• Word on the Street
• Ask Dr. Burge - What is the latest on the use of bleach to remove mold?
• Asbestos: Are Disaster Restoration Workers at Risk?
• Can EPA Take the Radon Program from Good to Great?
• High-Volume Air Exchange for More Efficient Remediation: A Case Study
• Is LEED Misleading? A Hard Look at “Green Buildings”

NEW ASTHMA RESEARCH
Asthma is more prevalent among boys than among girls, but girls are more likely to still have asthma after they grow to adulthood, according to a  study published in the American Journal of Respiratory and Critical Care Medicine, published by the American Thoracic Society.
“We wanted to investigate what was behind the observed sex differences in asthma rates,” said lead researcher, Kelan G. Tantisira, of Brigham and Women’s Hospital and Harvard Medical School. “This is the first study to prospectively examine the natural history of sex differences in asthma in this manner.”

Tantisira speculated that there may be a buried mechanism in asthma development, according to the research that analyzed airway responsiveness (AR) in more than 1,000 children with mild to moderate asthma over a period of about nine years.
The researchers found that when it came to the amount of methacholine it took to provoke airway constriction, the girls’ reactivity did not change markedly over the years. In contrast, boys became increasingly tolerant over time to larger and larger doses of methacholine, suggesting a possible decrease in disease severity. By the age of 16, it took more than twice as much methacholine to provoke a 20 percent constriction in the boys’ airway on average as it did with the girls.

“While our results were not unexpected, they do point to intriguing potential mechanisms, to explain the gender differences in asthma incidence and severity. Especially intriguing is that the differences in gender begin at the time of transition into early puberty.” said Dr. Tantisira.
 
HOME TESTING KITS
The September issue of the widely read Consumer Reports magazine will include the results of its tests of 18 lead and radon test kits. The magazine’s conclusion: the kits are a good first step for homeowners, but testers also found confusing instructions, challenging procedures and inaccurate results.

Four lead test kits for detecting lead in house paint - Abotex Lead Inspector Lead Test Kit, $13; First Alert Premium Lead Test Kit LT1, $20; Homax LeadCheck 5250 Test Kit, $8; and SKC LeadCheck Instant 225-2404 Sampling Test Kit, $24 - were rated Easy to Use. Industrial Test Systems SenSafe Lead Paint Test 480310, $15, had confusing instructions and was rated Difficult to Use.

Among radon test kits, CR tested seven short-term kits, three long-term kits and a digital-readout meter that can be used for either short or long-term measurements using experts at two outside labs. Among long-term kits (typically exposed for 90 days or more before lab analysis) Accustar Alpha Track Test Kit AT 100, $28, topped CR's ratings and is a CR Best Buy. All three long-term kits, however, were very good.

While some were fine options, three short-term kits were especially inaccurate, unreliable, or both.

The Accustar Short Term LS Radon Test Kit CLS 100i, $25, and the Kidde Radon Detection Kit 442020, $16, underreported radon levels by almost 40 percent. The Accustar Short Term Canister Radon Test Kit AC-1001, $30, was only "Fair" in accuracy and in reproducing the same result under the same conditions.

"Lead test kits are a reasonable first step for homes built before 1978 if no one in the house has elevated blood levels," said Celia Kuperszmid Lehrman, deputy home editor, Consumer Reports. "Every homeowner should test their home for radon and we recommend that people use long-term test kits because radon levels can change from day-to-day and month-to month."
Lead paint can gradually deteriorate into flakes, chips, and fine dust that's easily inhaled or eaten by small children, even when it's covered by many layers of unleaded paint.

The kits CR tested detected lead levels as low as 2,000 ppm in the home-based tests. In CR's lab tests, some kits detected lead at levels below 1,000 ppm. None of them falsely identified paint in a Consumer Reports lab painted in 1990 as having lead. CR's experts found that all kits required practice: exposing the layers of old paint took strength, dexterity, and lots of practice. Home test kits use one of two chemicals to detect lead by color change, but correctly reading color changes when lead levels were low also took practice.

CR also found that long-term radon kits are more accurate, given that radon levels can vary significantly from day to day.
 
ASBESTOS VERDICT
The law firm Weitz & Luxenberg P.C. won a $16.25 million verdict in an asbestos lawsuit on behalf of Marvin Penn, 71, diagnosed with the asbestos-related cancer mesothelioma, and his wife Josephine Penn. The jury attributed 20 percent of the liability to the sole defendant at trial, Kerr Corp., a dental supply company. The case, which clears a new path to justice in asbestos litigation, is believed to be the first successful asbestos verdict against that type of defendant.

Douglas D. von Oiste, Weitz & Luxenberg trial team attorney and lead counsel said, "The jury believed Mr. Penn and did not believe Kerr's defense that the product it distributed did not release harmful asbestos dust, and that Kerr could not have known at the time that it was dangerous."
Marvin Penn was a mail carrier from 1963 to 1999, though, in considering a career change, attended dental technician school in the late 1960s. It was there that he was exposed to asbestos while making castings by carving wax replicas of teeth using asbestos-containing dental tape.

The complex case (Index no. 105637/07, New York Supreme Court, Manhattan) involved a three-week trial featuring state-of the-art medical experts, which culminated in the verdict against Kerr. The jury attributed 20 percent of liability to another dental supply manufacturer, Dentsply Corp., which settled before the verdict.

The trial also addressed Penn's other exposures to asbestos. He testified that he worked in a post office across from the former location of the World Trade Center while it was being sprayed with asbestos. The spray was found to be 40 percent liable.

Additionally, Todd Shipyards was found 20 percent liable given that Penn's father worked there as a steamfitter. Family members of workers exposed to asbestos are at risk due to the asbestos dust brought into the home on the shoes, clothing, skin, and hair of workers.

