home
builders association, join it. In the past, we have
sponsored breakfast meetings and then presented RRNC
design and installation techniques while emphasizing
strongly that a trained radon specialist is the most
qualified and the person trained to install the system
properly.
Try to partner with a builder knowledgeable with
regards to radon reduction and work with that builder to
install RRNC features in all new homes sales.
I have also had success meeting with sales associates
for the builder so they have a good understanding of the
benefits of this feature and promote the system to their
buyers. It is our job to educate the builder, just like
the realtor. The more buyers demand radon systems in their
new houses, the more the builder will have to address the
radon issue.
Kladder: What are some key approaches
for working with builders?
West: The smoother we can make the
system installation for the builder, the more receptive he
will be in the future. Always provide the builder some
marketing tools personalized for that builder. In the
past, I have presented RRNC for home builders in Franklin
County, Wood County, Miami Valley and Mahoning County. Be
available and take advantage for these opportunities every
time that opportunity is presented.
Marketing our services to the builder is similar to the
realtor. Service, service and more service is the key.
Join your local home builders association. By joining the
BIA, you will have access to all the builder members in
your area. That is a good place to start. Education is the
key to creating a demand for RRNC. Once the demand is
created, the service then becomes the key ingredient. If
we cannot provide a timely service to the builder, the
builder will go elsewhere. In the past, we sent all the
builders in the central Ohio BIA a copy of the EPA CD
“Breathing Easy” and a cover letter referencing the CD.
This is a great tool narrated by a realtor. Follow it up
with a phone call or another letter. Do not get
discouraged – it takes time to create a demand for
services and expertise.
Kladder: You mentioned education as a
key element, but RRNC is not all that difficult. Have
there been problems associated with systems that have not
been installed by trained contractors?
West: Problems we regularly see are
vent pipes jammed into the soil without a tee fitting,
vent pipes located on footer, floor wall floor joints
sealed with wrong caulk or not at all, membrane in crawl
not sealed well enough around vent pipe, no pipe slope for
condensation, vent pipe too close to house eaves with no
room to add the fan, schedule 40 pipe in a 3.5-inch wall
cavity is noisy and vibrates with the addition of the
radon fan, system not labeled properly or at all,
expansion joints not sealed, the sump crock cover is left
with a 3-inch uncapped hole open to the basement and the
general integrity of all the fittings and pipe joints have
not been sealed and leak. Well, with a laundry
list of potential problems with systems installed by
untrained contractors, it is good we have folks like Dan
out there working with the trades to show them how it can
be done correctly. Again, congratulations to Dan West for
his well-deserved award and sharing his thoughts with our
readers.
As always who says there is nothing new in radon?
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AIHA Voices Official Opposition to NYC Monitoring Regulation
by Jonathan Miller
Controversial legislation in New York City, designed to regulate
the use of private biological, chemical and radiological detectors,
which was tabled due to opposition from public and private groups,
has a new foe – the American Industrial Hygiene Association.
As reported in the Feb., 2008 issue of this newspaper
[“NYC Proposes Law to Regulate Monitoring Equipment”],
“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 [New York Police Department].” The NYPD
claimed it pushed for regulation at the advisement of an
official with the U.S. Department of Homeland Security,
who expressed worry over “the growing, widespread use of
private environmental sensors since the terrorist attacks
on Sept. 11, 2001.”
Richard Falkenrath, NYPD’s deputy commissioner for
counterterrorism, noted the “locations and reliability of
the sensors [are] little known,” and that “endemic use of
such devices could lead to false alarms that could trigger
‘massive emergency response with all sorts of problems.’”
The bill’s stated intent “is to ensure ‘that they are
appropriate and reliable’” and would not require license
for routine detectors, “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.”
