Indoor Air
No longer seen as a safe haven,
air indoors presents special
pollution problems
K *-.*-•
-------
United States
Environmental Protection Agency
Carol M. Browner
Administrator
Communications, Education,
and Public Affairs
Loretta M. Ucelli
Associate Administrator
Miles Allen
Director of Editorial Services
Karen Flagstad
Senior Editor
Christine Gillis
Assistant Editor
Ruth Barker
Photo Editor
Nancy Starnes
Assistant Editor
Marilyn Rogers
Circulation Manager
Francheska Greene
Intern
Design Credits
Ron Farrah
James R. Ingram
Ftom cover: Photo by Miko Brisson.
s
ome sad news: New
England and EPA lost a
true advocate for the
environment with the death
of Paul G. Keough, Deputy
Regional Administrator in
Region 1. Paul was well
known as a tough enforcer,
a fair administrator, and a
superb communicator. He
was also a national leader
in promoting environmental
education and EPA's human
resources, as Administrator
Browner recognized by
creating the Paul G.
Keough Award for Adminis-
trative Excellence. He will
be sorely missed.
A Magazine on National and Global Environmental Perspectives
October-December 1993 • Volume 19, Number 4 • EPA 175-N-93-027
From the Editors
IVlention air pollution, and most of us think of outdoor air
pollution and regulatory standards under the Clean Air Act.
Those of us who live in certain urban areas may think of
"inversion" effects and smog alerts, when we may be advised
against exercising out of doors.
But what about indoor air? Comparatively recent exposure
monitoring studies, based on a concept called "total exposure
assessment/' have called into question the notion that indoor
environments are a safe haven from air pollution. In fact, certain
pollutants, such as benzene (a component in environmental
tobacco smoke, or ETS) are sometimes found at higher levels
indoors than outside. The implications of these findings are
compelling. After all, 90 percent of our time, on average, is spent
in indoor environments including residences and workplaces,
various public and commercial buildings, and private and public
transport vehicles (cars, buses, subway and other trains, and
airplanes).
Outdoor ambient air-quality standards do not apply to indoor
air. Even if they did, however, few observers believe that a
traditional, pollutant-by-pollutant approach would be adequate to
solve indoor air pollution problems. Among other reasons, many
more pollutants are involved (4,000 in ETS alone) than are
regulated in outdoor air, and there are many unanswered
questions about such phenomena as "sick building syndrome"
and multiple chemical sensitivity. What, then, is the best
approach for protecting indoor air quality? Not everyone agrees,
but several contributors to this issue of EPA ]ournal explore this
question. Related articles discuss cutting edge research, regulatory
and nonregulatory initiatives, and proposed legislation. Take a
deep breath, and stay with us. a
EPA JOURNAL Subscriptions
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-------
CONTENTS
Indoor Air
No longer seen as a safe haven,
air indoors presents special pollution problems
Articles
, Taking the True Measure of Air Pollution
by Kirk R. Smith
An Inside Look at Air Pollution
by Ken Sexton
")
~
Ur*
Indoor Allergens: A Report
by Andrew M. Pope
, Improving IAQ: EPA's Program
* by Bob Axelrad
Environmental Tobacco Smoke: EPA's Report
by Carol M. Browner
•
i Environmental Tobacco Smoke:
Industry's Suit
by Steven Bayard and
Jennifer Jinot
• Laws Protecting Nonsmokers
by Fran Du Melle
23 The TEAM Studies
by Lance Wallace
O C Investigating Sick Buildings
by Brian Leaderer
^ Economic Effects of Poor IAQ
by Curtis Haymorc and Rosemarie Odom
Regulating IAQ: The Economist's View
by Robert G. Hanson and John R. Lott, Jr.
California's Program
by Jerome Wesolowski
IAQ: Whose Responsibility?
by Hal Levin
"If* Lessons From Radon
by Mary Nichols
*2 Q The View From Congress
by Representative Henry A. VVaxman
Departments
9 EPA ROUNDUP
40
42
44
FEATURING EPA
Simulating a Radioactive Release
by Brad Nelson
FOR THE CLASSROOM
A Lesson Plan on Indoor Air Quality
by Stephen Tehudi
CHRONICLE
Legendary Pest Remedies
by Christine L. Cillis
ON THE MOVE
LIST OF CONTRIBUTORS
LETTERS
The U.S. environmental Protection Agency is charged by Congress to proteect the nation's land, air, and water systems. Under a mandate of national
environmental laws, the Agency strives to formulate and implement actions which lead to u compatible balance between human activities and the ability of
natural systems to support and nurture life.
EPA Journal is published by EPA. The Administrator of EPA has determined that the publication of this periodical is necessary in the transaction of (he
public business required by law of this Agency. Use of funds for printing this periodical has been approved by the Director of the Office of Management ant!
Budget. Views expressed by authors do not necessarily reflect KPA policy. No permission necessary to reproduce contents except copyrighted photos and other
materials.
Contributions and inquiries are welcome and should be addressed to: Editor, EPA Journal (1704), Waterside Mall, 401 M Street, SW, Washing-ton, DC
20460.
-------
EPA ROUNDUPS
EPA Responds to NAS Pesticide Report
EPA Administrator Carol
Brounifr has announced actions
that the Agency will take to
carry out recommendations of the
National Academy of Sciences
report Pesticides in the Diets
of Infants and Children.
Browner said: "The National
Academy of Sciences' study
makes three key recommendations
that I strongly agree with. . . .
One, we don't knou> enough
about the dangers of the
pesticides we use, and we need to
find out more. Two, we don't
know enough about the residues
that remain on the food we eat,
and we need to find out more.
And three, we don't knoiv what
children's exposure is (to
pesticides) because we don't know
what children eat. We need to
find out."
The Washington Post
reported: ". . . It [the report]
recommends that when
adequate data on a given
chemical are lacking, 'there
should be a presumption of
greater toxicity to infants and
children.' In such cases, the
NAS panel called for
exposure standards 10 times
more stringent than would
normally be applied. But the
study emphasizes that
parents should not reduce
their children's consumption
of fruit or vegetables. . . .
Currently, the Environmental
Protection Agency regulates
pesticide levels by balancing
agricultural benefits with
health risks, based on an
extrapolation from figures on
average adult consumption.
That system does not take
into account the dietary
patterns of children, who eat
fewer foods and consume
much more of certain foods
per unit of body weight than
adults, the panel
concluded. . . . To improve
regulation of pesticides and
increase understanding of
how they affect children, the
NAS panel urges federal
regulators to:
• Use immature animals in
addition to adult animals
(usually rodents) to test for
the toxicity of pesticides, to
provide better information
about how young organisms
react to the chemicals.
• Conduct food consumption
surveys at one-year intervals
up to age 5, as well as
surveys of children age 5 to
10 and 11 to 18. Surveys now
use only broad groupings that
do not reflect dramatic
changes in dietary patterns
at different ages.
• Increase sampling of
pesticide residues from food
consumed by infants and
children.
• Consider all sources of
dietary and non-dietary
exposure to pesticides,
including drinking water and
water added to foods, as well
as air, soil, lawns, pets and
indoor surfaces. Apply new
statistical methods in
estimating risk for
children. ..."
The New York Times
commented: ". . . Until now,
critics charge, agencies in the
Government have been at
odds over agricultural
chemicals and in recent years,
especially during the Reagan
Steve Detaney photo.
and Bush administrations,
there has been no effort to
restrict their use. Until now,
there has been no
coordinated effort among the
agencies, except when
concerns about individual
pesticides have raised public
alarm. Otherwise, the
environmental agency has
dealt with analyzing the
safety of pesticides, the
health agency has tested for
pesticide residues in food and
the agricultural agency has
worked to keep pesticides on
the market to help farm
production and income. 'The
Agriculture Department,
E.P.A. and the Food and
Drug Administration are
working together in a way
they have never done before
to benefit the American
people/ said Carol M.
EPA JOURNAL
-------
EPA. the Department
of Agriculture, and the
Food and Drug
Administration are
working together to
learn more about
children's exposure to
pesticides.
Browner, Administrator of
the E.P.A The food
and chemical industries say
that the food supply is safe
but agree that changes in
regulations are in order. 'We
need to be especially
concerned about children,'
said Lester Crawford,
executive vice president for
scientific affairs of the
National Food Processors
Association, 'because they
will get 70 years of exposure.
Changes ought to be made in
E.P.A. regulations. . . . ' The
National Food Processors, the
Grocery Manufacturers of
America and the United Fresh
Fruit and Vegetable
Association have been
recommending that their
members use Integrated Pest
Management. ..."
EPA Awards
Environmental
Education Grants
Under the National
Environmental Education Act
of 1990, EPA has awarded
$2.7 million in grants for
environmental education
initiatives to schools,
universities, and nonprofit
organizations in all 50 states
as well as Puerto Rico,
American Samoa, the
Republic of Palau, and the
District of Columbia.
Administrator Browner
said, "My administration has
identified four priorities for
the Agency: pollution
prevention, ecosystem
protection, partnerships, and
environmental justice. The
common thread through
these priorities is
environmental education.
Through the awarding of
these grants, we hope to
educate children and adults
about how their everyday
actions have a direct impact
on the world we live in."
In selecting grant winners,
emphasis was placed on
projects that improve
environmental education bv
enhancing teaching skills;
facilitate communication,
information exchange, and
partnerships; motivate the
general public to be more
environmentally conscious;
and develop an
environmental education
practice, method, or
technique that is new, has
wide application, and
addresses high priority
environmental issues. EPA
headquarters awarded the
nine grants that exceed
$25,000 each; EPA's regional
public affairs offices chose the
other 237 winners.
Headquarters grant winners
were the University of Rhode
Island; Citizens Committee
for New York City, Inc.; The
League of Women Voters
Education Fund, Washington,
DC; North Carolina State
University; Louisiana State
University Agricultural
Center; The Hazardous
Materials Training Research
Institute, Iowa; "E-Town" of
Boulder, Colorado; Humboldt
State University Foundation's
Center for Indian Community
Development, California; and
the Washington State Office
of the Superintendent of
Public Instruction.
U.S. Leads in
Envirotech Exports
An EPA report on
international trade in
environmental protection
equipment shows that the
United States has enjoyed an
increasing surplus since 1989.
The surplus stood at $1.1
billion in 1991, the last year
for which data are available.
This surplus contrasts with an
overall U.S. trade deficit,
which stood at $100 billion in
1990. The report, International
Trade in Environmental
E(jni;>im'»if: An /\sst'ss»it'iif of
Existing Data, analyzes
imports, exports, and
balances between 1980 and
1991 for the United States,
Germany, Japan, Canada,
France, South Korea, Mexico,
Taiwan, and Great Britain.
EPA officials said that, while
the report shows the United
States to be in the lead, it
leads by only a slim margin,
and more must be done to
stimulate competitiveness:
Taken as a percentage of
GDP, Germany, for example,
exports four times as much as
we do.
The Organization of
Economic Cooperation and
Development (OECD)
estimates that the global
market for environmental
goods and services in 1990
was $200 billion; it projects
the market will rise to $300
billion by the year 2000. 1{PA
currently spends about $120
million on
environmental-technology
activities. President Clinton
has asked for an additional
$36 million in fiscal year 1994
and an $80 million increase in
fiscal 1995.
A 1992 grant winner, the Mann County.
California, Office of Waste Management.
operates a "composting across the curriculum"
program for elementary and middle schools
OCTOBER-DECEMBER 1993
-------
EPA ROUNDUPL
Whirlpool Wins $30 Million Contract in Refrigerator Contest
In a contest sponsored by ti
consortium of 24 electric utilities,
Whirlpool Corporation has won a
$30 million contract to provide
consumers with refrigerators that
use 20 to 50 percent less
electricity than that currently set
by Department of Energy
standards. The consortium,
which runs the Super Efficient
Refrigerator Program (SERP),
also knoivn as the Golden Carrot,
developed the contest in close
collaboration with EPA, the
Electric Power Research
Institute, the Natural Resources
Defense Council, the American
Council for an Energy-Efficient
Economy, the Washington State
Energy office, and others.
Administrator Browner
commented: "The SERP
partnership will save consumers
money and protect the
environment. Here's a good
example of environmental
protection achieved not In/
expensive and contentions
regulation, but by a voluntary,
private-sector initiative that
actually helps the economy."
Whirlpool employee connects
sensors for energy efficiency
test at Refrigeration
Technology Center in
Evansville. Indiana
Whirlpool's CFC-free.
super-efficient refrigerator will
save consumers money on
their electric bills
The Los Angeles Times
said: ". . . The competition,
which drew 500 responses
from around the world, was
intended to accelerate
development of a refrigerator
that would be at least 25%
more energy-efficient than
today's models and use no
ozone-depleting
chlorofluorocarbons, or CFCs.
David Goldstein of the
Natural Resources Defense
Council, which first proposed
the contest idea, called the
collaborative program 'a
whole new way to address
the energy policies of the
nation.' Each of the utilities
provided from SI50,000 to S7
million, depending on the
number of customers in their
service area. Goldstein
estimated that the new
refrigerator will save utility
customers $300 to S500 in
electric bills during the
appliance's lifetime. Across
the country, state regulators
are pressing utilities to find
innovative ways to reduce
customers' energy use instead
of building new power plants
to meet increased demand.
Refrigerators, which use
about 20% of the electricity in
the average household,
seemed like a logical first
step, said Ray Farhang, an
Edison executive who headed
the utility consortium. ..."
USA Today commented:
". . . Whirlpool's fridge,
available from retailers early
next year under the
company's Whirlpool,
KitchenAid and Kenmore
brands, will cost $1,300 to
$1,400. That's at the high end
of the price range for
similarly equipped but
less-efficient models that use
CFCs. ... On the inside,
Whirlpool photo
Whirlpool's SERF fridge
contains a computer chip that
knows when to defrost and
when the energy-sucking
move isn't necessary. That's
more efficient than defrosting
on a regular, timed schedule
whether needed or not. The
model also has insulation
made of CFC-free substances,
high efficiency fan motors
and a new type of refrigerant
that does not include CFCs,
such as Freon. Yet on the
outside, the object of so much
science and so much money
looks pretty familiar. The
model unveiled in front of 90
people at the Marriott Long
Wharf Hotel is a tasteful
white, 22 cubic-foot,
side-by-side unit—'designer
style #22.' It has an
automatic ice maker, a utility
bin, a crisper and a snack bin.
The left door features an
exterior water and ice
dispenser—your choice,
crushed or cubed. Will
consumers buy it? That was
the missing link at Tuesday's
proceedings. Whirlpool's
Fettig praises SERF for
spurring development of a
product 'that consumers,
frankly, weren't asking for.
The simple truth is
consumers don't generally
perceive the value of added
efficiency'. . . . Initially,
Whirlpool's winning model
will be sold only in areas
covered by contributing
utilities. That's a condition for
getting the prize. The areas
include parts of Arizona,
California, Idaho, Maine,
Maryland, Massachusetts,
Minnesota, Montana,
California, New Jersey, New
York, Oregon, Washington
and Wisconsin. . . "
EPA JOURNAL
-------
Ongoing Enforcement
$2.8 Million Sought
for Failure to Report
Chemical Releases
Administrative complaints
totaling $2.8 million have
been filed by EPA against 37
facilities for failing to make
reports to the Toxic Release
Inventory (TRI). The facilities
are located in all 10 EPA
regions. Under the
Emergency Planning and
Community Right to Know
Act (EPCRA), companies
must report to TRI by July 1
each year on releases or
transfers of certain toxic
chemicals. TRI currently lists
more than 300 such
chemicals. The Pollution
Prevention Act requires that
companies also report on
source reduction and
recycling activities associated
with these chemicals. The
complaints are against
companies that failed to file
reports for 1991 and
preceding years. The
companies include paper
manufacturers, motor vehicle
manufacturers, makers of
railroad equipment, makers of
specialty cleaning and
sanitation preparations,
ammunition makers, and
many others. Companies who
fail to submit TRI reports are
subject to civil administrative
penalties of up to $25,000 per
day per violation. TRI allows
EPA and the public to gauge
progress in reducing toxic
chemical waste. State and
local emergency response
officials, fire departments,
and others use TRI to identify
chemical threats.
Action to Stop
Untreated Sewage
Discharge in
South Florida
The Department of Justice
and the U.S. Attorney's office
in Miami have filed a civil
complaint on behalf of EPA to
stop the illegal discharge of
untreated sewage into the
Miami River, Biscayne Bay,
and other local waterways,
and to replace the Cross-Bay
line—a 37-year-old sewer pipe
that carries untreated sewage
from Miami under Biscayne
Bay to a treatment plant on
Virginia Key. The complaint,
filed against metropolitan
Dade County (Metro-Dade),
Florida, and the Miami-Dade
Water and Sewer Authority
Department (MDWASAD),
alleges numerous and
repeated discharges of raw
sewage into the Atlantic
Ocean, Biscayne Bay,
Gratigny Canal, and the
Miami and Little rivers. As
recently as last spring, some
25 million gallons of
untreated wastewater were
discharged into the Miami
River because of a pump
station failure. EPA and the
State of Florida are working
with county officials to
develop a plan for
expeditious replacement of
the Cross-Bay line and for
preventing further discharges
from the wastewater
collection and treatment
system.
Hazardous Waste
Action Against
Air Force Base
The first imminent and
substantial endangerment
order ever issued to a military
installation has been filed by
EPA against the Reese Air
Force Base, located near
Lubbock, Texas. Samples
drawn from one of the base's
offsite monitoring wells for
the area's aquifer contained
carbon tetrachloride, chloro-
form, bromodichloromethane,
and trichloroethylene (TCE).
TCE, in concentrations ex-
ceeding EPA's drinking water
standards, was also found in
at least 10 residential,
business, or church wells.
TCE is associated with birth
defects; some forms of it are
classified as possible or
probable human carcinogens.
Texas Water Commission and
EPA officials said that the
most likely source of the
contamination was a leaking
industrial drain. They cited
the cooperation of base
officials, who supplied bottled
water to affected residents.
EPA's order was issued under
the Resource Conservation
and Recovery Act (RCRA);
the Federal Facility
Compliance Act authorizes
the Agency to cite federal
facilities just as it would
private parties.