The Situation: You, as a homeowner, need to replace your sheet flooring and drywall due to flooding.  You call a restoration contractor to give you a bid on fixing the flood damage.  The estimator arrives at your home and, given the age of the home, suggests having the flooring tested for asbestos – just in case.  So the estimator collects some samples and takes them to an asbestos laboratory for analysis.

 The laboratory reports that the sheet flooring contains 25% asbestos (present in the paper backing on the flooring).  The estimator tells you that there is asbestos in the floor and that the cost of the project will double because of the asbestos.  You agree to the price and tell the contractor to get started. 

The following afternoon, you arrive home and walk into your house.  The workers are really getting after it  - ripping the flooring loose from the substrate and piling the pieces on the patio.  Others are sledge hammering the damaged drywall and throwing it on the pile.

You, having been concerned about the asbestos in your floor had researched asbestos flooring removal on the internet the night before and notice that the workers are not following the procedures you read on the internet:  wetting the flooring, wearing respirators, etc.  They are also getting a drum sander set up to remove the residual asbestos paper that is still stuck to the substrate by the adhesive.

You ask the workers, “What the heck is going on?”  They look at you dumbfounded and ask you what your problem is.  You say:  “My problem!  My problem!  There’s asbestos in that floor.”  The workers explain they didn’t know about the asbestos.  Their boss didn’t tell them about the asbestos (you know, the one who took the samples to the lab and let you know there was asbestos in the floor to start with and doubled your cost). 

You call up the contractor and ask why the workers weren’t following asbestos removal procedures.  He tells you that he called the local asbestos regulatory agency and explained the situation.  The regulator just said they do not handle any residential work.

You personally call the local asbestos control agency looking for guidance and they tell you – “well you’re a homeowner – we don’t regulate residential work.”  You ask the regulator about the safety of the workers removing the asbestos as well as the possible safety risk to you and your family.  “Sorry, we don’t regulate residential work.”  How do I clean this up?  Again, “Sorry, we don’t regulate residential work.  Maybe tell the workers to put some water on the stuff and wipe everything off.”

You take migraine medicine and head to the local watering hole and hope that maybe the combination of the medicine and strong drink will end your misery.

The preceding scenario was made up but is based on actual events I’ve discussed over the years with contractors, homeowners and regulators.  Does anyone other than me see a problem here?  The regulators won’t enforce the asbestos safety regulations because the work is being done in someone’s home?  Yeah, I know:  The laws do not apply to homeowners who remove asbestos-containing materials themselves in their own home.  But, when a homeowner contracts a company to work on their home, isn’t that company (the employer) responsible for the safety of its workers (the employees)? This is one of the basic premises of the Occupational Safety and Health Act: 

OSHA’s general duty clause (Section 5(a)(1)) “requires employers to "furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees."” (Emphasis added)

Asbestos is a recognized hazard.  Asbestos is known to cause death or serious physical harm to those exposed.  If regulators are ignoring this most basic premise in the Occupational Safety and Health Act, just how safe are workers in this country?

The Reality

Here are some statistics for you to ponder.  In the United States in 2006:

·         Construction laborers held about 1.2 million jobs.

·         Carpet, floor, and tile installers and finishers held about 196,000.

·         Drywall installers, ceiling tile installers, and tapers held about 240,000 jobs.

·         Painters and paperhangers held about 473,000 jobs. (Bureau of Labor Statistics, US Department of Labor website)

With fires burning California to a crisp, hurricanes trucking across Florida every year, devastating flooding along the Mississippi River and tornado outbreaks in the Midwest annually, how many single family homes are affected by these events each year?  While some of the damaged properties will be complete losses, others will require restoration.  What about the indoor environmental quality of the properties undergoing restoration?  Thousands of workers will be working in single-family residences - especially after large-scale natural disasters. 

These same workers, if working at a commercial property, school, or health care facility, would be protected by OSHA.  From discussions with environmental consultants working on site during clean up efforts, it seems that the asbestos rules are being followed but not in single-family properties.  Shouldn’t the regulators consider what kind of work the restoration personnel are doing rather than where they are doing it? 

The regulatory agencies are at least making attempts to do the right thing.  The Environmental Protection Agency (EPA) is considering the potential contamination of the environment during natural disaster cleanup efforts.  The EPA is monitoring for asbestos in cities hit by tornados and flooding. 

For example, the town of Parkersburg, Iowa was hit by a Category 5 tornado in May 2008.  EPA representatives are collecting samples outdoors in various areas around the town.  The data for the asbestos monitoring may be found on the EPA website.  No asbestos has being detected in the samples.  However, the samples are collected outdoors, not in the structures themselves, thereby limiting their effectiveness to ascertain the exposure of individuals assisting in restoration activities. 

OSHA is also trying to get the word out that there are potential hazards involved with clean up activities.  OSHA has posted on their website several new, informative pages.  The page regarding asbestos states:

“Cleaning up after a flood requires hundreds of workers to renovate and repair, or tear down and dispose of, damaged or destroyed structures and materials. However, repair, renovation, and demolition operations often generate airborne asbestos, a mineral fiber that can cause chronic lung disease or cancer. The Occupational Safety and Health Administration (OSHA) has developed regulations designed to protect cleanup workers from asbestos hazards.”

(Protecting Workers from Asbestos Hazards, www.osha.gov/OshDoc/flood-tornado-recovery)

“OSHA has developed regulations designed to protect cleanup workers from asbestos hazards!”   Yep, they developed ’em decades ago.  The problem is not that there are no regulations; the problem is in the enforcement.  Again, what I am hearing from consultants on site is that only those public sites such as schools and universities are following proper asbestos abatement procedures.  The residential sites are being ignored.