“We’re interested mainly in sensors which [sic] will
alert someone to a possible chemical, biological,
radiological or nuclear weapons attack,” Falkenrath said
at the time. Opposition was staunch in that case, from
city-council members and other city-government officials
who complained of vagueness, loss of independent
environmental-data collection, and “a problem that does
not exist.” Testifying in opposition at the time was John
Glass, past president of AIHA’s New Jersey chapter and
current chair of the association’s environmental issues
special interest group. Glass echoed the vagueness
charges, noting 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 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.” Further, he
questioned how data reported to NYPD would “be evaluated,
responded [to] and recorded” and cited “ethical and
liability concerns for practitioners.”
Based in part on Glass’s testimony, committee head and
Queens council member Peter Vallone on Jan. 8 postponed a
vote until “the council [narrows] the scope of the
administration’s bill.” But, as AIHA president Donald
J. Hart, PhD, CIH noted in a recent letter to New York
City mayor Michael Bloomberg, “there is strong support
from you and others to reconsider this bill at a future
hearing. Because of this, we feel it is of the utmost
urgency that we contact you directly to again express our
opposition to this bill.
“AIHA understands the desire of the City of New York to
reduce the number of premature reactions to direct reading
instruments by untrained individuals. We share this
concern. However, there are numerous problems with
enacting legislation of this magnitude without enlisting
the input and expertise of those who are currently
qualified and have the experience of using these
monitoring devices for years.”
Hart’s letter, provided to IE Connections by Aaron
Trippler, AIHA’s director of government affairs, lists
examples of the association’s concerns that closely
resemble Glass’s original testimony: “The definition of
biological agent includes all biological entities.
Existing science does not provide us with numbers that can
be used to determine good or bad exposure;
“The definition of detectors is also designed so
liberally that each homeowner in the City will need to
file for a permit for smoke detectors. Under the law, it
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;
“The permit application requires emergency response
plans for use with the detectors. There is no way to
determine what emergency plan could possibly be needed for
situations that have not yet arisen;
“All exceeded limits must be reported to the NYPD. How
would this data be evaluated, responded to and recorded?
Perhaps more importantly, what will occur when the
reviewer comes to a different conclusion than the site
professional? Will the judgment of a seasoned exposure
assessment scientist be disregarded in deference to the
judgment of some administrator?”
The letter continues, “As you can see, we feel this
legislation creates more concerns than the problem it
addresses. Frankly, we are not convinced that there is a
problem. Perhaps rather than enacting a new law to
alleviate potential fear, it may be more advisable to
require all entities offering professional consulting in
this arena to have properly credentialed consultants
overseeing the evaluations. ... This will insure [sic]
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.”
After reminding Bloomberg of AIHA’s expertise and its
past assistance to the city, particularly for air-quality
monitoring following the Sept. 11 terrorist attacks, Hart
wrote, “In closing, AIHA is not opposed to the City of New
York enacting legislation that would better protect its
citizens. On the contrary, this is the type of legislation
we support. However, we ask that perhaps you step back for
a moment to consider all of the potential problems created
by enacting such a law with limited input from the
professionals who provide these services on a daily basis.
“AIHA asks that you withhold future action on this
legislation, invite affected stakeholders ... and others
to begin a dialogue that will produce a law that protects
the health and safety of citizens through the combined
resources of experts in all fields. AIHA offers its
assistance in this endeavor in any way possible.”
Trippler wrote in an e-mail to IE Connections, “We
believe this law is not needed – they are trying to create
a solution to a problem that has not occurred. If they
proceed down this path, they must at least ensure that
qualified professionals are not included in the law.” But,
Trippler, noted, “the draft regulations do address this
concern as it pertains to [certified industrial
hygienists].”
So far, he continued, “AIHA has not received any
specific response from the NYPD or the mayor’s office. We
did receive a letter from a couple council members. One
specifically came out and supported our position.”
Asked if the letter and Glass’s prior testimony would
have any impact, Trippler responded optimistically. “I
believe our early opposition, as well as the abundance of
opposition from others in the last month or so, convinced
the sponsor that there were numerous problems with the
proposal.