Booz-Allen and
Hamilton Fined
$1 Million for False
Time Sheets
The U.S. District Court,
Middle District of North
Carolina, has fined
Booz-Allen and Hamilton of
McLean, Virginia, $1 million
for submitting false time
sheets on EPA contracts. The
court has also ordered the
company to pay restitution of
$638,000. The company
cooperated with the
government in the
investigation and has entered
into a strict compliance
agreement with EPA. EPA
has agreed not to suspend or
debar the company provided
that it complies with the
agreement. The case was
investigated by EPA's Office
of Inspector General, which
alleged that employees of the
company submitted time
sheets showing work on EPA
contracts when, in fact, they
were attending to personal
business or to company
business unrelated to the
contracts. Booz-Allen and
Hamilton, Inc., is an
international management
and consulting firm whose
customers include many of
the largest industrial
corporations in the United
States and most departments
and agencies of the federal
government, a
OCTOBER-DECEMBER 1993
-------
Taking the True Measure
of Air Pollution
We have to look where the people are
by Kirk R. Smith
Concern about air pollution has
traditionally focused on the effects
on outdoor environments. We have
become accustomed to thinking of air
pollution in the context of such visual
symbols as the industrial smokestack
and the dark layer smothering modern
cities. In view of knowledge gained in
recent years, this focus on outdoor air
pollution and its sources has diverted
attention from our principal goal of
reducing the exposure of people to the
health-damaging pollutants they
actually breathe. These exposures can
be caused by relatively small localized
sources that are, literally, right under
our noses: cigarettes, spray cans, and
dry-cleaned clothes, for example. More
often than not, these exposures occur
indoors.
Although n number of adverse
effects on human welfare are
associated with outdoor air pollution,
including property damage and loss of
visibility, its impact on human health
has been the focus of most concern.
Primary standards for criteria
pollutants under the Clean Air Act in
the United States, as well as similar
standards in other nations, have been
established to avoid health damage.
Evidence includes the acute episodes in
London and in Donora, Pennsylvania;
epiderniological studies of long- and
short-term effects on different
populations; and laboratory
experiments with human volunteers.
The current pattern of monitoring and
regulation, however, may not directly
address the locations and types of
pollutants with the most damaging
health impact.
Present standards apply to outdoor
levels of pollution where
(Dr. Smith is Senior Fellow in //it' Program on
Environment of the East-West Center in Honolulu.
Hawaii.}
measurements are most easily made.
Most people, however, do not spend
much time outdoors, particularly in
temperate, developed countries. In the
United States, for example, only about
10 percent of the population's time is
spent outdoors. To measure the
pollutant concentrations to which most
people are exposed most of the time, it
is also necessary to monitor indoor
environments. A number of studies
show that indoor and outdoor
concentrations of most pollutants are
often significantly different and that
they do not correlate well with
concentrations at tine nearest outdoor
monitoring site.
The first ever air-pollution
monitoring network was located on the
tops of London fire stations during the
last century. Concentrations are still
most often measured on the roofs of
public buildings and at other locations
chosen by a range of criteria such as
convenience, security, geographic
spread, and general congruence with
population distribution. This placement
Harvard researcher
Mark Davey, right,
instructs a Part:cie
TFAM volunteer in
how to wear a
personal exposure
monaor. Particulate
matter in the
volunteer's
breathing zone will
be sampled during
normal activities
A 2-percent decrease in ETS
would be equivalent to eliminating
all the coal-fired power plants in
the countn/.
assumes that outdoor levels reasonably
indicate health-relevant exposures.
Such measurements, however, do not
truly represent individual or
population exposures to many
pollutants of interest. In some cases,
total exposure is less than that
indicated by outdoor measurements,
because there are few indoor sources:
for example, sulfur oxides. In other
cases, total exposure is actually more,
because there are significant indoor
sources: for example, nitrogen dioxide
from gas stoves.
The attention being given to indoor
air pollution in recent years indicates a
fundamental shift in environmental
health science: recognition of the need
Harvard School at Public Health phi
EPA JOURNAL
-------
In the United
States, people
spend only about
10 percent of their
time outdoors
for total exposure assessment (TEA).
The idea behind TEA is that if we are
to understand how a particular
pollutant affects humans and what the
most effective control measure would
be, it is necessary to account for all
routes of exposure. Put more bluntly,
to determine human exposure it is
necessary to measure the exposures of
humans directly. Studies of the
microenvironments within which
people spend time are needed. These
can be done by measuring pollutant
concentrations separately in each
microenvironment, then taking the
sum weighted by the amount of
Mike Sffsson photo
person-hours spent in each. Another
approach is personal exposure
monitoring, in which the air in the
breathing zone of individuals is
sampled during normal daily activities.
A range of portable devices and
techniques for both kinds of
monitoring has been developed.
TEA across all times and locations is
now a recognized way to conduct
health-effects studies of air pollution.
For many pollutants, small changes in
indoor conditions affect total exposures
more than do large differences in
outdoor concentrations, even
considering that indoor levels are
partly due to penetrations of pollution
from outside. Further, considering the
most significant sources on the basis of
exposure reveals that a quite different
set of sources is important. Many of
these sources, such as tobacco
smoking, gas stoves, and chemicals in
consumer products, occur indoors. On
the other hand, localized outdoor
sources may produce greater exposure
than outdoor monitoring instruments
would indicate because the instruments
are remote. Lead exposure of people
living near highways is an example.
The significance of looking where the
people are can be illustrated by studies
of recently targeted pollutants such as
those volatile organic chemicals that
are part of the category called "air
toxics." The Total Exposure
Assessment Methodology (TEAM)
studies discussed on pages 23-2-1
provide ample evidence that outdoor
measurements of these chemicals are
often inadequate for determining total
human exposures. This is also true for
some of the more traditional
pollutants, such as particulates and
nitrogen dioxide.
In a feasibility study of the
effectiveness of new nitrogen dioxide
emission controls on vehicles in
Chicago, for example, researchers
found that even large decreases in
average outdoor concentrations would
have minor impact on total daily
exposures. Peak concentrations along
highways would be little affected by
such controls. Also, daily average
outdoor exposures were much less
than the indoor exposures from gas
stoves. Although vehicle emission
controls could help Chicago meet
ambient outdoor-air pollution
standards, in this case they would not
appreciably decrease actual human
exposures to nitrogen dioxides. This is
true even though there are many more
tons per day of nitrogen dioxide
emitted from cars than from stoves.
A pound of pollution released
outdoors or in places where people do
not spend much time is substantially
less damaging to health than the same
amount released near people. Stringent
pollution controls, for example, are
applied to coal-fired power plants in
the United States, yet they collectively
still release about 500,000 tons of
particulates each year. Tobacco
smoking, which fortunately is
declining, now releases only about
OCTOBER-DECEMBER 1993
-------
20,000 tons each year. From a direct
participate emissions standpoint,
therefore, power plants are 25 times
more polluting than cigarettes. When
the comparison is based on human
exposure, however, the total exposure
from environmental tobacco smoke
(ETS), sometimes called passive
smoking, is 50 times higher. This
means that, from a particulate
exposure standpoint, a 2-percent
decrease in ETS would be equivalent to
eliminating all the coal-fired power
plants in the country.
Perhaps even more striking is that,
per pound released, ETS is more than
a thousand times (25 multiplied by 50)
more dangerous than the smoke from
power plants. This is not because of
any difference in their composition,
which here is assumed to be identical,
but simply because of the differences
in the place and time of release. The
power plant smoke is mostly released
from stacks high in the air and out of
town, or at least in parts of town
where few people live. ETS, on the
other hand, is largely released indoors
and often during human presence. Put
another way, per pound released, a
thousand times more ETS is actually
inhaled by people than is the smoke
from power plants. This difference is
their relative "exposure effectiveness,"
based on a comparison of how much of
what is emitted actually goes down
people's throats.
This one comparison alone, if
generally accepted, would have
tremendous implications for
air-pollution control strategy in the
nation. It implies, for example, that we
ought to be willing to pay a thousand
times as much to control emissions that
cause ETS as we are to control
power-plant smoke. But this is only
one example of how our present
system of air pollution regulation and
control tends to ignore the sometimes
large differences in exposure
effectiveness that can exist for the same
pollutant in different situations.
Some argue, however, that indoor
and outdoor exposures are
fundamentally different and should not
be so compared. Power plant smoke is
imposed on people without their
consent, the argument goes, and thus
Small changes indoors may affect total
exposure more than may large changes
outdoors.
warrants greater public concern than
indoor sources that people in some
way bring on themselves. This
argument, however, has at least two
major flaws.
First, it is only partly true that
people knowingly decide to bring
indoor exposures on themselves. How
many members of the public are able
to interpret the list of ingredients on a
can of household cleaner or pesticide
to decide how much exposure is
warranted for them or their families?
How are householders able to judge
what chemicals will be released from a
carpet or piece of furniture they buy?
What can members of a single
household do to determine what they
are being exposed to in the water
piped into their home?
The second flaw in this argument is
the hidden assumption that the
emissions from outdoor sources such
as chemical plants are somehow
different from those originating
indoors. If we are serious about
controlling benzene exposures for
health reasons, should not we view
each benzene molecule as our enemy
and work to stop as many as possible
from reaching people? What sense
does it make to propose spending
hundreds of millions controlling
stationary outdoor sources, which
cause relatively little human exposure,
while ignoring indoor sources that
cause much? Will the parents of a child
afflicted by benzene-triggered leukemia
be less upset if they are assured that
the benzene probably came from
indoor sources?
Another argument sometimes leveled
at efforts to bring indoor and other
total exposure considerations into
regulatory frameworks is that
stomehow this will result in an
infringement of individual rights—for
example, big government will place
electronic monitoring devices in every
home. This is ridiculous; total
exposures can be determined by
statistical sampling techniques
analogous to the way the Nielsen
ratings of television viewing habits are
done.
A variant on this Big Brother
argument is that regulating indoor
pollution will require the government
to impose its will on the individual
householder, meaning that pollution
fines, limits, and other controls would
be imposed on the "castle" that is each
householder's home. In fact, the
government already has ways to
control much inside the castles that are
our homes. Fuel quality is regulated by
the government, as is the performance
of stoves and other combustion
devices. Building and fire codes
already affect ventilation rates.
Household chemical products are
subject to regulation, some substances
being banned, for example. Termite
and other inspections are mandated in
most states. Taxes, public education,
and controls on advertisements have
had clear 'mpacts on tobacco
consumption. There would seem to be
little need to invent any other policy
tools to control indoor air pollution,
but rather to adjust the existing ones to
reflect total exposure.
In summary, to be sure that we are
protecting the most people possible
from ill health induced by air pollution,
we need to examine conditions where
the people are. This will entail finding
ways to take into consideration the
indoors in addition to our already
well-developed monitoring systems for
the outdoors, n
EPA JOURNAL
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An Inside
Look at
Air Pollution
by Ken Sexton
Complicated
public policy issues are at stake
iarty iefever photo Grant He/lman
On particularly smoggy days, small children and people
with respiratory illness are encouraged to stay indoors to
avoid health risks from air pollution. While this may be good
advice if the goal is to reduce exposures to, let's say, ozone,
there is substantial evidence that concentrations of many
airborne pollutants are often higher inside buildings and
vehicles than outside. It is becoming increasingly apparent
that being indoors, as, for example, in a residence, office, or
automobile, can offer protection from exposure to some
airborne agents, while at the same time increasing exposure
to others.
Concerns about the healthfulness of indoor air are driven
by six major factors. First, it is now widely recognized that
most people spend more than 90 percent of their time
indoors. Groups potentially more susceptible to the effects
of air pollution, like infants, the infirm, and the elderly, are
inside virtually all the time. Because most of us spend so
much time inside, indoor pollution concentrations, even if
they are uniformly lower than outdoor levels, make a
significant contribution to our average
exposure over a day, week, season, or
year.
Second, modern indoor
environments contain a complex array
of potential sources of air pollution,
including synthetic building materials,
consumer products, and dust mites.
Airborne emissions also occur because
of the people, pets, and plants that
inhabit these spaces. Efforts to lower
energy costs by reducing ventilation
rates have increased the likelihood that
pollutants generated indoors will
accumulate.
Third, monitoring studies inside
buildings and vehicles have
consistently found that concentrations
of many air pollutants tend to be
higher indoors than out. Indoor ait has
been shown to be a complex mixture of
chemical, biological, and physical
agents, only a small fraction of which
has been characterized adequately.
This complexity is illustrated by the
fact that more than 4,000 different
compounds have been identified in
tobacco smoke alone.
Fourth, scientific reports indicate that
indoor measurements are often better
than outdoor measurements for
classifying, estimating, and predicting
human exposures to many air
pollutants. This is true even for some
agents that are primarily of outdoor
origin. A promising approach to more
realistic exposure estimation is the
development and refinement of models
Indoor environments
contain a complex
array of air pollution
sources, including
pets and household
furnishings
(Dr. Sexlon is Director
of EPA's Office of Health
Research and matrix
manager of the indoor air
research program. He
was prn'iousli/ director
of California's Indoor Air
Research Program. The
views expressed are
those of the author
and do not necessarily
reflect the views and
policies of EPA.)
that combine information about
pollutant concentrations in both indoor
and outdoor settings with data on
time-activity patterns.
Fifth among the factors driving
indoor air concerns, complaints about
OCTOBER-DECEMBER 1993
-------
In public places, the
rationale for
government regulation
of indoor air is similar
to that for outdoor air.
inadequate indoor air quality and
associated discomfort and illness are a
burgeoning problem in our society.
Reports of illness outbreaks among
building occupants, particularly office
workers, with no secondary spread of
the illness to others outside the
building with whom affected
individuals come into contact, have
become commonplace. EPA classifies
these reports into two general
categories. Building-related illness
refers to episodes when symptoms of
diagnosable illness are identified and
can be attributed directly to airborne
contaminants in the building. In
contrast, sick-building syndrome is
defined as situations in which building
occupants experience acute health and
comfort effects that appear to be linked
to time spent in the building, but no
specific illness or cause can be
identified.
The so-called chemical sensitivity
syndromes, which may be caused only
partially or not at all by chemicals, are
a different, although potentially related
matter. Broadly defined, "multiple
chemical sensitivity" (MCS) is
postulated to be development of
responsiveness, including
manifestation of often disabling
symptoms, to extremely low
concentrations of chemicals following
sensiti/ation. A controversial and
emotional topic, the concept of MCS as
a distinct entity caused by exposure to
chemicals has been challenged by the
medical and scientific communities,
10
Monitoring studies inside buildings
and vehicles have consistently
found that concentrations of many
air pollutants tend to be higher
indoors than out.
and there appears to be consensus that
substantially more study is needed
before MCS should be considered as a
clinical diagnosis. Nevertheless, many
sufferers of MCS continue to believe
that their conditions are either caused
or exacerbated by indoor air pollution.
And sixth, exposures to many indoor
air pollutants are known or suspected
to occur at levels sufficient to cause
illness or injury. Scientific evidence
suggests that respiratory disease,
allergy, mucous membrane irritation,
nervous system effects, cardiovascular
effects, reproductive effects, and lung
cancer may be linked to exposures to
indoor air pollutants.
Scientists consistently rank indoor air
pollution at or near the top of
environmental health risks in the
United States. EPA reports on
risk-based priority setting, like
Unfinished Business (1987), Reducing Risk
(1990), and the Regional Comparative
Risk Protects (1989-92), all ranked indoor
air pollution as a high-priority risk to
human health. Public opinion polls,
however, continue to find that most
Americans do not perceive the risks of
indoor air pollution to be great.
Mike Bnsson photo
The specter of potential public health
risks from contaminated indoor air
presents decision makers with a
dilemma. Is the problem serious
enough to warrant intervention, and, if
so, what preventive or remedial actions
are most appropriate?
The significance of indoor air
exposures for acute and chronic health
effects remains uncertain in most cases.
Nevertheless, there is ample reason for
concern and caution. For example, it
has been estimated that exposures of
nonsmokers to ETS may cause as many
as 3,000 lung cancer deaths annually in
the United States, as well as contribute
to a wide range of noncancer diseases,
including pneumonia, bronchitis, and
asthma. Findings from several studies
suggest that indoor concentrations of
nitrogen dioxide, carbon monoxide,
and respirable particles can exceed the
Often present but
unseen in offices
and residences,
cockroaches and
their feces can be a
source of allergens.
EPA JOURNAL
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National Ambient (Outdoor) Air
Quality Standards set by EPA to
protect public health. And results from
many studies show that a plethora of
volatile organic chemicals and
pesticides known to be toxic and/or
carcinogenic can occur indoors at
concentrations significantly higher than
levels that create concerns in outdoor
air.
Designing effective and efficient
indoor control strategies requires an
understanding of several pertinent
factors. Contaminant characteristics
need to be considered, including
factors like concentration, reactivity,
and physical state. Emission source
configurations (e.g., area or point
sources) must be taken into account,
and it is necessary to determine
whether discharges are continuous or
intermittent. It is also important to
understand the dose-response
relationship for the contaminant of
interest so that informed decisions can
be made whether individuals are to be
protected from short-term exposures to
peak concentrations or from long-term
exposures to relatively low
concentrations. And, of course, the
type of indoor enclosure (e.g.,
residence, office, car) has ramifications
for which approaches and methods are
viable options.
But providing and maintaining
healthful indoor air quality is more
than just a complex scientific and
technical issue. Realization that
contaminated indoor air may pose an
unacceptable health hazard raises
complicated policy questions about the
proper role of government in
safeguarding people's health inside
public and private spaces.
Because concerns about adverse
health consequences from air pollution
have focused traditionally on outdoor
and occupational exposures, federal
Key Questions About Indoor Air Pollution
Answers to the following key questions
are critical to improving our
understanding of the relative risks
associated with indoor air pollution;
whether these risks are unacceptable;
and what to do about those that are.
Problem Definition: Is there an existing
or potential indoor air problem that
may have public health significance?
• What are the key health effects
associated with indoor air pollution,
and what pollutants and mixtures
cause these effects?
• What are the key pollutant sources,
exposure scenarios, and building
practices that influence indoor
exposures?
• How do indoor air quality
complaints/problems relate to other
indoor environmental factors, e.g.,
thermal comfort, odor, lighting, noise?
• How does the perception of indoor
air quality affect worker productivity?
Absenteeism? Health care costs?
Risk Assessment: If indoor air poses
serious risks to human health, what
are the likelihood and magnitude of
those risks?
• What are typical and high-end
indoor exposures, and how do these
exposures relate to indoor pollutant
levels?