There is an OSHA exemption for workers not exposed to asbestos over 30 days per year during their work.  But because of the lack of regulatory oversight, the presence of asbestos is not known at most restoration worksites, the workers are not being monitored for exposure and there is no way to know if a worker has been exposed for any duration, much less more than 30 days in a given year.  Think about it.  Workers who mainly do home restorations or remodels could potentially be exposed nearly every working day of their lives.

Possible Solutions

There has to be a solution to this problem.  Here are some ideas on what I think might make a difference and some options as to what we in the industry can do.

Professionalism: In my mind, there are three aspects to this:  experience, education, and communication. As environmental PROFESSIONALS it is our responsibility to uphold what is right and extend knowledge of our trade to others in parallel trades.  This may not be an easy task as there have been enough fly by night so called professionals in our industry to have tainted our industry’s reputation.  This needs to change.  When we receive a call from a homeowner, we should do everything we can to address their concerns and give them guidance on safe practices to look for when work is being conducted in their home.  At the same time we should be bringing the problems to the forefront in discussions with our colleagues.  Most of us are members of various organizations (AIHA, IAQA, ESA, EIA etc.).  During trade shows, chapter meetings, or other get-togethers, the topic of expanding education should be discussed. I bet we can all think of avenues we have available to us to educate the public, homeowners, and construction trades.  Talking with your local regulators and putting the idea in their heads about the safety concerns during restoration in single family homes may have some effect.  With a little effort on everyone’s part we can make change happen. 

New Regulations: During recent conferences, the topic of new regulations regarding asbestos has come up time and time again.  Ban asbestos from household materials!  Change the laws to include winchite and richterite from the Libby, Montana vermiculite mine!  Do we really need more laws governing asbestos or do we just need our enforcement agencies to actually do their jobs?  The laws are already there and have been for decades.  The problem I see and have discussed with others around the country is the lack of enforcement of the laws already on the books.

The asbestos industry has a problem in that enforcement of the various rules is sporadic, inconsistent, and many times interpretation of clear cut rules are just flat out wrong.  Working for a laboratory gives me the opportunity to talk with consultants and regulators from across the country on a daily basis.  I have heard some real off the wall interpretations.  For example, “If you have 50 bulk asbestos samples of one homogeneous area estimated less than 1% asbestos content; none of them need to be analyzed by point count to verify the asbestos concentration.  But, if one of the 50 samples is estimated greater than one percent, then they all need to be point counted.”

The regulator that gave this advice to the consultant I was speaking with was wrong in his interpretation.  EPA’s clarification of when to point count is very clear when applied to this situation:  If you want to treat the material as non-asbestos, you must point count all 50 samples regardless of the initial estimate.  If any one of the samples point count greater than 1%, then the entire homogeneous area is considered asbestos containing and must be treated in a regulated manner.  So what we need is consistent interpretation and enforcement of the regulations already promulgated.

Education through Litigation: As one of the lucky people in this country with a mortgage, I would be ticked if a restoration contractor contaminated my house through ignorance of the law or because the government was turning a blind eye to the situation.  I might even do what most red-blooded Americans would do in this type of situation – sue the bastards.  Homeowners have brought suits against restoration contractors who failed to conduct an asbestos inspection and have won.  I worked on a project where a restoration contractor ended up with an asbestos cleanup bill of around $75,000 plus settlement costs for a situation very similar to the one described at the beginning of this article. 

The restoration contractor, out of ignorance of the asbestos hazard, used a drum sander on the asbestos flooring and contaminated the entire house, including the duct system, furniture, and vehicles of the homeowner.  When you think about it, it’s kind of scary to wonder how many times this restoration crew had done exactly the same thing at other homes and then multiply that by the number of restoration crews operating in the United States.  Contractors need to realize that they are liable for the safety of their employees and for the safety of the future inhabitants of the home.  There is just not enough education in the construction industry about environmental hazards. 

I would hope the court system would be the last resort but unfortunately in our industry it sometimes seems that the only way for a situation to change is to get the lawyers involved.  Once pocketbooks get hit a few times and the actions of the regulatory agencies become the focus of scrutiny, changes may begin to occur. 

So, what it all boils down to is that there exists an entire group of workers whose health and safety is jeopardized on a daily basis because a blind eye is turned toward their work.  I have focused this article on the situation of restoration after natural disasters but these situations occur routinely all over the country, every day, and not because of any catastrophe.  These workers also encounter hazards other than asbestos (lead based paint, biological and chemical hazards) and put themselves and the homeowners for which they work at risk.  

In June, the U.S. EPA’s Office of the Inspector General released its findings from an evaluation of the agency’s Radon Program.  The report’s title and main chapter heading provide a rather succinct statement of their findings:

More Action Needed to Protect Public from Indoor Radon Risks

Risk of Exposure to Indoor Radon Grows Despite EPA’s Efforts

In a presumably unrelated development, an article appeared concurrently in Radiation Dosimetry by Dr. W. F. Angell, President of the American Association of Radon Scientists and Technologists (AARST). This article declared that “U.S. radon research, policy and programs have stalled since their start in the late 1980s and early 1990s. In 2005, more homes had radon above the Environmental Protection Agency (EPA) Reference Level than anytime in history.” 

Although both documents recognized several accomplishments that EPA has achieved over the last 20 years, the overall grade is certainly not an “A.” 

In my estimation, having been involved in this industry for 25 years, the EPA, as well as the states who administer radon programs, whether they be proficiency programs or public awareness programs, operate good programs.  However, with a ranking as a Group A carcinogen and one that is believed to cause 21,000 lung cancer deaths per year in the U.S., is “good” good enough?  Is there not a way, however painful, to take radon programs from Good to Great?   To answer this question lets first examine the elements of the OIG evaluation.