“While I have not been contacted by the mayor’s office,
the NYPD or the sponsor on whether they will ask AIHA to
assist in any further drafts, I believe they understand
our concerns and will address some, if not all, of these
concerns. [There are] no specific changes as key to the
proposal other than what we stated in our letter.”
“I’m not sure what the next step in the process it,”
Trippler wrote. “As I understand it, the revised proposal
has not yet been proposed before the council.”
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VOC Exposure From Unexpected Sources
By Jonathan Miller
Achieving and maintaining good indoor environmental quality is a
goal increasingly held by property owners and managers. HVAC systems
are installed, filters are changed, ducts are cleaned, vapor barriers
and insulation installed. Volatile organic compounds are kept at a
minimum. Air cleaners are introduced to sweep out microbes, dust,
particles and spores, and diligent cleaning prevents the growth of
molds and bacteria that can affect health. Detectors and specialized
systems are put in place to eliminate gaseous risks like carbon
monoxide and radon.
Ironically, for all that, a building’s problems may just be
beginning.
Despite any person’s best efforts to rid a building of IEQ
troubles, unexpected culprits may yet exist. Previously unknown, or
unconsidered, IAQ issues are discovered with regularity, including a
recent emphasis on volatile organic compounds. But while reducing
chemical components and fragrances is a first step, VOCs have myriad
sources, not all of which are widely known. Atmospheric ozone and
cleaning products are among the key VOC contributors missed by many.
Outdoor Ozone Since the development of
consumer concern for the emission of ozone by air-purifying devices
and their banishment from the California marketplace by the state Air
Resources Board [See IE Connections, Nov., 2007], ozone originating
indoors has decreased as a risk factor and may in the near future be
all but eradicated. But while the elimination of the gas’s indoor
causes removes one key detriment to good IAQ, another cause of indoor
ozone, and the VOCs it helps create, has been largely ignored.
According to a report by a team of researchers at the U.S.
Department of Energy’s Lawrence Berkeley National Laboratory, “Outdoor
Ozone and Building-Related Symptoms in the BASE Study,” increased
outdoor concentrations of ozone correlate to sick building syndrome,
the set of mysterious symptoms – including fatigue, headache and
irritation of the eyes and respiratory tract – that improve after a
person leaves the affected building.
The Berkeley Lab team of Michael Apte, Ian Buchanan, Mark Mendell
and Anna Mirer analyzed data from the U.S. Environmental Protection
Agency’s Building Assessment Survey and Evaluation, in which 100 U.S.
office buildings were studied for one week in either the summer or
winter between 1994 and 1998, according to Physorg.com. The BASE study
surveyed workers’ self-reported health conditions, weather and
workplace data. The Berkeley Lab team compared the BASE data to
contemporaneous ozone data from air quality-monitoring stations near
the surveyed buildings. Analysis showed linear increases of upper
respiratory symptoms with comparative increases in outdoor ozone
concentrations. Ozone also correlated with indoor concentrations of
aldehydes, including carcinogenic formaldehyde, and organic acids
known to be sensory irritants.
Apte told Physorg.com, “Based on patterns of associations between
building-related symptoms and certain volatile organic compounds
indoors, we hypothesized that increasing levels of outdoor ozone would
lead to higher prevalence of building-related symptoms among the
occupants within a building.”
But, as the team demonstrated, filtration may inadvertently lead to
even higher VOC concentrations if outdoor ozone concentrations are
high. A separate report by the Berkeley Lab team, “Air Filter
Materials, Outdoor Ozone and Building-Related Syndrome in the BASE
Study,” showed that polyester and other synthetic-material air filters
correlate strongly to health symptoms consistent with sick building
syndrome if outdoor ozone concentrations are high. Conversely,
buildings with fiberglass or natural-material filters reported fewer
symptoms in high-ozone environments, as did synthetic filters in
low-ozone environments.
“The study estimated that removing both risk factors – higher ozone
in outdoor air and polyester/synthetic filters – could reduce
[building-related symptoms] by 26 to 62 percent,” Apte said. He
cautioned, though, that further verification is needed in both
studies. “This research is a first step and it needs to be replicated
in other studies with a statistical design specifically to address the
ozone-symptom association and with accurate information on filters and
ozone levels.”