• What are the most severe human
health effects associated with
exposures to indoor pollutants and
pollutant mixtures?
• How do the relative risks of a
particular indoor pollutant or pollutant
mixture compare with: other indoor air
problems? outdoor air problems?
environmental hazards in other media?
Risk Management: If the associated
human health risks are deemed
unacceptable, what are the most
effective approaches to
preventing/reducing these risks?
• How can indoor pollutant sources
be eliminated or modified to prevent
indoor air pollution?
• What are the most cost-effective
ways to design, construct, operate, and
maintain buildings to optimize indoor
air quality and energy efficiency?
• When steps are taken to prevent or
reduce risks, how effective and durable
are they?
and state government programs
concentrate on protecting public health
from outdoor air pollutants or
protecting workers' health from
dangerous air pollutants in the
industrial workplace. As mentioned
earlier, EPA sets and enforces National
Ambient Air Quality Standards that are
designed to protect the general public
to within an adequate margin of safety.
The Occupational Safety and Health
Administration enforces consensus
standards for industrial work
environments, which are designed
such that no employee will suffer
material impairment of health or
functional capacity. However, federal
responsibility and authority for indoor
air quality in the nonworkplace are less
well defined.
There is ample precedent for
government authority and
responsibility to protect public health
and welfare inside buildings. It is
common practice, for instance, to
regulate construction and operation of
public buildings to ensure that
adequate provisions are made for
health and safety. Government
inspectors routinely enforce building
codes, health regulations, safety rules,
and fire ordinances. While government
has an obligation to protect public
health in indoor as uell as outdoor
environments, the justification for
direct government intervention varies
according to the characteristics
associated with different types of
indoor settings.
Creation of a regulatory framework
for protecting indoor environmental
quality poses special policy issues.
Promulgation of indoor air quality
standards and other regulations must
acknowledge that individuals,
especially in private residences, are
already making decisions about their
own air quality. Development of
effective and reasonable policy requires
an appreciation of the scope for private
action, as well as consideration of the
likelihood that public intervention will
foster improved private choices.
This is not to suggest that rules and
regulations have no part to play in
safeguarding indoor air quality. This
form of intervention is, however, not
necessarily optimal or even desirable in
certain types of indoor environments.
There are, of course, many different
types of indoor environments—for
example, occupational settings, both
industrial and nonindustrial;
OCTOBER-DECEMBER 1993
11
-------
nonoccupational settings, including
residential, commercial, institutional,
and public; and transportation
microenvironments, such as
automobiles, airplanes, subways, and
trains.
The role of government varies
according to the "publicness" of a
particular space as well as the nature of
air-pollution health risks, either
voluntary or nonvoluntary.
Understanding the diversity of
nonindustrial indoor environments is
an important step in the design and
implementation of practical and
cost-effective control strategies.
The rationale for government
regulation of outdoor air pollution is
based in part on a definition of outdoor
air as a "public good" and on the
realization that those who suffer the
effects of such pollution are neither
compensated by, nor powerful in
influencing, polluters. The situation is
quite different for some indoor
environments, especially private
residences, for both the costs and
benefits of pollution control are
internalized with households.
If occupants foul the air in their
home, they are forced to breathe it. If
they attempt to improve its quality by
increasing ventilation or installing
air-cJeaning devices, they bear the costs
and enjoy the benefits. For some
contaminants, such as tobacco smoke,
odorants, and water vapor, benefits are
readily recognizable through
improvements in perceptible air quality
and reduction of corrosion, soiling, and
molds.
The closed-loop, cost-benefit cycle
within residences suggests that
individual decisions are important
determinants of indoor air quality.
However, unlike residential energy
consumption, where monthly bills
from the local utility company provide
periodic feedback to consumers, indoor
contaminants may be below irritation
or odor thresholds. Thus, although
individuals are certainly making
decisions about their own air quality, it
is not clear that these are "informed"
decisions. Government actions aimed
at improving personal decisions about
indoor air quality may be preferable to
rules and regulations (e.g., simple
warning devices, product labeling, or
information programs).
It has been suggested that the Clean
Air Act be amended to give EPA
authority to control indoor air pollution
Biological pollutants, such as pollen, are a major
cause of health complaints and illnesses
in much the same way that outdoor air
pollution is currently controlled.
However, setting and enforcing strict
indoor air quality standards, similar to
existing National Ambient Air Quality
Standards, would be impractical
because of the prohibitive monitoring
costs and the difficulty of enforcement
within approximately 82 million
residences in the United States.
Perhaps the most serious
impediment to implementing a
regulatory approach is public antipathy
towards this form of intervention
inside the home. Restriction of indoor
pollution sources, certification of "safe"
indoor concentrations, product
emission standards, disclosure of
potential sources upon transfer of
ownership, and specification of
minimum ventilation requirements are
examples of government actions that
are likely to be less costly and more
effective than indoor air quality
standards.
Not all buildings are residences, and
not all residences are owner-occupied.
The rationale for direct government
intervention aimed at improving indoor
air quality is much stronger in public,
as opposed to private buildings. Air
quality in large public buildings, for
instance, displays many characteristics
of a public gooci. A person sensitive to
tobacco smoke would not rationally
pay the costs of cleaning the air in a
large convention hall. The costs would
greatly exceed any personal benefits an
individual might derive from
smoke-free air, and those who did not
contribute could not be excluded from
enjoying the benefits. In this situation,
the rationale for regulation is similar to
that for outdoor air pollution.
There is also substantial justification
for regulatory intervention in private
and public buildings where occupants
do not have control over their own
environment—-for example, modern
high-rise office buildings. Typically,
building managers are responsible for
operation and maintenance of heating,
ventilation, and air-conditioning
(HVAC) systems. Occupants of the
building, including both employers and
employees, often have little or no
direct control of temperature, fresh air
input, and ventilation rate. Because
HVAC systems are normally operated
to minimize energy costs, the health
and comfort of tenants rarely become
an issue unless a significant number of
complaints are reported.
Because health risks in this situation
tend to be nonvoluntary, government
may have a responsibility to safeguard
public health by defining what
constitutes acceptable indoor air and
taking steps to ensure that those
criteria are met. Examples of
government actions that might be
warranted include specification of
minimum ventilation rates necessary to
achieve healthful indoor air quality,
establishment of emission limitations
for building materials, and
development of indoor air quality
guidelines or standards for important
contaminants.
As a practical matter, however,
development of a comprehensive
federal approach to address problems
of indoor air pollution awaits
resolution of important public policy
and public health questions about the
proper role of government in
safeguarding the air quality inside
public and private spaces, n
12
EPA JOURNAL
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Indoor Allergens:
A Report
Wall-to-wall carpeting is a good reservoir
by Andrew M. Pope
One of five Americans will
experience allergy-related illness at
some point during their lives, and
indoor allergens will be responsible for
a substantial number of those cases,
according to a recent report from the
Institute of Medicine, Indoor Allergens:
Assessing and Controlling Adverse Health
Effects.
The report describes allergy,
generally speaking, as "the state of
immune hypersensitivity that exists in
an individual who has been exposed to
an allergen and has responded with an
overproduction of certain immune
system components such as
immunoglobulin E (IgE) antibodies.
About 40 percent of the population
have IgE antibodies against
environmental allergens, 20 percent
have clinical allergic disease, and 10
percent have significant or severe
allergic disease."
The report lists major sources of
indoor allergens in the United States as
house dust mites, fungi and other
microorganisms, domestic pets (usually
cats and dogs), and cockroaches. The
most common allergic diseases related
to these allergens are allergic rhinitis,
asthma, and allergic skin diseases.
Allergy plays a key but sometimes
unrecognized role in triggering asthma,
a disease that deserves special
attention because of its prevalence,
cost, and potential severity. In 1988,
4,580 people died of asthma in the
United States, and the mortality rate is
rising, particularly in blacks.
Depending on age, blacks are three to
five times more likely than whites to
die from asthma. In 1987 (the most
recent available data), asthma was the
first-listed diagnosis for more than
(Dr. Pope is Study Director, Division of Health
Promotion and Disease Prevention, Institute of
Medicine. Indoor Allergens is the iwrk of n
mullidisciplinary committee on the Health Effects of
Indoor Allergens (Roy Patterson, M.D.. Chair, and
Harriet Burge, Ph.D., Vice-Chair). The report is
available from the National Academy Press: call
202/334-3373 or 800/624-6242.)
OCTOBER-DECEMBER 1993
Initial exposure
Repeated exposure
No allergic symptoms
No or Mild allergic symptoms
Overt allergic symptoms
Source: Fireman & Slavm. 1991
450,000 hospitalizations in the United
States.
Allergy to house dust mites and cats
increases the risk of childhood asthma
fourfold to sixfold. In addition, indoor
allergens are thought to be responsible
for much of the acute asthma in adults
under the age of 50 years.
The total annual cost associated with
asthma in the United States has been
estimated at more than $6.2 billion.
This estimate includes direct and
indirect costs and is a 30-percent
increase over the estimated cost of the
disease in 1985.
For most allergenic agents, exposure
clearly creates a risk of allergic
sensitization, but insufficient data are
available to identify thresholds or risk
levels. The report indicates, however,
that a positive relationship has been
found between cumulative exposure to
dust mite allergen and the risk of
sensitization. This finding has long
been suspected, but never
demonstrated.
Avoiding specific allergens can
lessen the probability of initial
sensitization and can improve
dramatically the condition of people
with a known sensitivity by reducing
the cascade of symptoms that result
from exposure. Because of the amount
of time people spend sleeping, the
bedroom is one area where steps to
reduce exposure to allergens can be
especially beneficial. For example,
covering mattresses and pillows with
impermeable materials is an effective
way to limit exposure to dust mite
allergens.
Wall-to-wall carpeting in homes,
schools, hospitals, and offices is a good
reservoir for both dust mite and mold
allergens if the premises are damp;
vacuum cleaning is probably not an
effective intervention. In fact, vacuum
cleaning disperses and suspends
allergens and other particles in the air.
(Removing carpet might work bettor in
such circumstances.)
A thorough understanding of how
building systems and structures
operate and perform is essential tor
assessing and controlling indoor air
quality problems. The reduction and/or
elimination of human exposure is
probably best achieved by
simultaneously controlling allergen
sources and improving building
ventilation—that is, the design,
operation, and maintenance of heating,
ventilation, and air-conditioning
systems, o
13
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Improving IAQ:
ERA'S Program
Pollution prevention must become routine
by Bob Axelrad
Secause of the possibility of serious
impacts on the health of individuals
who may experience indoor air-quality
problems—as well as the dollar costs to
society if indoor air pollution is not
addressed—EPA has developed a
comprehensive program to better
understand the problem and to take
decisive steps to reduce people's
exposures to indoor air contaminants
of all types. The program is predicated
on three primary principles.
First, even in the absence of
complete scientific understanding of
indoor air pollution, prudent public
policy dictates that reasonable efforts
be undertaken to reduce peoples
exposure to potentially harmful levels
of indoor air pollutants, using the
authorities available to the federal
government under current laws.
Second, pollution prevention—and
efficient resolution of indoor air-quality
problems of all types—must become a
routine aspect of the design,
construction, maintenance, and
operation of public and commercial
buildings, homes, health and day care
facilities, educational institutions, and
other special-use buildings.
Third, an effective research and
development program must be
conducted to achieve a more complete
understanding of the factors affecting
indoor air quality. Through this
(Axelrad is Director of EPA's Indoor Air Division.)
14
program, we also need to acquire a
better understanding of exposure
patterns, health effects, and control
techniques for improving indoor air
quality.
EPA is working to implement these
principles using non-regulatory as well
as regulatory tools available under a
number of federal laws to provide
information and incentives for action to
product manufacturers, architects,
engineers, builders, building owners
and managers, and building occupants.
The primary objectives of EPA's
program are to:
» Establish effective partnerships with
organizations representing the range of
target audiences to communicate
specific guidance and information and
promote timely action on indoor air
quality issues
• Forge constructive alliances with
other federal agencies to leverage
resources and ensure that existing
statutory authorities are used most
effectively
• Develop practical guidance on
indoor air quality issues using a
broad-based consensus approach which
includes representatives from industry
and public interest groups to ensure
that information provided is accurate
and practical
• Design market-based incentives for
industries to lower chemical emissions
from their products and provide
consumers and other decision makers
with information needed to make
informed purchasing decisions
• Sharpen the focus of the chemical
screening and risk management
program under the Toxic Substances
Control Act (TSCA) and the Federal
Insecticide, Fungicide, and Rodenticide
Act (FIFRA) to ensure that chemicals
that pose unreasonable risks indoors
are identified and addressed
• Identify and fill research gaps in
order to address outstanding policy
issues concerning indoor air quality
• Select appropriate environmental
indicators to measure progress in
reducing population exposure to
indoor air-quality problems as the
program matures
• Bring about substantial reductions
in human exposure to the entire range
of indoor air pollutants.
Reducing Pollutant Levels
Indoors
The Building System Approach
EPA has set a high priority on
improving the way buildings are
designed and operated, having
concluded that people's exposure to
indoor air pollutants can be reduced
significantly by implementing current
knowledge about sound building
operation and maintenance practices.
Some of the major actions to date
include:
• Issuance, in cooperation with the
National Institute for Occupational
Safety and Health, of comprehensive
guidance, entitled Building Air Quality:
A Guide for Building Owners and Facility
Managers, on how to prevent and
resolve the full range of indoor
air-quality problems in public and
commercial buildings
• Publication of The Inside Story: A
Guide to Indoor Air Quality to help
people identify and correct potential
indoor air-quality problems in their
own homes.
In addition, EPA is developing
guidance for school facility managers,
new home buyers, and architects and
design engineers to acquaint them with
the most current information on how
to prevent indoor air-quality problems
from occurring or resolve them quickly
if they do occur.
EPA JOURNAL
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People's exposure to indoor air pollutants can he
reduced significantly by implementing current
knowledge about sound building operation and
maintenance practices.
The Pollutant-Specific Approach
The emphasis on a buildings approach
holds the most promise for addressing
all of the factors—including those
related to the ventilation system as
well as sources of individual
pollutants—that affect indoor air
quality. However, the Agency also
strongly believes that it must
aggressively utilize its combined
statutory authorities to identify specific
pollutants that present direct health
risks in the indoor environment, and to
use a variety of means to reduce their
levels indoors. The indoor air
pollutants that are currently receiving
significant Agency attention include:
Bird droppings have
collected near this
unprotected air intake.
Many indoor air quality
problems can be avoided
through sound building
operation practices.
Berns & Kay
Radon. The Indoor Radon Abatement
Act of 1988 directs EPA's
non-regulatory radon program to work
with states to reduce radon risks
through voluntary action and to serve
as the federal lead agency on radon
policy. This approach encompasses a
range of activities which include:
developing and distributing public
information and education materials;
supporting industry proficiency
programs; providing financial and
technical assistance to states;
developing and encouraging adoption
of radon-resistant building practices;
establishing training centers; and
conducting mitigation research in
different building types.
Environmental Tobacco Smoke. EPA has
completed a major report on the
respiratory health effects associated
with environmental tobacco smoke.
The report, entitled Respiratory Health
Effects of Passive Smoking: Lung Cancer
and Other Disorder*, concludes that each
year secondhand smoke is responsible
for about 3,000 lung-cancer deaths in
non-smokers and causes respiratory
health problems for hundreds of
thousands of young children. As the
first step in its education and outreach
program to inform the public about the
risks of passive smoking, EPA has
published a brochure advising parents,
decision makers, and building
occupants of actions they can take to
OCTOBER-DECEMBER 1993
15
-------
Young children are at particular risk because they are
more likely to swallow lead dust and because the
impact on their developing nervous systems is more
severe.
prevent involuntary exposure to ETS in
indoor environments.
Toxic Substances. TSCA grants EPA
broad authority to control chemical
substances and mixtures that present
an unreasonable risk of injury to health
and the environment. EPA has
authority to require testing of chemical
substances and mixtures; regulate
hazardous chemical substances and
mixtures by prohibiting or restricting
their manufacture, processing,
distribution, and disposal; review new
chemicals and their intended uses; and
impose labeling or notification
requirements. TSCA has been used to
regulate asbestos. In addition to using
TSCA to regulate individual chemicals,
the Agency is now evaluating groups
of chemicals in selected use categories
for their effect on people in indoor
environments.
Asbestos. Under the Asbestos Hazard
Emergency Response Act, passed in
1986, EPA established a regulatory
framework for addressing the
management or abatement of asbestos
in schools. As mandated by the
Asbestos School Hazard Abatement
Reauthorization Act of 1990, the
standards that the Agency established
for state accreditation of school
personnel are currently being revised
to include certain workers in public
and commercial buildings and to
increase the minimum number of
training hours required. EPA continues
to be involved in a range of outreach,
grant, and technical assistance activities
as well. This past year, EPA offered
$5.7 million in grants and $70.5 million
in interest-free loans for abatement
16
projects in 156 school districts across
the nation.
Lead. Exposure to dust from lead-based
paint can pose a serious health threat
in homes or apartments built before
1978—the year residential use of
lead-based paint was banned by the
Consumer Product Safety Commission.
Young children are at particular risk
because they are more likely to
swallow lead dust and because the
impact on their developing nervous
systems is more severe. EPA, along
with other federal agencies, is working
to develop a comprehensive strategy to
address lead exposures indoors and to
develop effective procedures for lead
testing and abatement procedures
through implementation of the
Residential Lead-Based Paint Hazard
Reduction Act of 1992.
Formaldehyde. EPA is implementing a
project, focused on newly constructed
housing, to test exposure to
formaldehyde in indoor air. This
undertaking is part of an investigation
being conducted under TSCA. It will
provide data that the Agency will use
to determine if there is a need to
reduce permissible formaldehyde
emissions from interior pressed-wood
building materials, such as
particleboard flooring and wall
paneling, and from related products,
including cabinets and furniture.
Carpet. EPA, along with other federal
agencies, the carpet industry, and
others, has been investigating the role
that carpet plays in indoor air quality.
While some people report symptoms
which they associate with new carpet,
the cause remains elusive. The carpet
industry has initiated a major research
and information program—including a
new carpet consumer-information
label—to improve understanding of the
relationship between carpet and indoor
air quality.
Pesticides. FIFRA authorizes EPA to
control pesticide exposures by
requiring that any pesticide be
registered with the Agency before it
may be sold, distributed, or used in
this country. EPA is evaluating the
health impacts of indoor products
including insecticide sprays,
termiticides, and wood preservatives.