The Inspector General’s Findings

At the suggestion of an Acting Assistant Administrator for the Office of Air and Radiation and the Region 2 Regional Administrator, the EPA’s OIG undertook an evaluation of EPA’s radon program utilizing the goals of the 1988 Indoor Radon Abatement Act as one of its primary comparative measures.  One of the key goals of this legislation tasked EPA to achieve the following national goal for indoor radon exposure:

The national long-term goal of the United States with respect to radon levels in buildings is that the air within buildings in the United States should be as free of radon as the ambient air outside of buildings.

To put this in perspective, this is an ALARA (As Low As Reasonably Achievable) goal that assumes that the lowest level for radon exposure reduction would be to match outdoor radon levels, which is generally assumed to be 0.4 pCi/L.  This number is 10 times lower than the US EPA’s guidance for long-term exposure of 4.0 pCi/L, a guidance which most consumers mistakenly assume exposure below which is safe.  Obviously, to achieve this goal or any reduction, one needs to implement radon reduction methods in existing and new structures.  So how are we doing?

The OIG report points out from statistics provided by EPA’s Office of radon and Indoor Air, that “Nationwide, after 17 years, only about 2.1 million of 76.1 million single family homes in the United States (2.8 percent) had radon-reducing features in place as of 2005.”  The same report also goes on to indicate that in high radon potential areas (Zone 1), “Of more than 1.5 million new single family detached homes built in high radon-potential Zone 1 areas between 2001 and 2005, less than 282,000 (or 18.4 percent) incorporated radon-resistant features.”  

A simple review of these numbers clearly points out (and as reinforced by Dr. Angel in his paper), that with only 2.8% of homes mitigated and with more homes in high radon potential areas being installed without radon control features than with radon control features (82% versus 18%), we are losing ground. 

But maybe it is not as bad as we think it is.

The determination of the numbers of existing homes being mitigated is based upon radon fan sales, and the number of installations of systems during new home construction, provided by the National Association of Home Builders Research Center, which is based upon the numbers of passive radon venting systems installed.

However, are these the only methods that we should be looking at which serve to reduce radon?  Clearly, there is a trend towards healthier buildings where fresh air make-up is encouraged.  The recommendations of the ASHRAE 62 standards, where implemented, would certainly reduce radon via building pressurization and dilution.  Several jurisdictions have adopted make-up air as a requirement for forced air systems that serves this purpose. 

Also, what about the growing trend for slab-on-grade houses to be constructed with post-tension slabs with monolithic pours to where there next to no slab penetrations which, in conjunction with improved ventilation can reduce radon? 

In other words, are there technological improvements occurring within the building industry and the Indoor Air Quality Industry that are not being counted, merely because they do not match our definition of a radon reduction system. 

Another example of this, and well within the experience of the IAQ industry, is the increased integration of air cleaning devices into residential forced air systems that continuously recirculate.  Numerous researchers and practitioners, including myself, have seen the dramatic effect of these systems in reducing indoor radon related exposures to equal to or even less than risks presented in the ambient air, and isn’t this the goal of the Indoor Radon Abatement Act?

So why aren’t these being counted or for that matter, encouraged?  Perhaps it is as Dr. Angel points out in his paper, that peer reviewed research has fallen off dramatically since the early 1990s (See figure below):

The question is why has this falloff in research occurred?  Do we think we know everything there is to know about radon and its reduction?  If that is the reason, then I and others would strongly disagree.  At the risk of receiving boos and hisses, I would suggest that new research is not encouraged, or at least the kind of research that would alter the status quo.

In response to OIG’s citation of the national goal being to reduce radon to exposures to that of outdoor air, the Office of Air and Radiation that oversees the radon program stated:

Radon mitigation methods currently available can significantly reduce the public’s exposure to radon from high levels to appreciably lower levels, well below our recommended action level of 4 pCi/L in many cases. They cannot typically or reliably achieve a level so low as 0.4 pCi/L in a given dwelling, and certainly not in all dwellings. Lacking technologically or economically feasible ways to meet the statutory goal, the regulatory authority offered by Section 310 to meet the provisions of IRAA will not enable its achievement.

Fortunately, Mr. Meyers went on to state in his letter that before “EPA can begin strategizing about how the regulatory authority offered by Section 310 might be utilized to meet the statutory goal, EPA must address the physical and technological limitations to achieving the national goal.” 

However, that takes research and, more importantly, the willingness to evaluate additional mitigation or building techniques, which when used in conjunction with active soil depressurization, can technologically reduce radon or radon decay product exposure to levels far less than is currently being practiced.

It also will likely require the EPA to look to other industry segments other than just the current radon industry for assistance.  Indoor air quality experts, HVAC equipment manufacturers and contractors, building scientists as well as health physicists all have valuable expertise to offer.  We merely have to invite them to the table.

It is well known that ORIA’s budget has been reduced over the years and that scientific personnel directly involved in the radon program have been reduced.  This has led to a greater reliance on industry organizations for technical input.  Although a good management approach to reduced budgets, it also comes with a responsibility to insure that the information is based upon solid research and the inclusion of other industries.

Can the Radon Program Go from “Good” to “Great”?

Certainly, the OIG report pointed out some short-comings, but there have also been successes which can be hard to come by with a voluntary program such as the radon program.  There have been award winning marketing pieces and some solid grass-roots awareness programs accomplished through SIRG funding.  One could certainly call this a “good” program but is it “great” program? 