Both papers will be published in the journal Indoor Air.
Cleaning Products The chemicals inherent in most
cleaners, besides offering the potential for accidental poisoning, are
not known for their pleasant aromas; if they were, added scents would
not be necessary. And while scents themselves are among the more
widely known sources for airborne VOCs, a new report from Air Quality
Sciences demonstrates that the cleaners themselves may be the real
causes of the problem.
The AQS report, “Cleaning Chemicals and Their Impact on Indoor
Environments and Health,” introduces cleaning and cleaning-product
manufacture as “faced with the challenge of balancing two important
goals: Creating effective cleaning products for a wide variety of
applications ... while not adding pollutants, such as volatile organic
compounds and particulates, back into the indoor air.”
To achieve these goals, the report states, manufacturers “are
trying to better understand how their products impact indoor air
quality and health;” “are also under pressure to provide green
products that meet today’s market demands for effective, yet safe
maintenance;” and “Consequently ... are striving to differentiate
their products by earning third-party impartial verification of their
environmental performance.”
Analysis of cleaning and cleaning products reveals that “adults in
the [United States] spend an average of 20 to 30 minutes per day
cleaning their homes ... [and] three million people ... are employed a
janitors, cleaners, maids and housekeeping staff.” Whereas “a number
of studies ... have confirmed that dust control and deep cleaning are
effective methods for reducing the level of viruses, bacteria,
particulates, endotoxins, molds and allergens in indoor environments
... a growing body of studies have demonstrated that the very products
and processes that are used to keep indoor environments clean also may
contribute to indoor pollution. ... In many cases, VOC emissions from
cleaning products and application processes, which building occupants
can easily inhale, are the primary cause of concern.”
Tests by AQS revealed acids, aldehydes, alcohols, esters and
chloroethylenes in a wide variety of surface cleaners, deodorizers,
disinfectants, spot removers and polishes. “Within two hours of
certain cleaning processes, the total VOC levels in these environments
can increase significantly, ranging from 40 μg/m³ to 25,000 μg/m³, and
reach levels higher than the acceptable value (500 μg/m³) for VOC
emissions from cleaning products [as established by the GREENGUARD
Environmental Institute].
Beyond the range of health issues related to VOCs, AQS pointed to
health-related loss of productivity and, particularly, the effects of
VOC exposure on children in schools, who face loss of productivity
among themselves and teachers, health risks [AQS notes that children
face greater risks than adults “because they breathe in more air with
respect to their body mass”] like asthma and, as a result, fall short
of learning goals.
The positive consequence of VOCs’ effects on children, the report
states, is “federal, state and local governments [requiring] the
creation of green-cleaning programs and the use of green or
environmentally preferred cleaning products.”
“Although there is no set legal or regulatory definition as to what
is ‘green’ or ‘green cleaning,’ the concept itself is
straightforward,” AQS says in introducing holistic and naturally based
cleaning products by manufacturers. However, the report notes,
“natural or green does not necessarily mean effective or safe,” and,
to sate an increasingly savvy and informed consumer population, the
push for independent certification of green products has created and
strengthened standards-making bodies like Green Seal, the
Environmental Choice Program and the GREENGUARD Environmental
Institute. Standards developed by these and other bodies mandate that
a product meet significantly low thresholds of maximum content for
various chemicals and toxins.
But, the report warns, “it is important to realize that many
‘low-VOC’ products, even those certified as green or environmentally
friendly, are rated by their VOC content, not by their VOC emissions.
... This is especially critical with cleaning products as potential
exposures are directly related to how a product is used.” With the
cleaning industry “responsible for minimizing exposures to VOCs
emitted from its
products,” AQS states that “to meet market demand and reduce
product liability risks, product manufacturers will increasingly need
to demonstrate their products’ safety by testing and monitoring VOC
emissions.”
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