Major accomplishments include the
withdrawal from the market of
chlordane as a termiticide in homes
and mercury used as a rnildewcide in
many indoor paints. This past year
EPA distributed to school districts
across the nation brochures
encouraging pesticide use reduction
and alternative pest-control methods
through Integrated Pest
Management.
Indoor Air Pollutants from Drinking
Water. The Safe Drinking Water Act
authorizes EPA to set and enforce
standards for contaminants in public
water systems to protect against both
health and welfare effects. Besides
setting standards for contaminants in
drinking water, EPA sets standards for
volatile organic compounds (VOCs)
that can enter the air through
volatilization from water used in a
residence or other building. Many
VOCs have already been regulated.
EPA is also currently developing a
standard for radon in drinking water.
EPA JOURNAL
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Increasing Access to Indoor
Air Information
Information Dissemination
In addition to publishing a wide range
of information materials on indoor air
quality, EPA is also developing
additional strategies for disseminating
information to key audiences. To
ensure that a full range of information
about indoor air-quality problems and
solutions is readily available to both
the technical and nontechnical public,
EPA's Indoor Air Quality Information
Clearinghouse (IAQ INFO) began
operation in fall 1992. The
Clearinghouse is equipped with
toll-free, operator-assisted telephone
access and provides written
information including fact sheets and
brochures, performs literature searches,
and makes referrals to appropriate
federal, state, and regional resources.
IAQ INFO answered 17,000 telephone
requests for information and mailed
out over 130,000 publications last year.
Training Key Audiences. Because concern
about indoor air problems is a
relatively recent phenomenon, many of
the people who are in the best position
to prevent problems or resolve them
when they do occur are not sufficiently
informed about the issue.
Many indoor air-quality problems
can be avoided through sound
building-operation practices, or
resolved by knowledgeable building
personnel without the need for
potentially costly outside assistance.
EPA has developed a training course
for building owners and managers to
acquaint them with the guidance
contained in Building Air Quality: A
Guide for Building Owners and Facility
Managers (December 1991). Because
many indoor air-quality problems are
best resolved by responsible
government agencies at the state and
local level, EPA has developed both a
live instructional course on indoor
air-quality issues, entitled Orientation to
Indoor Air Quality, and a self-paced
learning module entitled Introduction to
Indoor Air Quality (April 1991) for these
audiences.
Forging Cooperative Partnerships. Many
groups share EPA's interest in indoor
air quality. EPA is working with
numerous public and private sector
groups to leverage our resources and
to transfer information to target
audiences who can implement our
policies and take action to improve
indoor air. Some examples include the
American Lung Association, the
Building Owners and Managers
Association International, the
International Union of Operating
Engineers, and the Consumer
Federation of America.
Advancing the Science of Indoor Air
Quality. EPA is conducting studies to
assess indoor air conditions in the
nation's existing building stock. Special
emphasis is being given to identifying
those factors that exert the greatest
influence on overall indoor air quality
(IAQ). The information gained will be
used to improve IAQ diagnostic
procedures as well as to provide a
basis for evaluating the effectiveness of
our pollution-reduction strategies over
time. Another set of studies now
underway is designed to quantify the
costs of key options for controlling
indoor-air pollution in typical building
structures.
EPA's Office of Research and
Development conducts a
multi-disciplinary research program
which encompasses studies of the
health effects associated with indoor-air
pollution; assessments of indoor air
pollution sources and control
approaches; building studies and
investigation methods; risk
assessments of indoor air pollutants;
and a recently initiated program on
biocontaminants.
Working with Other Federal
Agencies
More than 20 different federal agencies
have responsibilities associated with
indoor air quality, either through their
own statutory responsibilities or
because they are major property
managers. The activities of these
agencies are coordinated through a
variety of mechanisms, including an
interagency Committee on Indoor Air
Quality (CIAQ) which meets on a
quarterly basis to exchange information
on indoor air issues. Five federal
agencies—EPA, the Consumer Product
Safety Commission, the Department of
Energy, the National Institute for
Occupational Safety and Health, and
the Occupational Safety and Health
Administration—are CIAQ co-chair
agencies. In addition, EPA works
closely with other agencies on
regulatory and information-
development efforts and jointly
sponsors many of its guidance and
public information documents with
these other agencies to help ensure
that federal actions are
well-coordinated, a
MIND IF
I BLOW
ASBESTOS
DUST IN
YOUR FACE?
MIND
IF I
SMOKE?
PASSlVf
SMOKE:
CLASS A
Steve Kelley cattoon. Reprmted wrth permission of Copley News Service
OCTOBER-DECEMBER 1993
-------
Environmental Tobacco Smoke:
EPA's Report
by Carol M. Browner
ETS is classified as a known human carcinogen
Environmental tobacco smoke (ETS),
also termed secondhand smoke,
harms the health of thousands of
Americans each year. ETS is a mixture
of the smoke given off by the burning
end of cigarettes, pipes, or cigars, and
the smoke exhaled from the lungs of
smokers. This mixture contains over
4,000 substances. More than 40 of
these are known to cause cancer in
hurnans and animals, and many are
strong respiratory irritants.
Exposure to secondhand smoke,
called involuntary smoking or passive
smoking, is concentrated indoors,
where ETS is often the most significant
pollutant. Indoor levels of the particles
you may inhale (the "tars" in the
cigarettes) from ETS often exceed the
national air quality standard
established by EPA for outdoor air.
The high levels of carbon monoxide in
secondhand smoke also warrant
concern.
Drawing by Richter. Copynght 1993 The New Yorker Maga/*nc>. Inc
(Browner it Administrator of I'.l'A.)
In January 1993, EPA released an
assessment of the health risks of
passive smoking in a report entitled
Respiratory Health Effects of Passive
Smoking: Lung Cancer ami Other
Disorders. The report summarizes the
findings of an extensive investigation
conducted by the Agency. It
incorporates comments from two open
public reviews and recommendations
from EPA's Science Advisory Board—a
panel of independent scientific experts
in this field. The board endorsed the
conclusions of the report and the
methodologies used. In particular, the
board unanimously endorsed the
report's classification of ETS as a
human lung carcinogen.
Based on the overall weight of
available scientific evidence, EPA
concluded that widespread exposure to
secondhand smoke in the United States
presents a serious and substantial
public health risk.
Secondhand smoke is responsible for
approximately 3,000 lung cancer deaths
annually in nonsmokers in the United
States. ETS is classified as a known
human, or Group A, carcinogen under
EPA's carcinogen assessment
guidelines. This classification is
reserved for those compounds or
mixtures that show the strongest
evidence of a cause-and-effect
relationship in humans. Other agents
classified by EPA as Group A
carcinogens include radon, asbestos,
and benzene, to name a few. Of these,
ETS is the only one found to cause
elevated cancer risks at commonly
found indoor levels.
The report also includes the finding
that secondhand smoke has subtle but
significant other effects on the
respiratory health of adult nonsmokers.
EPA JOURNAL
-------
These include coughing, phlegm
production, chest discomfort, and
reduced lung function.
Infants and young children whose
parents smoke are among the most
seriously affected by exposure to
secondhand smoke. They experience
an increased risk of lower respiratory
tract infections such as pneumonia and
bronchitis. EPA estimates that passive
smoking is responsible for between
150,000 and 300,000 lower respiratory
tract infections in infants and children
under 18 months of age annually,
resulting in between 7,500 and 15,000
hospitalizations each year. Children
who have been exposed to secondhand
smoke are also more likely to have
reduced lung function and symptoms
of respiratory irritation such as cough,
excess phlegm, and wheezing. Passive
smoking can lead to a buildup of fluid
in the middle ear, the single most
common cause of hospitalization of
children for an operation.
Asthmatic children are especially at
risk. EPA estimates that exposure to
secondhand smoke increases the
number of episodes and the severity of
symptoms for between 200,000 and one
million asthmatic children. Passive
smoking is also a risk factor
contributing to the development of
new asthma cases in thousands of
children each year.
EPA firmly believes that the scientific
evidence is sufficient to warrant actions
to protect nonsmokers from
involuntary exposure to secondhand
smoke. Accordingly, we are conducting
a public outreach program to
communicate the findings of the report
to the public.
In July, the Agency published a
brochure, What You Can Do About
Secondhand Smoke, which specifies
actions that parents, decision makers,
and building occupants can take to
protect nonsmokers, including
children, from indoor exposure to
secondhand smoke. The brochure also
contains a special message for smokers
about how they can help protect
people around them. Copies of the
publication may be obtained by calling
EPA's Indoor Air Quality Information
Clearinghouse at 800-438-4318.
What kinds of actions are being
advised? The following steps can help
curb ETS exposure in the home, at
child-care centers and schools, in the
workplace, and in restaurants and bars:
• Don't smoke in your home or
permit others to do so. If a family
member smokes indoors, we
recommend increasing ventilation in
the area by opening windows or using
exhaust fans. We also recommend that
smoking should not occur if children
are present, particularly infants and
toddlers. Baby-sitters and others who
work in the home should not be
allowed to smoke indoors or near
children.
• Every organization dealing with
children— schools, day-care facilities,
and other places where children spend
time—should have a smoking policy
that protects children from exposure to
ETS.
• Every company should have a
smoking policy that protects
nonsmokers from involuntary exposure
to tobacco smoke. Many businesses
and organizations already have policies
in place and more and more are
instituting them, but these policies
vary in their effectiveness. Simply
separating smokers and nonsmokers
within the same area, such as a
cafeteria, will still expose nonsmokers
to recirculated smoke and to smoke
drifting in from smoking areas.
Instead, companies should either
prohibit smoking indoors or limit
smoking to rooms that have been
specially designed to prevent smoke
from escaping to other areas of the
building.
Video on ETS and Children
A 12-minute video entitled Poisoning
Your Children: The Perils of Secondhand
Smoke is available from the American
Academy of Otolaryngology (the
specialty of ear, nose, and throat
medicine). The film features Surgeon
General Jocelyn Elders voicing her
concern about this health hazard.
EPA's report on passive smoking is
also discussed as well as the type of
injury passive smoking can cause to
infants and children. For ordering
information, please call 703-519-1528.
• If smoking is permitted in a
restaurant or bar, smoking areas
should be located in well-ventilated
areas so nonsmoker will face less
exposure. More and more restaurants
and restaurant chains are prohibiting
smoking in their facilities, and cities
and counties across the United States
are restricting smoking in restaurants
within their jurisdictions.
EPA will he publishing guidance to
help organizations establish smoking
policies in indoor environments.
Providing our children and the public
with a smoke-free environment must
be a national priority. i-J
Steve Deianey photo
Spraying tobacco.
Secondhand smoke
contains over 4,000
substances; more
than 40 are known
human carcinogens
OCTOBER-DECEMBER 1993
19
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Sethann& Peterson p>
Environmental
Tobacco
Smoke:
Industry's Suit
Charges focus on epidemiology studies
_ by Steven Bayard and Jennifer Jinot
In June 1993, the tobacco industry
filed suit in the Middle District Court
of North Carolina claiming that EPA's
classification of environmental tobacco
smoke (ETS) as a known human lung
carcinogen was "arbitrary and
capricious." The industry has
petitioned the court to compel EPA to
rescind its classification of ETS and to
withdraw its risk assessment. (The suit
does not challenge F.PA's
characterization of the respiratory
effects of ETS on children.)
To put the industry's challenge into
perspective, one should look at the
history of the case and the body of
evidence connecting ETS and lung
cancer. EPA's 530-page health risk
assessment, which took nearly four
years to complete, is an extensive
review and evaluation of several
hundred scientific studies on ETS. Two
separate drafts were reviewed
externally, and public comments
obtained. Two public review meetings
were held by an EPA Science Advisory
Board (SAB) committee of 18
independent experts in the field.
Following their second review meeting
in July 1992, the SAB concurred in
EPA's methodology and unanimously
endorsed the classification of ETS as a
"Group A" (known human) lung
carcinogen. The board also
commended the report's assessment of
the respiratory effects of ETS other
than cancer. No other report in recent
memory has received a stronger SAB
endorsement.
In addition, the National Cancer
a/i/ril iiinl linc>t of the A$eiu'\i'x Office of
Research and Development arc cmiittlm* cf O'/l'
-j>orl on t'TS.)
20
Institute and the Department of Health
and Human Services have endorsed
the assessment. So have the American
Medical Association, the American
Public Health Association, the
American Lung Association, and the
American Cancer Society.
EPA is neither alone nor the first to
find exposure to ETS hazardous. It has
merely assessed the largest database.
Both the U.S. Surgeon General and the
National Research Council of the
National Academy of Sciences
produced reports with substantially the
same conclusions in 1986. hi 1991, the
National Institute of Occupational
Safety and Health reviewed the
evidence and concluded that not only
was ETS a "potential occupational
carcinogen" but it could possibly cause
heart disease as well. Even a working
group of academicians (primarily at
McGill University) financially
supported by one of the plaintiffs
concluded there was strong evidence
linking "residential exposure to ETS
and both respiratory illness and
reduction in lung function."
More specifically, the tobacco
industry's lawsuit charges that EPA
used unscientific methods, did not
include the proper studies, loosened its
statistical standards, purposely
excluded studies that did not support
its conclusions, and violated its own
guidelines for conducting the
assessment. These charges focus
mainly on 30 epidemiology studies
used in assessing the relationship
between ETS and lung cancer in
women who never smoked themselves
but who were exposed to their
spouses' ETS. The lawsuit also charges
that "EPA completely ignored two
large studies published in the United
States . . . prior to its release ot the
final ETS risk assessment."
In focusing on these 30 epidemiology
studies, the EPA report included all
available lung cancer studies of
never-smoking women and ETS which
appeared prior to a necessary cutoff
date for literature review. The
evaluation involved five separate
statistical analyses, including
dose-response analyses and calculation
of risks to the women in the highest
exposure groups. The results of all five
analyses were consistent, and the
dose-response analyses and
high-exposure group risk analyses
provided very strong evidence of an
ETS hazard. For example, of the 30
studies, 17 provided data on risks by
amount of exposure; in all 17, those
women whose husbands smoked the
most had increased lung cancer risk,
and nine of these increases were
statistically significant despite small
sample sizes. Moreover, in the three
lung cancer studies which were
published after the cutoff date, the
women with the most ETS exposure
also had significantly increased risks.
Probably the best analysis for
evidence of a causal relationship
between ETS exposure and lung cancer
is an analysis for dose-response trends.
Of the 14 epidemiology studies which
provided data sufficient for
dose-response testing, all had positive
trends, and 10 of these were
statistically significant. The probability
of this high a proportion of significant
trend tests occurring by chance is less
than one in one billion. Also, it is
worth noting that two of the three
recent studies had statistically
significant dose-response trends.
Of course, the EPA report examined
the total weight of the evidence, not
just the 30 epidemiology studies.
Especially compelling evidence of the
carcinogenicity of ETS is the known
human-lung carcinogenicity of
"mainstream" tobacco smoke inhaled
by active smokers. For mainstream
tobacco smoke, a dose-response result
has been obtained down to very low
levels—and with no evidence of a
threshold. The similarities of ETS and
mainstream smoke (they come from
the same cigarette) and the known
exposure of nonsmokers to ETS at
levels which can be considered risky
are well documented in EPA's risk
assessment, n
EPA JOURNAL
-------
Lows Protecting Nonsmokers
So far, no stale bans smoking in all public places
by Fran Du Melle
Mike Bnsson photo
For more than 40 years, the
American Lung Association has
fought to eliminate air pollution from
both outdoor and indoor
environments. In recent years,
environmental tobacco smoke—or
ETS—has become a major focus.
To understand why a pollutant such
as ETS can be so harmful, think about
your lungs.For all practical purposes,
they are an external organ exposed to
the atmosphere as surely as is your
skin. If spread out end-to-end, the
gossamer-thin membrane lining of your
lungs would cover an area the size of a
tennis court. Even minute amounts of
air pollution can damage this intricate
breathing system, especially in infants
and young children.
Right now, according to the Centers
for Disease Control, 25.7 percent of all
adults in the United States smoke.
They consume nearly one trillion
cigarettes each year. That many people
smoking that many cigarettes mean a
lot of ETS assaulting our lungs.
The health effects of ETS were first
reviewed 20 years ago in the 1972 U.S.
Surgeon General's report on smoking
and health. Since that time, public
health advocates like the American
Lung Association have urged adoption
of laws and regulations making public
places, workplaces, and schools smoke
free. Release of EPA's January 1993
assessment of the health risks of
exposure to ETS provided a new
framework for encouraging policy
makers at the federal, state, and local
levels to take action to protect
everyone—smokers and nonsmokers
alike—from the dangers of ETS.
Smokers in the United States consume nearly
one trillion cigarettes each year. That means a
lot of ETS.
(Du Melle is Deputy Managing Director of the
American Lung Association.)
Exposure to ETS needn't be very
large to translate into a significant
public health hazard. The risk
assessment indicates that the dangers
from exposure to ETS are
dose-response related— the greater the
exposure, the greater the risk of injury.
Thus, policy makers can focus on
banning or at least restricting smoking
in places where people spend most of
their time. For adults, that means the
workplace; for children, it means
day-care centers and schools.
Many state and local governments as
well as private organizations and
companies have responded to the EPA
risk assessment by evaluating their
own laws, regulations, and policies on
smoking. The American Lung
Association has been pleased by this
response. However, much remains to
be done. Laws protecting nonsinokers
remain inconsistent from state to state
and from city to city.
Today, 46 states restrict smoking in
public worksites to one extent or
another, but many still allow smoking
in designated areas with or without
separate ventilation systems. The EPA
risk assessment has alnMdy spurred
several states, including Vermont and
Missouri, to enact new restrictions.
However, in a majority of st.Urs,
workers remain unprotected from ETS
in private worksites. California, tor
example, responded to the HPA report
by issuing an executive order banning
smoking in all state buildings. Yet that
state failed to pass legislation providing
the same protection in private
worksites. North Carolina has a new
law declaring that state buildings
cannot be totally smoke-free—each
must have an area designated for
smoking.
When it comes to protecting children
from ETS, state action has been very
21
-------
Restrictions on Smoking in Public Places
None (4)
Minimal (19)
Moderate (22)
J Extensive (5)
Comprehensive (0)
limited. Where steps have been taken,
they are frustrating]}7 inconsistent.