A great program would be where all homes being built in high potential areas included radon control features.  A great program would be where consumers understood that radon is a health concern and took personal action to test and reduce it because it is a health concern rather than a means to remove a contingency when selling a home.  A great program would be one that addressed the means by which low-income families could have reasonable access to radon reduction methods. A great program would be where a physician conducting a physical exam would ask “What are your radon levels?”

However, the question is how can this be achieved?  I would maintain that before we can answer that question we need to answer the question of: Do we really want a great radon program, or just maintain the status quo?  That means stepping outside our circle of comfort and working with other interests and having the courage to question all of our assumptions, rather than continuing to beat the same drum with the same rhythm.

The question would also be: Why wouldn’t we want a great program?  If we assume that the scientific data to date confirms that there approximately 21,000 lung cancer deaths per year in the United States, then why should it not be a great program that would equal, if not exceed, the importance of any program within the US EPA as well as within any local governmental agency located within high radon risk areas?  Either we believe it and act upon it, or we don’t believe it and treat it as just another hum-drum issue that helps support a partial FTE. 

The conviction to take action comes from leadership at many levels.  Why should a national objective, as stated by law, not be treated with the same conviction as John F. Kennedy’s challenge to land on the Moon, or Al Gore’s recent challenge that 100% of the nation’s electricity be provided via alternative sources within the next ten years.  Is averting 21,000 lung cancer deaths per year any less important or noble than these objectives?  I don’t believe the answer lies in renegotiating the national goal, but rather re-focusing our energies towards achieving the goal.

The OIG report suggests that the US EPA has the authority from Indoor Radon Abatement Act to issue regulations to fulfill the objectives of the act, yet to date has not done so.  First, I would like to point out that I and others are not necessarily in favor of more regulations.  However, anyone who has been in the radon industry for more than a couple of weeks has heard the comment “If radon is so bad, then why isn’t it regulated?”

  Of course, we all respond with the pat answer that it isn’t regulated because it isn’t manmade.  Perhaps, that response is just not good enough.  A hazard is a hazard and why would we treat it differently?  Perhaps, that response comes from a mindset within the EPA that primarily administers regulations regarding manmade sources.  Perhaps, closer liaisons could be formed with agencies that deal primarily with voluntary programs regarding environmental health, such as the National Center for Environmental Health at the Centers for Disease Control.

To take different approaches, including regulatory approaches will not be easy.  Nor will considering new technologies and including other non-traditional stakeholders be easy.  But, I would maintain that if those to whom we have entrusted the duty to advise us on the health and safety of our environment are serious, then it is time to toss out the Easy Button.

In closing, I must indicate that I borrowed the title of this article from Jim Collin’s book “Good to Great” that, in my opinion provides some valuable insights in how such a transition from good to great could occur within our industry.  I listened to it on CD as I drove across the country and would highly recommend it. 

As always who says there is nothing new in radon?

Doug Kladder

High-Volume Air Exchange for More Efficient Remediation: A Case Study

Following Hurricane Katrina my company, Indoor Environmental Technologies, was retained to assist in the remediation of a large government building on the Gulf Coast.  The project proved to be more complex than anticipated, with IET on-site for over three months. Procedures we developed with the remediation contractor resulted in a more than 50% reduction in both the estimated time and estimated cost of remediation.

Due to concerns created by the Oklahoma City bombing, the recently-built 10-story structure was designed to withstand a similar attack. This design also resisted damage from Katrina, despite a location only two blocks from the Gulf subjected to sustained winds above 140 mph.  Two feet of water entered the ground floor due to storm surge, but physical damage to most of the building was remarkably light.

No windows broke, but they leaked. They leaked a lot. Windows and other building assemblies are seldom able to prevent leakage caused by very high winds. At sea level, wind pressure per square foot is calculated at about 13 pounds at 50 mph, 51 pounds at 100 mph and 100 pounds at 140 mph.

Materials in the building were not dried rapidly enough to prevent extensive mold growth on wet materials, especially in wall cavities and where up to five layers of drywall were present.  Growth was generally found near the perimeter of the structure, especially on exterior walls. 

Building management decided to use visual criteria to determine whether remediation was needed in an area and when remediation had been successfully completed. Air, surface and bulk sampling were not used. Intrusive inspection determined which areas and materials needed remediation.

IET’s client was the remediation contractor. We cooperated with consultants working for the government and for the general contractor. Top priorities were to complete remediation rapidly and in a systematic manner so that reconstruction could begin as quickly as possible.

The Katrina project will be used in this article as a case study to illustrate some of the procedures IET developed to meet these objectives. Our primary discovery was that high air exchange rates combined with relatively small volume containments allows the remediation process to proceed more quickly. IET also developed methods that allowed more than 200 small volume containments to be assembled and relocated rapidly and efficiently. We will discuss the second of these methods first. 

Reusable Local Containment Barriers

Traditional remediation often involves isolating entire rooms, treating them as units. On the Katrina project, most affected materials were located on exterior walls, with growth often extending up the walls less than two feet, mostly inside cavities.  We speculated that remediating affected walls rather than rooms would speed the process. On this particular project, the time required to remediate entire rooms would have been even greater than usual, as most areas had 20’ ceilings and many of the rooms or areas were large. 

For each affected area a floor sheet was installed, then lightweight reusable panels were used to form a barrier about 4’ out from the wall. A containment ceiling was created by attaching poly to the wall with a 1x2 about 7’ up, stretching the poly over to the panels, then attaching the poly to the outside of the panels with spray adhesive.

Panel frames were made of 1¼” Schedule 80 PVC pipe. A variety of connectors were used, including Ls, Ts, snap clamps, 3-way and 4-way fittings.  Most panels were 7’ wide by 5½’ high, as this size could easily be moved from floor to floor on the elevators. Panels were also constructed in 3’, 4’, and 5’ widths.