Although 39 states and the District ot
Columbia have laws restricting
smoking on school property, only a
few states—Hawaii, Kansas,
Minnesota, New Hampshire, New
jersey, Washington—ban tobacco use
by both students and faculty in school
buildings at all times.
For infants and toddlers—children
with the tiniest, most vulnerable
lungs—there are no significant
state-level protections from ETS.
Alaska and Michigan are among only a
very few states that prohibit smoking
in day-care facilities. Other states have
some restrictions but allow smoking in
designated areas or at times when
children are not present. Few states
regulate smoking for day-care centers
located in private homes.
The EPA risk assessment provided
an incentive to the American I.ung
Association and its partners in the
Coalition on Smoking OR Health, the
American Cancer Society, and the
American Heart Association to
re-evaluate the way we assess laws or
regulations to protect individuals from
ETS. In the past, we simply examined
the number of places covered by a law.
The Coalition now examines, in detail,
the actual provisions of each law
restricting smoking in public
workplaces, private workplaces,
schools and day-care centers,
health-care facilities, and public places
and restaurants.
The risk assessment indicates that
the dangers from exposure to ETS
are dose-response related—the
greater the exposure, the greater
the risk of injury.
Our new rating system is presented
in State Legislated Actions on Tobacco Use,
an annual Coalition publication. We
found that although 46 states have
restrictions on smoking in public
places, 19 have laws we consider
"minimal" and 22 we consider
"moderate."
States with "minimal" restrictions
require employers to establish a written
smoking policy. Details of the policy
are determined by the writer of the
policy—the employer, building owner,
etc. In some states, designated
smoking areas may be required. In other
words, a worksite could not be
declared completely smoke free. In a
worst-case scenario, an entire building
could be designated as a smoking area.
States with "moderate" restrictions
are likely to ban smoking outright in a
few places, such as retail stores, public
transportation, hospitals, and
elevators, and these states call for
mandatory designated smoking areas
in many places.
States with "extensive" restrictions
ban smoking more widely in public
places but still permit some designated
smoking areas. Only three
states—Minnesota, New Hampshire,
and New York— received "extensive"
ratings.
States with "comprehensive"
restrictions—the Coalition's top rating
category—ban smoking in all public
areas. No state has achieved this
status—yet.
The inequities of this "patchwork
quilt" must be corrected to protect
everyone from exposure to ETS in
public places or at work. The American
Lung Association is certain that, as
public awareness and concern about
ETS grow, policy makers will heed the
concerns of the people they serve. In
the coming years, more states and
localities will move into the "extensive"
and "comprehensive" categories. D
(To obtain a copy of State Legislated
Actions on Tobacco Use, contact the
Coalition on Smoking OR Health, 1150
Connecticut Avenue, NW, Suite 820,
Washington, DC 20036; telephone:
202/452-1184.)
EPA JOURNAL
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The TEAM Studies
by Lance Wallace
Hot showers produced elevated levels of chloroform
What links cigarettes, air
deodorizers, and hot showers? If
you respond that they are among the
major sources of human exposure for
certain toxic chemicals, you probably
have been reading about the results of
EPA's TEAM (Total Exposure
Assessment Methodology) studies.
EPA's Office of Research and
Development developed the TEAM
concept in 1979, and for more than a
decade—by directly measuring the
exposure of individuals—these studies
have supplied a wealth of information
on our actual exposure to pollutants in
arr and drinking water. As discussed
earlier in this issue of EPA Journal (see
articles on page 6 and 9), knowing
more about exposure enables us to
better estimate risk.
Participants in a TEAM study are
selected randomly, as in a Gallup poll,
to represent a much larger group.
Target pollutants are selected on the
basis of toxicity, carcinogenicity, and
production volume. To measure
exposure where people are, personal
air quality monitors are provided to
accompany participants on their
normal daily activities. If drinking
water is a likely source of a pollutant,
samples are collected from the tap at
home and at work. Samples of food or
house dust may be collected as well.
Breath samples are collected to
determine levels of certain pollutants in
people's bodies. Outdoor air samples
are collected near the participant's
house to determine what proportion of
the exposure is contributed by outdoor
air.
To date, about 2,500 people,
representing a total population of
about 3 million residents of various
cities, have taken part in TEAM
studies. The TEAM concept has also
been applied in large-scale studies by
industry and by foreign governments.
(Dr. Wallace is nn environmental scientist at EPA's
Atmospheric Research and Exposure Assessment
Laboratory. He has worked (or the Agency's Office
of Research and Development since 1977.)
OCTOBER-DECEMBER 1993
The premier TEAM study was the
first and the largest study that
attempted to determine whether
persons living close to chemical plants
and petroleum refineries had higher
exposures to toxic volatile organic
compounds than persons living a few
miles away. No such effect was found
at any of the study sites—Elizabeth
and Bayonne, New Jersey, and Los
Angeles, Antioch, and Pittsburg,
California. Surprisingly, the median air
concentrations of the 18 targeted
chemicals ranged from 2 to 20 times
higher in participants' homes than in
the outdoors. In short, even in these
areas that were thought to be highly
polluted, outdoor air, on average,
accounted for only about 2 percent to
25 percent of total airborne exposure.
The bulk of the exposure, for every
chemical, came from indoor sources.
What were these sources? The study
was able to identify some, but not all,
of the important sources for certain
toxic chemicals. For example,
measurements of exhaled breath
revealed that smokers have 6 to 10
times the amount of benzene in their
blood as nonsmokers. In fact, for
average smokers, cigarettes provide
about 90 percent of their total exposure
to benzene. Moreover, indoor air in
homes with smokers had about 50
percent more benzene than in homes
without smokers.
A second toxic chemical included in
this study was para-dichlorobenzene
(p-DCB), a registered pesticide
commonly used to control moths but
also used as a bathroom air deodorizer.
It is used in most public toilets in the
United States, and it is the active
ingredient in products for the
home—"srickups," sprays,
liquids—that are used as a room air or
toilet bowl deodorants. About a third
of the 750 homes measured in the
TEAM VOC studies had elevated levels
of p-DCB. By putting a common
bathroom air deodorizer into a home
and measuring concentrations of
p-DCB both in indoor air and in the
exhaled breath of the residents, the
investigators were able to track sharply
increasing concentrations of P-DCB in
the blood of the residents over a
three-day period.
This first TEAM study suggested that
elevated indoor air concentrations of
chloroform are caused by heated water
uses in the home, especially hot
showers and washing clothes and
dishes. Measurements of tap water
showed that it too was an important
source of exposure to chloroform.
Finally, measurements of food and
beverages showed the presence of
chloroform at low levels in soft drinks,
milk, and dairy products such as butter
and cheese.
A special TEAM study determined
that bringing home freshly dry-cleaned
clothes elevates indoor levels of
dry-cleaning chemical (usually
terrachloroethylene) to concentrations
about 100 times outdoor
concentrations. Levels remain elevated
for at least a week. The major pathway
of exposure was determined to be the
outgassing of the chemical residues
remaining on the clothes.
Another special TEAM study of three
new buildings and seven older ones
showed that the new buildings had
concentrations of eight chemicals that
were typically 100 times outdoor
concentrations. These chemicals
included xylenes, ethylbenzene,
decane, and undecane, which are
commonly used in paints and
adhesives. Repeated visits to the three
new buildings over the three months
following their completion suggested
that it would take six months to a year
for the chemical concentrations to
decline to the levels observed in the
seven older buildings.
A TEAM study of exposure to carbon
monoxide (CO) in winter was carried
out in Washington, DC, and Denver,
Colorado. More than 800 people in
Washington and 450 in Denver carried
a newly designed personal CO monitor
for a day. The findings confirmed
suggestions from earlier studies that
23
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driving was the most common source
of concentrated exposure to CO. But
they also showed that attached
garages, gas stoves, and environmental
tobacco smoke (ETS) could elevate
exposures.
A TEAM study of exposure to
airborne pesticides (the
Nonoccupational Pesticide Exposure
Study, or NOPES) was carried out in
Jacksonville, Florida, and Springfield
and Chickopee, Massachusetts. Indoor
sources accounted for 90 percent or
more of the total airborne exposure to
most of these pesticides, some of
which had already been banned or
otherwise regulated by EPA (aldrin,
dieldrin, heptachlor, and chlordane)
but continued to be found in the
homes.
Since these pesticides were
previously used widely to prevent
termites, they are believed to have
entered the homes via diffusion of soil
gas into basements, in much the same
way as radon enters homes. Another
pesticide, DDT, banned for nearly 20
years, was found in house dust in five
of eight homes. Later studies, which
included measurements in soil just
outside the home, suggested that DDT
and other long-lasting pesticides may
be tracked in from soil clinging to
shoes.
It is almost as if the participants
were walking about in their own
personal cloud of particles, a sort
of Pigpen effect....
The most recent TEAM study was
performed in Riverside, California.
This was the Particle TEAM, or
PTEAM, study. A personal monitor
collected particles (and also nicotine) in
the breathing area of 178 Riverside
residents for two consecutive 12-hour
periods. The filters were later analyzed
for 15 elements, including lead,
chlorine, and sulfur.
A major surprising finding was that
daytime personal exposures were 50
percent higher than concurrent indoor
air concentrations measured by a fixed
monitor in the home. It is almost as if
the participants were walking about in
their own personal cloud of particles, a
sort of Pigpen effect, after the character
in the Peanuts comic strip. This excess
exposure—including exposure to 14 of
the 15 elements—may be due to
particles from carpets, furniture, or
clothing that are resuspended through
walking, sitting, or other movements.
Other important indoor sources of
PEANUTS
CHARLES M...SCH.UL2
THEY 6M Mf atXiK ON
HIM THE CXfiT AND DC^T Of
ANCIENT CIVILIZATIONS...
HISTORY 16
Bf FORE
EYES!
PEANUTS leptimea by permission of UFS. Inc.
particles were smoking and cooking.
Cooking resulted in increased levels of
particles and organic chemicals known
as polyaromatic hydrocarbons (PAHs).
In summary, the findings of the
TEAM studies underline the
importance of actually measuring
human exposure, rather than
estimating it from measurements of
outdoor (or indoor) air. Without the
measurements made possible by
personal monitors, we might still think
that urban-industrial areas, chemical
plants, and petroleum refineries
provide our major sources of exposure
to toxic chemicals. Instead, the TEAM
studies suggest that the major sources
for many chemicals are literally under
our noses.
Should we be worried about these
chemicals? The TEAM studies alone do
not answer this question. In the case of
benzene, both the International Agency
for Research on Cancer (1ARC) and
EPA have determined that benzene
causes leukemia in humans. Further,
studies have shown that children of
smokers die of leukemia at twice the
rate as children of nonsmokers. Many
of the other chemicals mentioned
above—chloroform,
tetrachloro-ethylene, PAHs,
p-DCB—cause cancer in rats and mice;
they mayor may not cause cancer in
humans. Some of the remaining
chemicals—xylenes, decane,
undecane—act on the central nervous
system at high concentrations, causing
dizziness and headaches. Because
these symptoms are common in Sick
Building Syndrome (SBS), particularly
in new or renovated buildings where
concentrations of these chemicals are
high, some investigators believe that
these and related VOCs may be one of
the causes of SBS.
What can you do to reduce your
exposure to indoor air pollutants? A
number of simple and inexpensive
measures, such as maintaining a
smoke-free home and routinely using a
doormat or even establishing a "no
shoes indoors" policy to avoid tracking
soil into the house can reduce
exposures considerably. To obtain a
free booklet, The Inside Story, which
describes actions people can take to
reduce their exposures to indoor
pollution, contact: Indoor Air Quality
INFO, P.O. Box 37133, Washington,
DC 20013-7133; phone: 800/438-4318. a
EPA JOURNAL
-------
Investigating
Sick Buildings
No obvious sources of contaminants are found
By Brian Leaderer
It is a winter afternoon. You are at
your desk feeling uncomfortable.
Your eyes and throat are irritated; you
have a slight headache and feel
lethargic. You find that several of your
coworkers are experiencing these same
symptoms plus others: nose irritation,
fatigue, watering eyes, stuffy nose, dry
or itching skin, and difficulty
breathing. These symptoms seem to
occur only during working hours, are
highly variable in their degree of
severity, and affect a variable percent
of your building's occupants on any
given day. A few occupants seem to be
severely affected.
You and the other building
occupants fear that poor air quality is
responsible for all of your symptoms.
The building owners call in a group of
(Dr. Leaderer is a Professor and Head of the
Division of Enviranincntal Health Sciences,
Department of Epidemiology and Public Health at
the Yale University School of Medicine. He is ii/sn a
fellow nt the Inhn B. fierce laboratory.)
OCTOBER-DECEMBER 1993
The symptoms of sick building
syndrome usually diminish when
the individual is away from work.
experts to determine the nature and
cause of the complaints. Levels of
microbiologicals, volatile organics, and
particulates are found to be well within
accepted standards. No obvious
sources of contaminants are found.
Fresh-air supply rates are at the low
end of accepted guidelines; the
engineering drawings of the building
do not reflect the many changes made
to the building's heating, air
conditioning, and ventilation system.
Thermal conditions are within the
accepted comfort range but somewhat
variable. The quality of lighting is
variable, and the office space is dusty.
The experts are unable to find a
direct relation between employee
symptoms and any physical, chemical,
or biological factors in the building.
They recommend increased fresh air
Sfeve Delaney photo
supply rates, better building
maintenance and record keeping,
improved lighting at work stations,
and more direct occupant control of
their thermal environment. No
guarantees are given that these steps
will reduce the occupants' symptoms,
particularly the most severe symptoms.
When asked whether the symptom
rates are high and reason for health
concern, the experts can only say that
they have no basis of comparison upon
which to make that judgment. The
building owner makes the
recommended changes and hopes the
problem will disappear.
The situation described above has
become known as building-related
occupancy complying syndrome
(BROCS), sick building syndrome
(SBS), or tight building syndrome. It
occurs in nonindustrial workplaces
such as schools, office buildings,
commercial buildings, and hospitals
throughout the world. The incidence of
these outbreaks has increased with the
25
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Bruce Tichenor.
environmental
engineer at EPA's
Air and Energy
Research
Laboratory in RTF,
North Carolina.
adjusts a
temperature probe
for a small
environmental test
chamber. The
interactions of so
many factors
(including
temperature) make
sick building
syndrome difficult
to study.
EPA photo
development of strategies to reduce
energy consumption and with the
introduction of new materials and
machinery into the workplace.
BROCS/SBS is loosely defined as an
increase in the frequency of a
constellation of acute, nonspecific
symptoms characteristically affecting
multiple occupants of a building. The
symptoms usually, though not always,
diminish while the individual is away
from the building. The most common
include irritation of the eyes, nose, and
throat; headache; fatigue; nausea; and
lethargy. Sore or dry eyes, stuffy or
runny nose, sore throat, difficulty
breathing, and dry or itching skin have
also been associated with the
syndrome. The symptoms do not fit
any specific clinical syndrome and are
typically not associated with any single
source or specific air contaminant.
BROCS/SBS is one of two
building-related problems. The second
is known as building-related illnesses
(BRI). Unlike BROCS/SBS, BR1 are
illnesses with a specific clinical
syndrome that is associated with
exposure to specific or general
categories of contaminants related to
identifiable sources. Examples include:
Legionnaires' disease, associated with
exposure to bacteria; hypersensitivity
pneumonitis and humidifier fever,
associated with exposure to bioaerosols
such as fungi and bacteria; and
symptoms associated with specific
chemical exposures, such as headaches
and cardiovascular effects resulting
from carbon monoxide exposure or eye
irritation associated with exposure to
formaldehyde.
The cause of the complaints
associated with BROCS/SBS is believed
to involve a complex interaction of a
number of factors. These indoor factors
include: chemical and biological
emissions from building materials,
furnishings and surfaces; building
environmental systems; building use;
physical factors such as temperature,
humidity, air flow, noise, and light;
ergonomics; individual characteristics
such as age, gender, race, smoking
status, and health; and social
dynamics—job stress, job satisfaction,
privacy. The nonspecific nature of the
complaints and the complex interaction
of the factors make BROCS/SBS
difficult to study.
Several investigations, some
involving thousands of office workers
in several buildings, have been
undertaken to characteri/e the nature
and prevalence of building-related
symptoms and to determine whether
an association can be established
between them and the factors
mentioned above. Typically, there are
no obvious sources. A complex mix of
contaminants is measured, with all
individual constituents well below
industrial or ambient air standards.
There are no relevant indoor air quality
standards or guidelines that apply,
although there are ventilation and
thermal guidelines issued by the
American Society of Heating,
Refrigerating and Air-conditioning
Engineers (ASHRAE). Occupant
complaints are nonspecific, episodic in
nature, and affect varying numbers of
occupants. Invariably, the symptoms
are absent when investigations are
conducted—the "you should have been
here yesterday" effect.
Further, there is a lack of normative
data: What is a "healthy" building? In
setting criteria for thermal conditions in
a building, it is generally accepted that
only 80 to 90 percent of the occupants
need be satisfied. No data exist,
however, that establish the baseline
rates in "normal" buildings for the
prevalence and severity of symptoms
or environmental factors. Without
normative data, it is difficult to identify
problem buildings.
Field study efforts to characteri/e the
nature of building-related symptoms
have had difficulties for two major
reasons. First, questionnaires used for
self-reported symptoms have not
adequately addressed such issues as
frequency of symptoms, temporal
distribution, and whether they are
work-related (i.e., symptoms disappear
away from work). Also, they have not
obtained information on such
important factors as health status and
job satisfaction. Second, only a few
environmental variables have been
monitored, the temporal and spatial
representation of the monitoring has
been poor, and the measurements
typically have not been coincident with
the reporting of symptoms by
occupants.
In spite of all the problems with
studying BROCS/SBS, progress is being
made. Recent investigations (see box)
have used methodologies that address
many of the shortcomings of previous
ones. EPA has sponsored development
of standardised protocols and will fund
their application in hundreds of normal
and problem buildings across the
United States. This will allow the
pooling of data, the analysis of which
will provide definitions of what
"healthy" and "sick" buildings are.
New statistical methods are being
applied that should advance our
understanding of the interrelationships
among factors associated with
BROCS/SBS. Scientists have recently
initiated animal and human studies
into the nature and degree of eye,
nose, and throat irritation (among the
major BROCS/SBS symptoms); they are
also examining how low levels of
complex volatile organic compounds
emitted from building materials and
furnishings affect irritation.
Perhaps, one day when occupants
complain of a host of nonspecific
symptoms related to their
nonindustrial workplace, the experts
called in to investigate may actually be
able to provide solutions. Q
26
EPA JOURNAL
-------
EPA and LOG Buildings Examined for SBS
One of the most
comprehensive
investigations of
workplace indoor
air quality was
conducted at
Washington, DC,
offices of EPA and
the Library of
Congress. Shown is
EPA headquarters'
West Tower
building.
The Indoor Air Quality and Work
Environment Study of the Library of
Congress (LOC) Madison Memorial
Building and the EPA headquarters
buildings (Waterside Mall complex,
Fairchild Building, and Crystal Mall) in
Washington, DC, is one of the largest
and most comprehensive BROCS/SBS
investigations ever conducted. The
study was undertaken in the winter of
1989 in response to a long history of
complaints reported by the occupants
and to their concerns about indoor air
quality in their work environment. The
study was designed and conducted by
an interdisciplinary group of
researchers from the John B. Pierce
Laboratory at the Yale University
School of Medicine, the National
Institute for Occupational Safety and
Health, EPA, the National Institute of
Standards, and Westat, Inc.
The primary objectives were to
survey health symptoms and comfort
concerns of employees, characterize the
indoor environment in selected
Sreve Delaney photo
locations, and analyze possible
associations between health or comfort
symptoms and conditions in the
building. The study provided
researchers with an opportunity to test
protocols which could address many of
the problems inherent in studying
BROCS/SBS issues.
The study was conducted in two
stages. The first consisted of a
self-administered questionnaire that all
occupants of the buildings were asked
to complete. Respondents provided
information on work-station
characteristics, work-related acute
health symptoms and thermal
discomfort, perceived sources of poor
air quality and effects, demographics,
and psychosocial factors including job
stressors. The questionnaire was
distributed to 8,076 employees and
completed by 6,800 for a response rate
of 84 percent. From the results of this
initial survey, areas of the buildings
were ranked according to
health-symptom and
thermal-discomfort prevalence; areas
with low and high reporting rates were
chosen for inclusion in the second
stage of the study.
In the second stage, environmental
monitoring was conducted at the high
and low symptom and thermal
discomfort locations, and a
supplemental questionnaire was
administered to occupants near the
monitoring sites. This questionnaire
assessed health and comfort status and
mood states during the same period
the monitoring was performed.
Monitoring included measurements of
temperature, humidity, ventilation
rates, and a host of air contaminants.
The second questionnaire was
administered to approximately 1,300
occupants.
The investigation has produced a
rich database, the analysis of which is
ongoing. Descriptive analysis of the
initial questionnaire showed
BROCS/SBS symptoms to vary between
buildings, with the LOC building
generally showing a higher rate of
symptoms than the EPA buildings.
Symptom prevalence rates were
typically less than 20 percent.
Without normative data, it is difficult
to determine whether rates were
higher than should be expected.
Thermal discomfort was high in all
buildings, with as many as 55 percent
of the Waterside Mall occupants
indicating that they would like to
adjust the temperature. Multivariate
analysis showed that several of the
workplace factors were associated with
variations in symptoms—stuffy air,
respondent allergies, thermal
conditions, dustiness, glare, etc. These
factors generally explained between 15
to 25 percent of the variation in
reported symptoms. Measured levels of
air contaminants were not associated
with the symptoms. As the statistical
analysis of the data proceeds, we
expect to learn more of the relation
between symptoms and exposures.
The LOC/EPA study, while not
providing any clear cause for the
symptoms experienced by the building
occupants, did advance our
understanding of BROCS/SBS and has
led to new lines of investigation of the
nature and causes of building-related
symptoms and discomfort.
OCTOBER-DECEMBER 1993
-------
Economic Effects
of Poor IAQ
by Curtis Haymore and
Rosemarie Odom
Just opening a window can disrupt production
Poor indoor air quality (IAQ) takes
its toll in a variety of ways. It
damages our health and our
possessions; it lowers our productivity
at work; and it diverts resources to
diagnosing and solving problems that
result from it. Although the economic
costs of some of these damages are
fairly tangible and easy to quantify, a
large portion are hidden. The
cumulative impact can easily reach into
the billions of dollars.
The cost to diagnose, mitigate, and
litigate IAQ problems is evidenced by
the burgeoning number of businesses
providing these services. A recent EPA
survey indicated that over 1,500 firms
specialize in IAQ services, a 25-percent
increase from 1988. The median price
for evaluating and balancing ventilation
systems ranges from $250 to $1,500.
The median for duct-cleaning services
is about $500 and for asbestos
abatement and construction/renovation,
about $5,000. Costs can be as high as
$50,000 for some of these services.
In addition, the cost of fees, awards,
and settlements is also growing as an
increasing number of lAQ-related cases
are being litigated. Although most IAQ
complaints are resolved through
settlements, enormous sums of money
have to be invested in investigations,
testing, and expert testimony, in
addition to legal fees. The settlements
themselves are often in the hundreds
of thousands to millions of dollars.
The economic costs of poor IAQ also
include the actual damages to property
caused by contaminants. Indoor air
pollutants can damage metals, paints,
textiles, paper, and magnetic storage
(Haymore is Vice President of the Energy and
Environment Division, Socio-Teclinicnl Research
Applications, hie. Odom is a Senior Associate al
Socio-Tecliniail Research Applications. Inc.)
media and can cause increased soiling,
deterioration of appearance, and
reduced service life for furniture,
draperies, interiors, and heating,
ventilation, and air conditioning
(HVAC) equipment.
Some objects and materials are
"sensitive populations" and are
particularly susceptible to damage. For
example, antique leather- bound books
and fine art are particularly vulnerable
to a number of contaminants.
Electronic equipment, which is
particularly susceptible to corrosion,
represents a large investment at risk
from poor IAQ.
Injury to people represents an even
larger cost of poor IAQ. EPA ranks
IAQ problems as one of the largest
remaining health risks in the United
States. Health effects range from the
mildly irritating, such as headaches
and allergies, to the life threatening,
such as cancer and heart disease.
Medical costs due to excess cancer
cases caused by indoor air
contaminants are estimated to range
from $188 million to $1.375 billion
nationwide. Heart disease caused by
exposure to environmental tobacco
smoke can equal another $300 million.
One study indicated that for every 100
white collar workers, poor IAQ would
cause an extra 24 doctor visits per year.
This amounts to another $288 million.
One of the "invisible" costs of poor
IAQ is the lost productivity of workers
who experience headaches, eye
irritation, and fatigue, among other
symptoms. Productivity drops as
employees are less effective at their
tasks, spend more time away from
their work stations, or require more
frequent breaks. Even a seemingly
minor activity such as taking a pain
reliever or opening a window can
disrupt productivity. In more severe
cases, increased absenteeism and
plummeting morale result. One study
found that 14 minutes are lost per
8-hour day due to poor IAQ. In
addition, for every 10 workers, poor
IAQ causes an additional six sick day:
per year. If this is true, the resulting
cost of the lost productivity for the
United States is $41.4 billion.
Given these large costs of living wit
poor-quality indoor air, what can be
done? The long-run answer is that
buildings can be designed better. The
short-run answer is to correct problerr
in existing buildings. What does it
cost? Our research has shown that
better practices often save money. In
any event, they are a small fraction of
overall building costs, and they are
substantially less than the price we pa
for poor IAQ.
Better Designs Save Money
About 1,250,000 new housing units
and new office, retail, and factory
buildings are built each year. In these
new structures, architects and builders
have the opportunity to "do it right th
first time."
The first step in better designs is to
avoid contaminants. Architects and
builders can:
• Insist on building materials that
have fewer potential contaminants or
have lower concentrations of
contaminants
• Change the mix of materials (for
example, using linoleum instead of
carpeting usually results in fewer
potential contaminants and a lower
building cost)
• "Air out" materials before they are
used, and air out the building before it
is occupied
• Place air intakes away from sources
of contaminants, such as parking areas
street traffic, and exhaust vents
28
EPA JOURNAL
-------
The Old Reading
Room at the Folger
Shakespeare
Library.
Washington. DC
Fine art and antique
leather-bound
books are
particularly
vulnerable to some
contaminants
• Avoid breeding bacteria bv
exercising good ductwork design, use
of materials that won't trap moisture,
and design of the HVAC system for
easy inspection and cleaning.
Did you ever notice that bathrooms
usually have separate exhaust tans that
pump bad air directly outside? This
same principle should be used in areas
where indoor air contaminants are
likely to be present, such as kitchens
and smoking lounges. But by tar the
most common technique for improving
IAQ is to use bigger HVAC equipment
to move more outside "fresh" air into
the building, replacing some of the
"stale" or contaminated air. \'e\v
buildings can also use more
sophisticated filters that better remove
contaminants from the air stream,
Good Operations Cost Can Also Save
Most buildings will be in use for at
least 20 to 30 years. Indoor air quality
depends on maintaining the building
and its HVAC system well. This
requires periodic replacement ol
equipment, preventive maintenance to
avoid problems, and monitoring
building conditions.
A good maintenance program
monitors the actual performance of a
building and surveys the building
occupants to discover problems. Some
common maintenance procedures
include inspecting, cleaning, or
repairing the following:
Outdoor air intakes
Mixing plenums (where outside air
is mixed with recirculating
indoor air)
Filters
Heating and cooling coils
Air supply fans
Ducts
Humidity controls
HVAC system controls.
Although owners might fear the
costs of improving the IAQ of their
buildings, our research has shown that
well-run buildings cost less to operate.
Here are some ways in which building
owners can save money:
• Well-run buildings use less
electricity and other forms of power.
Relative Costs and Savings of Measures to Improve IAQ
Better Design
Retrofit
Operation and Maintenance
Folgei Shskesped/e Lrbrar,' p/iofo
• Good IAQ practices result in lower
life-cycle costs for equipment, less
frequent repairs and system
shutdowns, and longer life of HVAC
equipment.
• The major reason most tenants
move is not cost or location or space,
but their dissatisfaction with their
current buildings systems. If tenants
experience three basic building
problems in a year, there is greater
than a 50-percent chance they will
relocate ("three strikes and theyre
out!"). Good IAQ practices help keep
tenants.
Why Isn't More Being Done?
If good IAQ is so cost effective, why
isn't it pursued? First of all, a lot of
people simply dont know about indoor
air quality and its costs. Tenants dont
demand good IAQ practices when they
choose office space, so building owners
and operators have no incentive to
invest in them. Moreover, investors
tend to act on the "edifice complex." In
other words, they prefer to invest in
the outward appearance of buildings
rather than their mechanical systems.
Most people never see the HVAC
system in a building, so little attention
is paid to it. Until public awareness
increases and tenants and consumers
begin demanding good IAQ, the costs
of poor IAQ will continue to drain our
resources and burden our economy. a
OCTOBER-DECEMBER 1993
29
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Regulating IAQ:
The Economisfs
View
Indoor air is air that someone owns
Bungee jumper take
plunge. The individua
attach different vali
health and length >
than the govern
by Robert G. Hansen and
John R. Lott, Jr.
' arketplace forces don't always
. produce the desired results in
environmental quality. Outdoor air
pollution, for example, is a difficult
problem to solve using the free market.
In large cities there are thousands of
sources of pollution and millions of
potential victims. If left to their own
desires, would those individuals
responsible for outside air pollution
assume the cost of reducing pollution
but share the benefits with everyone
who might be affected? Altruism seems
unlikely to be enough to solve this
pollution problem, and the likely
answer is no. In the case of outdoor air
pollution, then, most economists
would advocate taxes to make those
who produce the pollution bear the
costs that they are imposing upon
others. Indoor air pollution is another
matter.
In general, environmental problems
arise precisely because decision makers
do not bear all the costs resulting from
their decisions. Economists refer to one
version of this problem as the
"common pool" or "overfishing"
problem. In the case of fisheries,
fishermen overfish an area until the
stock of fish has been depleted because
they stand to gain nothing for letting a
fish remain uncaught. If one fisherman
lets a fish go so that it might mature
and produce more offspring, there is
no guarantee that another fisherman
will not catch that same fish.
(Hansen is an associate professor at Tuck School oj
Business at Dartmouth College; Lott is the Carl D.
Covitz Assistant Professor at the Whartoii School of
Business at the University of Pennsylvania.)
30
Therefore, the fishermen catch the fish
as quickly as they can, and the
outcome is that the fishery is depleted.
One solution to this problem,
favored by economists, is to ensure
that one person owns the fishery.
When a fishery is privately owned and
not open to just anyone who desires to
fish there, it is in the owner's interest
to maximize the long-term value of that
property. Moreover, if fish become a
scarce commodity in the future, the
individual owner stands to earn an
even greater return for abstaining from
fishing today so that more fish will be
available for sale at a higher market
price later.
The irony in the current debate over
indoor air pollution is that indoor air
fits the classic case where economists
argue government intervention is most
unwelcome. By definition, indoor air is
air within a building that someone
owns. As long as someone owns the
air, he or she obtains both the benefits
and the costs from deciding how clean
it should be.
The most obvious case is where
someone owns and lives in a home
alone. No problem exists since the
owner/occupant bears all the costs and
benefits of any pollution produced
within. This is just as true for the
decision to smoke cigarettes as it is to
purchase less expensive products that
emit toxic fumes, such as benzene or
formaldehyde, instead of more
expensive ones that do not. Even with
more than one occupant in the house,
there would still not be a case for
government intervention. Since those
affected are few in number, they
should easily be able to reach
agreement on air quality within the
house.
If government intervention occurs in
such a case, it should be limited to
providing individuals unbiased
•information—though it is not obvious
why the market would not provide
such information if really desired by
people. (For example, the information
could be produced through Consumer
Reports or private firms raring the
condition of houses.)
Cost-benefit calculations done by the
government are not a close substitute
for private decision making.
Individuals' decisions may differ from
regulators' because individuals may be
inarticulate and uninformed, or
perhaps because they may attach
different values to their health and
length of life than do the regulators.
Cost-benefit analysis goes to great
lengths to approximate peoples values
for these things, but this is one area
where we can simply rely on those
affected individuals to reveal this
information themselves. Moreover,
binding regulations ignore the
possibility that just as some individuals
are happiest when taking risks like
bungee jumping, there may be a few
whose utility is greatest when they
take risks that most people deem
unacceptable.
Individuals undoubtedly make
mistakes, but the government must
find some way of distinguishing
whether people are underestimating
the risks of their actions or are simply
attaching different values to things
than regulators do. The problem is
even more complicated in that
individuals may be just as likely to
overestimate the risks from their
actions as they are to underestimate
them. Evidence from opinion surveys
EPA JOURNAL
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and econometric studies of smoking
suggest that people have a greater fear
of getting cancer from smoking than is
justified by actual cancer statistics. Any
honest appraisal would also have to
admit that the government also makes
its share of mistakes. As examples,
consider the mandates for use of
oxygenated auto fuels during the
winter or for asbestos removal from
buildings, or the Food and Drug
Administration's restrictions on
vitamins over the past 3D years.
Government regulation of indoor air
quality in office buildings and
restaurants is similarly unwarranted,
for there is still one person—the
owner—who has clear incentives to do
the best possible cost-benefit analysis.
Wide World photo
The question of allowing smoking in a
restaurant is no different than the
question whether the restaurant
provides music or other amenities.
Some customers may value music with
their meals, just as some value being
able to smoke cigarettes. Presumably,
regulators are not concerned about
whether restaurants are failing to
provide the right amount or type of
music, and the reason for this is pretty
obvious: If restaurants do not provide
the service wanted by the customers,
they will go out of business. Nor does
there currently seem to be a strong
movement to ensure that additional or
fewer restaurants provide vegetarian
foods or steaks. When restaurants
make the wrong decision, customers
The question of allowing
smoking in a restaurant is no
different than the question
whether the restaurant
provides music or other
amenities.
take their business elsewhere.
Restaurants offer customers
nonsmoking areas, without any
government mandates, and Muse Air
tried to offer completely nonsmoking
flights during the 1980s but eventually
went out of business. Economists
would infer from Muse Air's
experience that smokers valued
smoking in airlines (even if restricted
to certain smoking sections) more than
nonsmokers valued completely
smoke-free air. To force airlines to ban
smoking on all flights thus makes
smokers worse off by a greater amount
than it benefits nonsmokers.
Similar considerations apply to
employers and employees. For
employees, there is a large economics
literature identifying the higher wages
firms must pay their workers in order
for these workers to be willing to
undertake riskier activities. Firms
requiring that their workers inhabit
so-called "sick buildings" not only face
greater costs through higher
absenteeism, but also higher wage
costs as workers find those jobs less
desirable places to be. Workers value
their health, but they also value higher
wages. It is not obvious who, other
than the workers and owners, is in a
better position to judge the trade-offs
that workers are willing to make
between these two values.
The bottom line is that even the
most efficiency-motivated government
is unable to improve upon the
cost-benefit calculus done by those
affected by indoor air pollution. In the
real world the true choice is even
clearer. Governments face many
conflicting interests that have nothing
to do with maximizing consumer or
worker welfare. Government
bureaucrats' preferences are not
necessarily superior to those they are
regulating. Who is to say that citizens
are making mistakes whenever their
decisions differ from what the
regulators desire? n
OCTOBER-DECEMBER 1993
31
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California's Program
Indoor air problems arent amenable to regulation
by Jerome Wesolowski
In 1982, California's legislature
established an Indoor Air Quality
Program (CIAQP) in the Department of
Health Services to carry out research
on the nature and extent of the indoor
air problem (excluding industrial
worksites), to find appropriate
mitigation measures, and to promote
and coordinate the efforts of other state
agencies. Since indoor air problems
usually are not amenable to regulatory
solutions, regulatory authority was not
included in the mandate.
Seven technical people work in the
program. They represent several
disciplines, including chemistry,
epidemiology, industrial hygiene,
ventilation engineering, psychology,
and microbiology. The group also
draws on other professionals in the
Department of Health Services (DHS),
such as toxicologists, physicians,
sanitarians, and risk assessors.