Panels were wrapped in 6 mil poly and secured with spray adhesive, snap clamps and tape.  The poly was good for about 10 setups.

Panels were connected with PVC pipe fittings. 2” to 3” gaps between panels were left partly open for makeup air entry. To prevent the assembly from collapsing forward under negative pressure, 1x2 cross-members ran from the 1x2 ceiling support on the wall to each point where panels joined. See below for a more detailed description and diagrams of the process. See Figure 1 for a photo of a completed containment.

Massive Air Exchange

IICRC S520 Standard and Reference Guide for Professional Mold Remediation and other published standards generally recommend 4 to 12 air changes per hour (ACH) in contained areas as an engineering control for a safer working environment. Since this recommendation is a minimum, higher ACH creates no conflict with the standard. We wondered if significantly higher air exchange rates might contribute to more rapid and effective remediation.

It is commonly assumed the volume of air exchanged should be in rough proportion to the volume of the work zone, or that using a large negative air machine for a small containment causes problems. In fact, negative pressure is created when air is exhausted from a space while the total area of openings in that space available for infiltrating air is restricted.  Negative pressure has no direct relationship to the volume of the space being exhausted.  Small volume containments can easily be maintained at high air exchange rates but “normal” negative pressure by increasing the area of makeup air openings. As long as appropriate negative pressure is maintained, these openings can be any size or location.

Assume a local containment 25’ long, 4’ wide. Height averages 6’, so volume is 600 CF. Attaching a 2000 CFM negative air machine generates 200 ACH.

The containment is sealed tightly so makeup air enters only at the far end from the exhaust point. Average air speed across the containment is 83.3 feet per minute.  In other words, air will on average cross this work zone and be exhausted in about 18 seconds. This leaves little time for fine particles to settle onto surfaces or accumulate in the air!

In the real world, due to turbulence and other factors, these results are not consistently achieved. However, high air flow across the work zone has many benefits even when true laminar air flow is not maintained.

Benefits of high volume air flow include:

o   Employee safety:  High air exchange from a clean(er) source means that the air in the containment is significantly less contaminated. IET has no specific data, but it is reasonable to assume air exchanged at 200+ ACH will be at least 95% lower in contaminants than air being exchanged at 4 ACH.  Effective engineering controls may justify reducing the level of PPE.  However, due to high momentary exposures during initial phase remediation, respiratory protection is always needed. It is best to err on the side of safety.

o   Employee comfort: Airflow helps keep workers cool, reducing heat stress. Decreasing the level of respiratory protection may also help worker comfort.

o   Entry/exit controls: IET generally found it possible to complete controlled demolition and detailed cleaning in a single work period, eliminating entry/exit while work was in progress and minimizing cross-contamination.

o   Processing time: The most labor-intensive and time-consuming aspect of mold remediation is detailed cleaning; often done by cleaning all surfaces, allowing aerosolized dust to settle, repeating as needed. Three or more “rounds” of detailed cleaning are sometimes required to reach a true “dust-free environment” level of cleanliness, which means that a minimum of four or five days may be needed for the entire process. Fine dust particles aerosolize easily and settle slowly. They are the most difficult to remove using traditional methods.  Using the system discussed in this article, the area of surface to be cleaned is greatly reduced since only a small portion of the room is contained; the volume of air that dust particles can disperse into is reduced to an even greater extent; and fine particles remain aerosolized for only brief periods. Most importantly, there is no need to wait for dust particles to settle between rounds of cleaning. When reusable containment panels were combined with high air flow, most work zones were contained, remediated and successfully “cleared” in one day.  (See Figure 2.)

Concerns

The cleanliness of makeup air is critical. Under negative pressure, air infiltrates at multiple, usually unknown points. If contaminants are present in the path of infiltrating air, they may be pulled into the contained space, negatively impacting the remediation process and worker exposure.

High volume air exchange may pull in outside humid or hot air when exhausted to the exterior of the building. On this project, this was not an issue, as air exhausted back into the conditioned space.

For a given containment setup, increasing ACH does not change the pathways infiltrating air travels. When the same negative air pressure is maintained, the volume and velocity of airflow through any given infiltration pathway is about the same whether the exchange rate is 4 ACH or 400 ACH, so the chance of contamination from infiltrating air is also about the same.

Containments can be built to withstand high levels of negative pressure. Unlike high airflow, the volume and speed of air infiltrating at uncontrolled points increases with high negative pressure. As air volume/speed increases, so does the chance that contaminants will be pulled in.  Negative pressure higher than 10 Pa (0.04” wg) provides no real benefits and significantly increases both the potential for cross-contamination and the strain on the containment structure.

On larger containments, multiple negative air machines were used when needed to keep nominal ACH above 200.  To maintain adequate negative pressure, multiple machines were also used in some situations where wall cavity design allowed massive infiltration. On some smaller containment setups, ACH was well over 1000. Workers likened this to working in a wind tunnel. (See Figure 3.)

Step-by-Step Process

Example: A typical containment area about 38’ in length with an affected area about 30’ wide. See Figures 4 and 5:

1. Install a floor sheet. Set up and connect panels. Five 7’ wall panels and two 5’ end panels (installed at a slight angle) are used, with one of the wall panels incorporating an entry door. Attach a 10’ wide ceiling sheet to the wall at about 7’ height with a continuous 1x2 furring strip. Install 1x2 cross-members under the ceiling sheet from the wall 1x2 to the wall panels to prevent air pressure from pushing the panels in and reducing working space. Stretch the ceiling sheet over the cross-members, securing to panels with spray adhesive.