The program conducts research into
a wide range of contaminants—radon,
asbestos, formaldehyde, carbon
monoxide, volatile organic compounds,
environmental tobacco smoke (ETS), as
well as into biological aerosols that
cause such diseases as Legionnaires
disease, tuberculosis, allergies, and
asthma. Studies are also carried out to
better understand the Sick Building
Syndrome. The research includes field
surveys to determine the exposure of
the population to specific contaminants
and experiments in the laboratory to
develop protocols for reducing
exposures. The research emphasizes
measurement of exposure—
concentration multiplied by
the time a person is exposed—as
opposed to measurement of
concentration only.
(The late Jerome Wcso/otosfci wns the Qiic/o/ the
Environmental Health Laboratory of the California
Department of Health Services and an Adjunct
Professor at the University of California, Berkeley.
He died on January 1, 1994, at the age of 61.
Donations in his name may be made either lo
environmental conservancy agencies or to cancer
research.)
The research provides a scientific
basis for policy. For example, radon
surveys were used in developing the
state's mitigation objectives. These
objectives are somewhat less ambitious
than those of other states, because the
survey found that radon levels in
California were generally lower than
levels in other states.
The research component also
provides the scientific foundation for
the education component. Education
includes workshops, technical
conferences, telephone response to
citizen questions, and the development
of pamphlets and guidelines for the
general public, building owners and
managers, and hospital staff.
Pamphlets and guidelines include: A
Californian's Guide to Radon, Using
Ultraviolet Radiation and Ventilation to
Control Tuberculosis, Guidelines for
Reduction of Exposure to Volatile Organic
Compounds (VOC) in Neivly Constructed
or Remodeled Office Buildings, and
Control of Asbestos in Public Buildings.
Because resources don't cover
investigative services for individual
citizens or building owners and
managers, the group has developed an
assistance directory which lists the
names, addresses, telephone numbers,
and IAQ diagnostic and mitigation
services offered by private companies
in California.
The program coordinates other state
IAQ activities through an Interagency
Working Group. The group consists of
representatives from state and local
agencies, private companies, and
environmental groups; it meets at least
quarterly. State agencies include the
Air Resources Board (ARB), the
California Energy Commission,
CalOSHA (Occupational Safety and
Health Administration), the
Department of Consumer Affairs, the
Office of the State Architect, the
Department of Housing and
Community Development, the
Department of Education, and the
Department of General Services. Many
of these agencies have minimal IAQ
resources.
An exception is the ARB. In 1986,
the legislature gave the ARB authority
to carry out exposure-assessment
research through extramural grants.
The ARB was required to assess both
indoor and outdoor exposures when
estimating the risks posed by
pollutants considered under the toxic
air contaminants program. Again, no
regulatory authority was included.
Notable research efforts, often in
cooperation with the CIAQP and
federal EPA, include: studies to
determine what percentage of time
Californians spend on various activities
in different environments (home, car,
work, etc.); and exposure assessments
for contaminants such as
formaldehyde, volatile organic
compounds, small particles, radon, and
polynuclear aromatic compounds. For
many of the pollutants studied,
exposures were found to be much
higher indoors than outdoors.
Although the largest programs are
those of the DHS and ARB, the other
agencies also explore ways to improve
IAQ. For example, CaVOSHA, with
technical assistance from CIAQP, has
promulgated a Minimum Building
Ventilation Standard that assures that
ventilation systems are not only
correctly designed and installed, but
are also properly operated and
maintained.
City and county governments play
an important role in improving IAQ by
adopting and enforcing local building
codes, by responding to citizen
complaints, and by adopting smoking
ordinances. Approximately 300 of 458
cities have significant nonsmoker
protection laws. CIAQP carries out
research to establish the efficiency of
various ETS exposure reduction
techniques in office buildings.
The State's Tobacco Control
Program, a multimillion dollar effort
funded by a 25-cents-per-pack cigarette
tax, attempts to protect the public
32
EPA JOURNAL
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through a strong education campaign
on the significant health aspects of
"involuntary smoking." Numerous TV,
radio, billboard, and newspaper and
magazine advertisements inform the
general public, particularly parents, of
the hazards of ETS. Funds are given to
local health departments to help them
educate local businesses, youth
organizations, and policy makers and
to assist them in developing legislation
to provide smoke-free environments.
Additionally, a competitive grants
process funds projects to inform the
public of ETS hazards through labor
unions, child-care facilities, and health
care facilities.
In 1993, Governor Wilson signed an
executive order banning smoking in all
public buildings. The order was
subsequently made into law. A law has
also been signed which bans smoking
in all licensed child-care facilities.
IAQ in California is also improved
through an unlikely mechanism,
Proposition 65. Among other features,
Prop. 65 declares that people may not
be exposed knowingly to significant
amounts of a toxic substance without
first receiving a warning. This includes
exposures from air, water, and
consumer products. A unique feature
of the law is that any individual or
group may inform the appropriate
authority (e.g., the Attorney General)
of their intention to sue a business that
they believe is in violation. If the
authority does not prosecute the
purported violator within 60 days, the
individual or group is allowed to
proceed with a suit and, if it is
successful, they will retain a portion of
the penalty provided by the law.
Proposition 65 declares that people
may not be exposed knowingly to
significant amounts of a toxic
substance without first receiving a
warning.
A 1989 consumer product case
illustrates how the process works. It
involved a product many clerical
workers and graphic artists use
regularly, namely typing correction
fluid. The case was initiated by an
environmental group, which claimed
various manufacturers were in
violation of the adequate warning
provision of Prop. 65. The group
alleged that the manufacturers'
products contained amounts of
trichloroethylene (TCE) sufficient to
cause significant cancer risk to
consumers using the product in a
reasonable way. The significant cancer
risk level is defined as one excess
cancer case per 100,000 people exposed
for a lifetime.
Chemical analysis of randomly
selected samples purchased from
retailers revealed that many of the
products did contain TCE in amounts
of about 30 to 50 percent by weight. Of
course, the question is not what is in
the bottle, but what is the consumer's
exposure. Prop. 65 simply refers to the
"level in question." The California
Health and Welfare Agency has
interpreted this to mean exposure
which is the result of reasonably
anticipated use at an average rate of
consumption by the typical consumer.
Although it can be argued that this is
still somewhat vague, it does make it
clear that exposure estimates are not to
be based on the worst possible
scenario.
The anticipated exposure was
estimated by simulating the use of
these products by a researcher in a
simulated office exposure chamber.
TCE was measured—using a personal
sampler as well as area samplers
located in various parts of the
room—throughout the day as the
researcher used typing correction fluids
under typical conditions. For example,
it was assumed that a typical use of the
product might involve correcting 10
standard type characters at a frequency
of one application every two hours
during the workday. The
measurements indicated a typical office
worker would receive an exposure
much higher than that which would
trigger the significant cancer risk under
Prop. 65 guidelines.
The Attorney General decided that
this was sufficiently high to proceed
with the case. Manufacturers decided
to reformulate many of the correction
fluids rather than face litigation.
Of necessity, a state IAQ program
will be complex and involve many
agencies and groups. It is important
that one organization be responsible
for coordinating the efforts and
assuring that important aspects of the
problem are not overlooked. In
particular, it is critical that IAQ
programs vigorously address the ETS
problem. An IAQ program that does
not make ETS a high priority is failing
to address a major public health
issue. D
By Bill Holbrook
Reprinted with special permission of King Features Syndicate.
OCTOBER-DECEMBER 1993
33
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IAQ: Whose Responsibility?
The problem is not energy conservation
by Hal Levin
A popular myth holds that energy
conservation measures,
implemented since the oil crises of the
1970s, cause indoor air pollution
problems. This myth ignores the fact
that most indoor air pollutant sources
have little or nothing to do with energy
conservation. In at least one study
conducted before 1973, the air inside
buildings was found to be more
polluted than outdoor air even during
severe air pollution events. In fact,
only two types of conservation
measures directly increase indoor air
pollutant concentrations:
inappropriately reducing ventilation
and using sealants and caulks that emit
pollutants.
The myth ignores the fundamental
responsibility (and ability) of architects,
engineers, and building operators to
create indoor environments that are
both habitable and environmentally
responsible. Achieving good indoor air
quality (IAQ) is as essential as
providing comfortable, healthy thermal
conditions and functional, aesthetically
sound lighting and acoustical
environments.
How Ventilation Affects IAQ
Changes in ventilation rates generally
affect IAQ only indirectly. What
directly impacts IAQ is the relationship
between ventilation and pollutant
sources. Consider the following three
factors.
First, there would be no indoor air
contamination if there were no
pollutant sources. The sources have
changed in number and kind during
the past 45 years or so; abundant,
harmful pollutant sources have
resulted from new building materials,
(Levin is a California research architect and editor
of Indoor Air Bulletin.)
34
furnishings, equipment, and consumer
products.
Second, thermal control has become
the dominant driving force in system
design. The need to maintain good
IAQ by adequate outdoor air exchange
has become incidental.
Finally, in the majority of buildings
with IAQ problems, ventilation
systems do not function as designed.
Many of these failures result from
problems in operation and
maintenance. As many as 75 percent
stem from design and construction
flaws because designers simply did not
place enough emphasis on IAQ.
Thermal Control vs. Air Quality
Historically, ventilation requirements
were set to maintain air quality. In the
19th century, before people began to
bathe frequently and use personal
deodorants, rates were specified to
keep human body odor at acceptable
levels. Traditionally, architects and
engineers designed mechanical or
natural building ventilation on the
basis of established outside air
requirements for assumed occupant
loads and activities in the building
program.
With the advent of variable air
volume systems in the 1950s, thermal
control objectives came to drive system
design. The shift became more
important as buildings became larger.
There was more space remote from the
envelope, or exterior, of the building
and concomitant lost access to daylight
and ventilation through windows. This
shift has led to the notion that "energy
conservation causes indoor air
pollution." At most, reduced air
exchange to conserve energy
exacerbates IAQ problems, but, for the
most part, the causes of indoor air
pollution are not the direct result of
energy conservation.
Determining Loads
Maintaining a healthy, safe, and
productive environment requires that
ventilation be sufficient to maintain a
quality. The amount of ventilation
required depends on the occupant
density, the types of activities that tal
place in the building, and the strengt
of pollutant sources (from equipment
building materials, and consumer
products). Since these factors vary
independently, it is difficult to provid
universally applicable ventilation rate:
The American Society of Heating,
Refrigerating, and Air Conditioning
Engineers (ASHRAE) sets minimum
ventilation values, but these assume r
"unusual sources" of indoor pollutant
The burden is on designers to
determine the nature of pollutant
sources and whether they require moi
than the recommended minimums.
Sources of Indoor Air Pollutants
There are many sources of pollutants
in buildings, and they vary
considerably from building to building
For that reason, addressing these
sources effectively must be part of the
design process. Simply following the
general guidance for ventilation as a
means of controlling pollutants means
choosing the default solution; it does
not represent the best effort of a good
designer.
It is important to understand the
relative contributions of various
sources and to address the strongest
ones. We must go after the ones with
the most surface area, the most mass,
and the emissions that we know or
believe to be most irritating or toxic.
Emissions from new building
materials far exceed emissions from
aged materials. However, maintenance
refinishing, and replacement activities
do result in significant increases in
EPA JOURNAL
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The fundamental responsibility of architects, engineers, and building operators is to create
habitable indoor environments.
Mike Bnsson photo
pollutant emissions. Therefore, the
durability of a material impacts IAQ
significantly. It is important to note
that "wet" products such as paints,
adhesives, caulks, cleaners, waxes, and
polishes emit very large fractions of
their mass into the building air, and
usually soon after application.
However, even after these products are
functionally dry, they continue to emit
very slowly for a very long time.
In the past 40 years, building
materials have changed in ways that
make them stronger sources of indoor
air pollutants than "traditional"
materials. For example, composite
wood products have replaced solid
wood materials, bringing binders,
adhesives, and other chemic.il
additives indoors. The best-known and
perhaps most widely used examples
are particleboard, plywood, and other
composite wood products based on
urea-formaldehyde resins. Fortunately,
these resins are being replaced by more
stable phenol-formaldehyde resins, and
some manufacturers are developing
and even marketing products that use
no formaldehyde-based resins at nil.
New low-emitting adhesives are now
available for installing flooring
products. Paints that use far less
organic solvent are also becoming more
common. However, replacing a strong
emitter with a nondurable,
low-emitting product may result in
more maintenance and replacement.
This can mean more frequent,
short-term emissions. Durability can
therefore be a very important
determinant of IAQ.
Architects' and Designers' Roles
Architects and designers can
substantially reduce indoor air
pollution by proactive!}' minimizing
undesirable sources. They can limit
chemicals with known toxic effects to
levels that will not cause adverse
reactions. For example, the California
Air Resources Board recommends that
formaldehyde levels not exceed 50
parts per billion. Since it's known that
most particleboard, plywood,
hard-board fiberglass insulation batts
and boards, some textiles, and many
other building products emit
formaldehyde, architects and designers
must try to limit their quantities, select
lower-emitting products, or choose
substitute materials. They can calculate
emissions from these products based
on test data. Knowing ventilation rates,
they can estimate formaldehyde
concentrations in indoor air and
change specifications if necessary.
This approach, although it seems
rather unscientific and not very
specific, is, in fact, similar to the way
we design illumination and acoustic
and thermal control. This brings us
back to our title topic. We don't say
that energy efficiency causes poor
lighting or visibility problems in
buildings; instead we determine what
lighting levels are necessary to perform
the task for which the building is
designed and built, then we attempt to
achieve those levels in an
energy-efficient manner. We must
recognize the need to apply the same
approach to IAQ. c
OCTOBER-DECEMBER 1993
35
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Lessons
From Radon
Consumers need user-friendty information
by Mary Nichols
When I joined EPA a few months
ago, I was struck by the
impressive public outreach program
that the Office of Air and Radiation
(OAR) had developed for radon. 1
believe the radon program has lessons
for other complex environmental
problems that have no immediate
regulatory solution.
Radon is a naturally occurring
environmental pollutant that poses
unique challenges for those who would
foster public awareness and concern.
You can not see, taste, or smell radon,
and it produces no immediate health
symptoms. EPA's challenge is to bring
together such diverse professionals as
risk communicators, scientists,
economists, lawyers, and politicians to
forge a common view ot the problem.
acuw er- ,. vev ui^ — , ;n /MILW. i
of homes au" ,nungca^cv ; u p^l —I
J^g^^K-S
-------
To meet the difficult challenge radon
presented, OAK's Radon Division
developed working relationships with
national nonprofit groups who share
our mission. These groups hove
well-established communication
networks with their memberships for
advancing their goals. Such diverse
groups as the American Lung
Association, the Advertising Council,
the National Association of Counties
(NACo), the Consumer Federation of
America, the National Association of
Homebuilders, and the National Safety
Council have joined with EPA to
reduce radon health risks.
The diverse priorities, purposes, and
ideologies of these groups could be
seen as a challenge to forward
progress; however, EPA saw this
diversity not as an obstacle but as an
opportunity to enrich the radon
program. Great care was taken to build
strong relationships based on mutual
trust and to discourage potential
conflict. A key to success: EPA and its
partner groups all share the same
mission and are committed to
achieving risk reduction. As part of the
process, partner groups continue to
look to EPA for vision and leadership
on how to best get bottom-line results.
Through this alliance, EPA has been
able to take advantage of
communication channels that it could
never replicate on its own. Every
group working with EPA disseminates
the radon message through its own
established channels to reach its
constituency. These partners wield
authority in their fields and are ideal
for addressing the concerns of their
audiences. For example, the American
Medical Association has its own means
of addressing physicians through the
Journal of American Medicine, AM
NEWS, American Medical Television,
and continuing education conferences.
Similarly, the National Medical
Association and the National Coalition
of Hispanic Health Services
Organization use newsletters,
conventions, special publications, and
community outreach to bring the
message to African-American and
Hispanic communities less likely to
hear about radon through the
mainstream media.
(Nichols is EPA's Assistant Administrator tor Air
and Radiation.)
Cooperating groups can influence
state or local public policy on radon
risk reduction or can convince
individual homeowners to test and
repair. For instance, NACo sends the
message to local government officials
that they should be aware of radon so
as to help protect public health and
forestall costly and difficult mandates.
NACo's communication channels
include newsletters, workshops, grant
programs, public service
announcements, and national
conferences. The association has
developed a Radon Advisory
Committee to tap into their extensive
membership network of more than
12,000 county officials in very diverse
communities across the country. In
turn, these officials can use their strong
ties with local community programs
and networks to reach millions of
county citizens. One of the big benefits
of working with these organisations is
their ability to target high-risk
populations and areas at the local level.
Despite the difficulties inherent in
communicating the radon issue,
substantial accomplishments have been
made. Kentucky's public health clinics
are a shining example of how one
simple change can be leveraged into
significant gains. Viola Brown, chief
state nurse, amended the state's
medical history forms to include a
question about whether patients had
tested their homes for radon. If not, a
public health nurse would then explain
radon risks and present a brochure on
how to test a home cheaply and
quickly for radon. With one simple
change in a form, some 70,000
Kentucky citizens are now being
reached every year.
Each partner, often an influential
leader in the community, knows the
best way to reach local individuals.
Homeowners who might ignore a
message from the federal government
will receive reminders from a partner
organization or from other sources—a
nurse or doctor, a builder, home
inspector, realtor, county or city
government, teacher, or the media.
This process of repeating and
reinforcing a message has been used
effectively by other public health
programs, like smoking cessation,
seat-belt use, and promotion of smoke
detectors.
EPA has also benefitted from
partnerships with the business
community. One of the first was with
the Advertising Council, a group that
acts as a conduit to bring Madison
Avenue talent together to create public
service campaigns.
Radon public service announcements
have been produced for use in
television, radio, print, and direct mail
campaigns. The estimated value of
media air time and print placement
donated to carry the radon message
now tops $100 million, according to Ad
Council figures. Another program,
created by the Ad Council and
sponsored by the National Safety
Council, uses direct marketing
techniques to offer consumers
discounted radon testing sen-ices, then
evaluates consumers' response to
varied radon messages.
The Results
Organizing diverse national, state, and
local interests in a voluntary program
to meet an invisible public health
threat is not an easy way to approach
environmental problems, but the
results are gratifying.
In the six years of the program, EPA
estimates that more than nine million
homes have been tested for radon and
three hundred thousand have been
mitigated. Grassroots awareness and
support have produced real estate
radon disclosure laws in nine states,
and the real estate industry has
voluntarily adopted disclosure policies
in other areas of the country. The
relocation industry regularly requires a
radon test and remediation (if
necessary) as a condition of property
transfer. Based on discussions with
states and on EPA's national school
survey, it is estimated that about 20
percent of U.S. schools have been
tested for radon.