2. Install two 2000 CFM negative air machines, providing 270 nominal ACH for this 888 CF containment.  Test the system to ensure that containment is structurally solid. Adjust makeup air to maintain 5 to 10 Pa (0.02 to 0.04” wg) by covering openings between panels or cutting additional openings in panels. Ideally, most makeup air enters at the far end of the containment from the exhaust. Depending on conditions in the surrounding area, an exhaust diffuser may be used or the exhaust may be ducted into another area.

3. Four people don PPE and enter containment. Starting at the far end from the negative air machines, two workers remove drywall to 2’ or 4’ above the floor. A small-diameter circular saw/HEPA vac system minimizes dust. Drywall is cut into 2’ squares. Removed materials are immediately bagged. The other two workers follow behind, removing screws and starting the cleaning process. On large containments, the number of workers may be increased.

4. When drywall removal is complete, all workers continue cleaning, primarily with HEPA vacs.

5. A second round of detailed cleaning starts at the far end of the containment and involves HEPA vacuuming followed by damp-wiping of all surfaces. 

6. After the second round of cleaning, monitoring with a particle counter begins.  The particle level of the makeup air at 0.5 µm/CF is compared to the level inside the containment. Soft bristle counter brushes are used on surfaces to aerosolize remaining dust particles. If measured particle levels climb when this is done, additional cleaning is performed.  Remediation is complete when disturbing surfaces does not increase particle count.  Workers vacuum off PPE and doff it, bagging gloves and protective clothing. Debris bags are double-bagged. Workers exit containment. Steps 3-6 can usually be completed in a single work period (2 to 3 hours).

7. IET performs post-remediation evaluation using visual inspection and particle counter methods.

8. If IET approves the work, the consultants working for the government and the general contractor inspect the work. If approved, the containment is disassembled and ceiling and floor sheets discarded. Panels are moved to the next scheduled work area.

The entire process from setup of containment to post-remediation verification and disassembly was usually completed in a single day. 

As stated, on this project the client decided to use visual criteria to determine whether remediation had been successful, focusing on achieving a truly dust-free environment.  However, on other projects, IET has set up an on-site laboratory with a microscope, using non-viable air and surface samples to document successful remediation.  When work flow is properly structured, it is still possible to complete the whole process in a single day.  IET has never had a work zone that passed the dust-free surface and particle count criteria fail our microbial sampling criteria.

For localized contamination, IET has found a strategy of minimizing the volume of the containment while maximizing airflow across the containment to be highly effective. It speeds the remediation process while increasing its effectiveness.

Timothy D. Toburen is an Indoor Environmental Consultant for Indoor Environmental Technologies, based in Clearwater, Florida.  He has worked in the restoration, remediation and environmental consulting industries for over 35 years, serving on the committees that produced both the IICRC S520-2003 Mold Remediation and S500-2006 Water Damage Restoration standards.  He can be reached by e-mail at ttoburen@ietbuildinghealth.com or by phone at (727) 446-7717.

Will Spates is President of Indoor Environmental Technologies, based in Clearwater, Florida. He has over 20 years of experience in the environmental consulting industry. He can be reached by e-mail at wspates@ietbuildinghealth.com or by phone at (727) 446-7717.

Henry Gifford, an energy efficiency expert who lives in New York City, believes that the LEED “green building” rating system developed by the U.S. Green Building Council -- is misleading in one critical area: He claims the LEED certified buildings for which fuel bills have been made available, use, on average, more energy, not less, than equivalent non-LEED certified buildings.

(We asked the U.S. Green Building Council for comment on our concerns; their response can be found at the end of this article.)

Mr. Gifford was the opening speaker at Joe Lstiburek’s annual Westford Symposium on Building Science last August 4. He presented data supplied by the New Buildings Institute of Vancouver, Washington, which the USGBC commissioned to do a study of LEED building energy use, along with confirming audio recordings from their past conference proceedings CD as substantiation for his conclusions.

After first hearing the claims that LEED buildings save energy, his initial reaction was that it was hard to believe that people taking an 8 hour class and then following a checklist could influence a building design in a way that produced significant energy savings. LEED was claiming 25-30 percent savings when the numbers published in the study showed 25 percent. Not a huge difference, but significant none the less. Mr. Gifford continued:

I went to the sources at the New Buildings Institute and I asked for the mean value of the energy use of the LEED certified buildings. I was not encouraged by their hesitancy. After some persistence they reluctantly gave me the figures.

After I received the missing value, my calculations were even more disturbing. I now was looking at a 29% increase in energy usage over conventional buildings, not a decrease.

The audience, composed of many of the most accomplished and venerated building scientists and associated professionals in the U.S. greeted his presentation not with challenges (at which they are diplomatically adept) but with hearty applause and cheers. “Hallway” conversation afterwards was supportive and appreciative of what he did.

I asked Lstiburek, organizer of the symposium (and a member of IE Connections’ editorial advisory board), about the credibility of Henry’s report. He said, “Many of us suspected some of the LEED claims didn’t fit the data. We complained to each other but Henry did the research and proved it. He is dead on.”

Dr. Joe then rattled off a list off several offending buildings and their discrepancies, many of which are celebrated icons of LEED prowess.

In San Francisco the Federal Building looks like something out of a Mad Max post apocalyptic vision is so uncomfortable the occupants are suing the General Services Administration.  The 20 story building was constructed without air conditioning with elevators running only to every other floor (you have to walk up or down a floor).  Occupants have to wear sunglasses to deal with the glare.

In London, England the London City Hall designed by Sir Norman Foster was being celebrated as the greatest green building ever – before it was built – now there is deafening silence from the British Research Establishment as the energy bills come in.

In Seattle, the new City Hall, a LEED green building is consuming 50 percent more energy than the building it replaced.

According to Joe the list goes on and on and on…..

Gifford’s investigation focused on two primary factors on how the USGBC performed the statistical analysis of their data.

Gifford: First, and in layman’s terms, the study compared the median (the number separating the higher half of a dataset from the lower half) of one dataset to the mean (average) of another dataset, which is a meaningless and misleading comparison.

They called the 20 worst performing buildings “high” energy use buildings, and omitted them from most of their analysis. They called the best 101 the “medium” energy use buildings, and gave a glowing report on how well those compare to various goals. 

Which leads to Gifford’s second point:

I read the report and noticed that there was no basis for the 30% claim. The LEED buildings had a claimed Energy Use Index (EUI) of 68, which when compared to the CBECS figure of 91 for all buildings, shows a 25% saving. I then noticed that the CBECS data includes those built before 1920. Further down the same page in the CBECS report there was data for buildings built between 2000 and 2003. Because all the LEED buildings were built after 2000, I compared their claimed energy use to the 81.6 figure for the newest buildings and found the saving was only 17%.

However, this is still not valid, because it is based on comparing the MEDIAN value of the LEED buildings with the CBECS data, which is a MEAN value. I know that comparing a mean to a median is a meaningless comparison, but the study never mentions the median value of the LEED database. I found out that the LEED buildings have an Energy Use Index of 105. This is 29% higher than the CBECS EUI figure for the newest buildings in their dataset. In other words, LEED certified buildings use, on average, 29% more energy than the most comparable buildings.

Gifford showed the audience the following two charts from page 15 and 16 of the informational slide show entitled Energy Performance from LEED Buildings prepared by the New Buildings Institute for the USGBC.

Available from: http://www.newbuildings.org/downloads/LEED_presentation_Nov2007s.pdf

Figure 1: Page 16 of the New Buildings Institute slide show. The chart is based on the data set for the 25% part of the claim of a 25-30% savings. It is fundamentally flawed because it compares a median (LEED buildings) to a mean (CBECS data on thousands of buildings)

Figure 2:  Page 15 of the New Buildings Institute slide show. This chart includes all buildings in the data set, including the High Energy buildings excluded from most of the analysis in the report. Gifford’s calculations for the entire data set show an EUI of 105, a 29% increase in energy usage, not a 30% decrease.

Gifford: The chart from page 15 of the New Buildings Institute slide show includes the 20 worst buildings which were excluded for most of the analysis. The chart from page 16 of the New Buildings Institute slide show shows the best 101 buildings, and compares the median value of all 121 buildings with the CBECS data which includes buildings built before 1920. Also, page 16 compares the median of all 121 buildings to the mean value of the CBECS database. According to Cathy Turner, one of the authors of the study, the actual mean value for the 121 LEED certified buildings is 105.

Two days later Henry Gifford reported to the conference Cathy Turner’s calculation of 105 as the mean value for the 121 LEED certified buildings

Shortly thereafter, Sam Rashkin, National Director, U.S. EPA ENERGY STAR for Homes, presented an update on his program. But first he made the following comment. “Henry’s findings are important for establishing the credibility of energy savings claims in buildings.”

In a subsequent personal conversation, Mr. Rashkin pointed out that although his involvement with the ENERGY STAR program is for residential rather than commercial buildings, LEED for Homes uses ENERGY STAR as a minimum requirement. Thus, energy savings claims by USGBC for homes should be reliable if they track those promised by ENERGY STAR. However, in the past, the LEED for Homes draft brochure promised energy savings twice to three times that of ENERGY STAR. USGBC has advised EPA that they will revise that claim based on EPA concerns.

He then made another interesting point.

“Energy Star uses a system approach to buildings whereby one component dynamically affects the others. This means each cannot be evaluated solely by itself. Yet the USGBC rating for residential buildings separates the various components by assigning each with its own point value. They grant building accreditation based on a total of the points without considering what makes up the points or the relationship between the ones chosen. One building may have critical  IAQ components for chemicals and radon, for example, and another with only water management IAQ components, yet both carry the same rating.”

My overall impression at the symposium was one of professional collegiality and a confidence that USGBC would now do the right thing.

But some, including Joe Lstiburek, were not as optimistic.

"Despite the current LEED attitude and the general attitude of the architectural profession as a whole, LEED and the USGBC represent the best hope and best vehicle to get better buildings designed and delivered.  It is unfortunate that LEED and the architectural profession have to be embarrassed, ridiculed, chided and otherwise yelled at before they change.  Playing nice apparently does not work as it does not seem to penetrate the layers of arrogance and holier than thou attitude."

Henry Gifford hopes that from now on, not a single building is rated as environmentally friendly unless actual utility bills are made publicly available to show that it really does save a significant amount of energy. “It is time for our country to stop relying on estimates of energy savings and start measuring actual savings.”

Green Building Council Response

During the preparation of this article, we asked for comment from the folks responsible for the LEED system. Mark Frankel, technical director of the New Buildings Institute, took sharp exception to some of our contentions.

According to Frankel, the article ignores the fact that “if you look at ANY type of building in the LEED data other than Labs, the (average or mean) EUI for each type is well below the CBECS average EUI for that type of building.  As an example, office buildings, which make up the most common building type in LEED, have an average EUI of about 62 for LEED buildings, compared to 93 in CBECS.  There is not a single category of building for which the LEED buildings don't have a lower EUI than CBECS.”

Brendan Owens, vice president of technical development at USGBC, added: “The NBI study was reviewed internally at NBI and externally at DOE, EPA and LBNL ... I find it hard to accept that everyone who reviewed the paper is complicit in the misrepresentation you seem to believe was perpetrated.”