Increasingly, Americans are realizing
that their behavior as consumers has a
direct impact on their health and
environment, and they are seeking
user friendly information to help them
act. Governments, in turn, are lacing
up to the political and financial costs of
mandating and enforcing citi/rn
behavior and are searching for
innovative nonregulatory tools. The
lessons gleaned from our success with
radon point to an important untapped
resource in reaching national
environmental goals within the
confines of today's resource realities. D
OCTOBER-DECEMBER 1993
37
-------
The View From Congress
We can no longer overlook the indoors
by Representative Henry A. Waxman
Today's growing awareness of indoor
••-environmental hazards reminds me
of an old Liza Minnelli song—the one
about Shirley Devore, who "travelled
'round the world to meet the guy next
door."
Since the first Earth Day over 20
years ago, the environmental
movement has been fighting problems
caused by industrial pollution, like acid
rain, polluted rivers, and toxic waste
dumps. These battles have produced
landmark laws, like the Clean Air Act
and the Clean Water Act, from which
the public has benefited
immeasurably.
But like Shirley Devore discovering
the guy next door, many experts are
now realizing that some of the greatest
environmental threats to health are
those closest to home. The new
frontier for F.PA has become the great
indoors.
Indoor pollution problems are
serious and widespread. According to
the Centers for Disease Control (CDC),
the most common and societally
devastating environmental disease of
young children, lead poisoning, is
caused by hazards hidden inside
millions of American
homes—deteriorating lead paint, high
levels of lead in household dust and
soil, and contaminated drinking water.
As many as three million
children—one out of every six—have
enough lead in their blood from these
sources to cause subtle brain damage,
including a loss of IQ.
Another indoor environmental
threat—exposure to secondhand
tobacco smoke—is the third leading
cause of premature death in the United
States, killing over 50,000 Americans
each year, according to the Surgeon
General. Secondhand smoke is also a
(Representative Waxman (D-California)
chair* tiic House Subcommittee on Health
and the Environment.)
severe threat to children, causing
hundreds of thousands of cases of
bronchitis and pneumonia each year.
Up to a million asthmatic children
suffer attacks when exposed to tobacco
smoke; many cannot lead normal lives
because of the risks of encountering
tobacco smoke in public places.
One of these asthmatic children,
nine-year-old Michelle Dart, told my
subcommittee earlier this year what
exposure to secondhand smoke means
to her: "I get dizzy, I start to sneeze, 1
can't breathe very well, and sometimes
... 1 get too much smoke in my lungs
and go into the hospital." No air
pollutant—especially one that is so
easily prevented—should ever be
allowed to cause so much harm to an
innocent child.
A third indoor pollutant, radon gas,
which seeps into homes from soil, is
the second leading cause of lung
cancer in the United States. According
to EPA and CDC, it causes 14,000 lung
cancer deaths each year—more deaths
than drowning, fires, and airline
crashes combined.
Peeling paint Under
the Lead Hazard
Reduction Act. realtors
and landlords will have
to provide information
on lead hazards before
they sell or rent
homes.
EPA JOURNAL
-------
Children are especially susceptible to environmental hazards The author believes Congress should enact
legislation to improve the indoor environments of schools and day care centers
Mike flr.'SSOn i
An important precedent was set in
1992, when Congress enacted the Lead
Hazard Reduction Act, one of its first
substantive efforts to address an indoor
environmental threat. Under this law,
EPA is expected to issue a regulation
by October 1995, requiring realtors and
landlords to provide home buyers and
renters with information on lead
hazards before they move into a home;
the parties involved must sign
disclosure forms acknowledging
awareness of any lead hazards; and
home buyers will be allowed a 10-day
inspection period. Moreover,
home-remodeling contractors and the
burgeoning lead abatement industry
will be licensed and regulated to
prevent the creation of new lead
hazards and insure the proper cleanup
of old ones.
This year, Congress has accelerated
its efforts to safeguard the indoor
environment, with three major pieces
of legislation pending in the House.
Under Administrator Carol Browner,
EPA has become a full
partner—indeed, often a leader—in
these efforts.
The first bill, the Smoke-Free
Environment Act of 1993, would
guarantee all Americans a smoke-free
environment bv prohibiting smoking in
buildings accessible to the public,
except in designated, separately
ventilated smoking rooms.
This is an opportunity we cannot
afford to miss. For virtually no cost,
the bill would save tens of thousands
of lives and protect hundreds of
thousands of children each year, not to
mention the building fires and
maintenance costs, which would be
reduced. By providing nationwide
protection, the bill would eliminate
countless battles for smoking
restrictions at the local level.
The second bill, the Radon
Awareness and Disclosure Act of 1993,
introduced by Representative Ed
Markey (D-Massachusetts), applies
ideas embodied in the 1992 Lead
Hazard Reduction Act to reduce radon
risks. Under its market-based
approach, home buyers would be fully
informed of the risks of radon and
have an opportunity to conduct an
inspection before signing a contract.
This approach has achieved
considerable consensus, being
supported by the Consumers
Federation of America, the National
Association of Realtors, and the
National Association of Home Builders.
The third bill, the Indoor Air Act of
1993, introduced by Representative Joe
Kennedy (D-Massachusetts),
establishes a national framework for
addressing indoor air problems other
than secondhand smoke and radon. It
calls upon EPA to identify common
indoor air hazards—levels of individual
pollutants or faulty ventilation
systems—then issue guidelines for
identifying, eliminating, and
preventing them. If the voluntary
guidelines do not succeed in protecting
the public, EPA would have the
authority to take appropriate regulatory
action. For the third Congress in a
row, Senator George Mitchell's
(D-Maine) indoor air bill has passed
the Senate, The Kennedy bill finally
provides a viable legislative vehicle for
House action.
Beyond these important measures,
Congress should also enact
comprehensive legislation to improve
indoor environments in schools and
day care centers. Children are
especially susceptible to environnuMit.il
hazards, and recent hearings ol my
subcommittee have found that many
schools and day care centers harbor
hidden environmental hazards. In NVw
York City, for instance, thousands of
classrooms—nearly one out of every
four—has a lead hazard. Nationwide,
one out of every five schools has at
least one classroom with an elevated
radon level.
For too long, federal environmental
policy has overlooked the
environmental hazards lurking in our
homes, schools, and offices. For the
sake of the millions of Americans
afflicted by these contaminants, now is
the time for a change, Q
OCTOBER-DECEMBER 1993
-------
FEATURING EPA\
Simulating a
Radioactive
Release bB Ml
by Brad Nelson
From the safety of a hotel conference room,
officials play out a scenario
An insistent beeping pierced the
sleep of the off-duty
EPA Radiological Response
Coordinator. The SkyPager on the
table across the room displayed the
phone number for the National
Response Center. It was 4:00 a.m. in
Washington, DC. The center always
waits for the work day to begin before
making routine notifications, so this
had to be an emergency. The
coordinator, groggy with sleep,
stumbled in the dark to the telephone
and dialed the center's number.
The National Response Center,
located at Coast Guard Headquarters in
Washington, is staffed 24 hours a day,
seven days a week. The- senior officer
on watch took the coordinator's call
and relayed the news: The Emergency
Preparedness Directorate of the
neighboring country to the north had
just reported an incident at the Boom
Nuclear Power Station (NPS). A major-
radiological release was probable. The
power station was just across the
international border from the U.S.
town of "Spaburg" (see map). The
coordinator took down all the
information the center had, requested
that the officer follow up his oral
report with a fax, and hung up.
This was big. At worst, thousands of
people would have to be evacuated on
both sides of the border to prevent
them from receiving hazardous doses of
(Nelson is u Nuclear Engineer fur EPA'sEmergency
Ki's/Kiusc Section, Office of Radiation and Indoor Air.)
radiation. At best, it was still an
international incident that would be all
over the news in a few hours.
The coordinator called the
Emergency Preparedness Directorate
across the border to confirm the report
and get additional details. As it
happened, a fire in a switchboard at
Boom NPS had caused the loss of
several power supplies, leading to
emergency shutdown of the reactor.
There was a loss of primary coolant,
with an increasing radioactive
contamination level in the containment
structure. Boom officials had informed
authorities that, in the worst case, the
uncovering of radioactive fuel could
occur in about five hours—around 9:00
a.m. The containment was designed to
hold contamination during just such an
accident. However, to be safe,
government authorities had based their
assessment of the offsite consequences
on containment failure.
The coordinator next called the head
of the radiation control program in the
U.S. state nearest the accident to
confirm that state personnel had been
notified of the incident by their
neighboring province. They had.
Then, since under the Federal
Radiological Emergency Response Plan
EPA is the lead federal agency for
foreign radiological emergencies which
could affect the United States, it was
time to take charge, get the word out,
and prepare for the worst. As the lead
agency, EPA would handle all technical
details, including monitoring and
recommending public actions, whereas
the Federal Emergency Management
Agency would handle all
administrative matters.
The coordinator phoned his
superiors to describe the situation;
Administrator Browner would inform
the President. Calls to the Nuclear
Regulatory Commission (NRC)
Operations Center and the State
Department revealed that they had
already learned of the incident.
The Chemical Emergency
Preparedness and Prevention Office
(CEPPO) activated the EPA Emergency
Operations Center and assigned staff
to continue the notifications to other
EPA offices and other federal agencies.
The coordinator jumped into some
clothes, grabbed a couple of bagels,
and headed for the EPA center, located
in the basement of EPA Headquarters
at Waterside Mall.
Calls to the regional radiation
program manager and to the state
radiation program manager revealed
that the state was planning a
preemptive evacuation of Spaburg
because of deteriorating conditions at
the power plant. If officials waited
until they were absolutely sure a
release would occur, there wouldn't be
time to move people. The state was
doing the right thing, according to
guidance published by EPA, so the
coordinator agreed with the evacuation
decision. However, the neighboring
foreign province was keeping its
citizens at home until officials were
sure of the release. That was going to
be tough to explain to the public; they
all watched the same TV channels and
listened to the same radio stations.
The director of EPA's Office of
Radiation and Indoor Air (ORIA)
arrived at the Emergency Operations
Center just as CNN was breaking the
story. After being briefed by the
coordinator, she called Administrator
Browner to report the latest
developments and to lay out ORlA's
response strategy, which was to
activate the Federal Radiological
Emergency Response Plan and
establish a Federal Joint Information
Center. EPA would then work with the
Department of Energy to airlift the
Federal Radiological Monitoring and
Assessment Center's staff and
equipment to the scene to monitor the
anticipated plume.
40
EPA JOURNAL
-------
• 'rentier
Provincial State boundary
• .. 5 [ai
Measurement stations
Meanwhile, additional emergency
response staff from ORIA and from
CEPPO reported to the emergency
operations center. They exchanged
information and made arrangements
for the monitoring teams. Their faces
became sober as they monitored the
incident, gave advice to the state, and
directed the response to an event
which might seriously impact the
United States but which they could not
control. They worked together with
their counterparts across the border,
drawing upon relationships and
knowledge gained from training
exercises they had hoped they would
never have to use. The wall clock
unreeled the hours as if driven by a
falling weight.
At noon, EPA was informed that the
Boom Station's containment had failed,
and a significant radioactive release
had begun. However, the release was
smaller than worst-case predictions. At
1:30 p.m., word came that nuclear fuel
cooling had been restored and the
containment leak identified. By 2:00
p.m., containment integrity was
reported restored.
By 4:00 p.m., the invisible
radioactive plume from the release was
already beginning to fall out and
dissipate. That was the worst of it. The
Department of Energy had a plane
tracking the cloud and sending data to
a computer at a ground location out of
the plume pathway. At the request of
the neighboring country, the plane, like
the plume it was tracking,was ignoring
the international boundary. In a couple
of hours,the computer would print a
dose-contour map that combined the
aerial survey results with Global
Information System data already in its
memory.
The survey indicated that the release
was not as extensive as projected. That
was not unusual. Predicting within a
factor of 10 was considered a success.
Further, it was better to err on the side
of caution. It was easier for the
Governor to tell citizens that their 100
mile round trip in the family car wasn't
necessary than to tell them that their
children's lifetime cancer risk was now
higher than it was 24 hours ago.
During the next few days,
monitoring teams on the ground took
surveys and analyzed samples to verify
the results of the aerial survey. They
also measured concentrations of
specific isotopes in the soil, in drinking
water supplies, and in livestock forage.
Emergency workers, public health
officials, and agriculture experts on
both sides of the border worked to
analyze the growing mass of data and
to make sense of it to the public.
Most of the people who had been
evacuated were given permission to
return to their homes. However, those
who lived within a two-mile radius of
Boom NPS would not be allowed to
return right away, nor would those in
a similar area 15 miles away where
precipitation had occurred and the
plume had been "rained out" onto tin-
ground.
The above scenario was played out in a
hotel conference room In/ representatives
from EPA and other federal agencies,
Canada, the State of New York, the
Nuclear Regulatory Commission, and the
departments of State, Energy, Agriculture,
and Health and Human Services. The
intense day-long session was conducted by
ORIA last May. It was one of more than a
dozen identical exercises conducted this past
spring In/ Nuclear Energy Agency (\t',.-\i
member countries to increase their
preparedness and to identify deficiencies in
international radiological emergency
response. The players concentrated on
notification and communication, protective
actions for people, safeguards for food and
agriculture, and international assistance.
A follow-up meeting to present the
results of all NEA exercises was held in
Paris in June 2993. Of particular interest
to other countries was the unique
participation by the United States and
Canada in each other's exercises. To
maintain the readiness of governments to
respond to such disasters, another exercise
is recommended two years hence. ^
OCTOBER-DECEMBER 1993
41
-------
FOR THE CLASSROOM
A Lesson Plan on
Indoor Air Quality
by Stephen Tchudi
To the Teacher: Discussing
indoor air quality (IAQ) is as
relevant to our lives as our next
breath. The difficulty in studying
it comes from the fact that much
indoor air pollution is invisible,
a point made in several of the
classroom activities that follow.
However, a great deal of
scientific information is available
on visible and invisible indoor air
pollution, not OH/I/ in this issue
of EPA Journal, but through
myriad leaflets, brochures, and
pamphlets provided In/
government and public-service
agencies. To prepare for this
unit, have students write in
advance for information from
the agencies listed at the close of
this article. In addition, contact
(or have your students call) your
city, county, or state
public-health agencies as well as
hospitals and university
extension services in your region
and ask for available materials on
IAQ. As the literature flows into
your classroom, you might have
individuals read up on one topic
or another—e.g., passive
smoking, radon, asbestos,
ventilation—thus becoming the
class expert. Or you might
simply store the materials and,
after the opening exercise below,
pass out the literature and invite
the students to delve into the
reading to accompany your choice
of the following activities.
Beginning the Unit
Read or paraphrase the following script
aloud and have the students do some
"deep breathing" exercises.
"Take a deep breath and hold it. Did
you know that when you breathe in,
your lungs take in billions upon
billions of air molecules? Now breathe
out!
"Breathe in. Did know that along
with air, each lungful you inhale can
contain hundreds of pollutants?
Breathe out.
"Breathe in some air. It may contain
cigarette smoke, tiny airborne insects,
dust, carbon monoxide, viruses and
bacteria, fungi, and chemical fumes.
Breathe out.
"Breathe in. Did you know that
evidence of smoky, bad air has been
found in the mummified lungs of
people who lived hundreds, even
thousands of years ago? Breathe out.
"Breathe in. Did you realize that in
our time, there are more harmful
pollutants in the air than ever
before—chemical, biological pollutants,
things that cause allergic reactions,
poisons? Breathe out.
"Now can anybody tell me why it
might be important for us to study
Indoor Air Quality—or what we call
IAQ?"
[At this point, present an overview of
the different kinds of IAQ topics that
students might study. You can use this
issue of EPA Journal as a guide. Also
especially helpful is EPA's Introduction
to Indoor Air Quality: A Self-paced
Learning Module (see Places to Write.)
This would also be a good time to
show Air Pollution: Indoors. (See
Videos.)]
(Tchudi is Professor of English at the
University of Nevada, Reno, and lias a long
standing interest in interdisciplinary and
environmental education.)
-------
• It's iii the Air. To help the students
get a sense of the visible pollutants in
the air, try this experiment adapted
from Julianne Bochinshki's Complete
Handbook of Science Fair Projects (New
York: John Wiley, 1991). Draw a
two-inch circle on each of a dozen or
so blank index cards; then spread a
thin layer of petroleum jelly in each
circle. Next, place the index cards at
various places around the classroom
and/or the school where they will not
be disturbed: on the teacher's desk,
near a window that is opened
regularly, near a heat register or vent.
Write the location on the card. After 24
and 48 hours, have the students look
at the sticky circle with a magnifying
glass and discuss what kind of stuff
has accumulated. Point out to the
students that (1) this is only a measure
of visible pollutants, and (2) their very
own breathing passages and lungs,
which have mucous linings, can collect
visible pollutants in much the same
way.
• The Smoking Debate. Have students
collect and analyze advertisements
from tobacco companies. First, have
them study the warning labels of
cigarette advertising: What sorts of
illnesses are discussed in the Surgeon
General's warnings? Second, to get
another side of the story, have your
students write to various tobacco
companies (their addresses can be
found in the advertisements) asking for
their side of the active and passive
smoke inhalation debate. Students can
compare and contrast the companies'
literature with that supplied by EPA,
the Surgeon General, and groups like
the American Lung Association. For
additional information, students might
contact city agencies and/or
restaurateurs to get their points of
view. Finally, have the students stage a
debate on the IAQ aspects of smoking.
Should smoking be banned in all
public places? In some? In none?
• Rndon Detection. Through the yellow
pages, locate a firm that specializes in
radon detection and/or the commercial
reduction of radon rates. Or call your
local health agencies to find someone
who is a specialist in this area. Invite a
speaker to the class to explain what
radon is, what it does, how it can be
detected, how it can be eliminated.
(See also the useful video on this topic,
listed under Videos.) On the basis of
the presentation, have your students
develop leaflets or fliers or simply a
letter to the adults at home
summarizing their knowledge and
advising how best to deal with radon.
• The Ston/ of a Flame. Light a
household candle and have a student
hold a light-colored ceramic plate about
six inches above the flame. Then have
the students take a peek at the visible
pollutants collecting on the bottom of
the plate. Extinguish the flame and
quickly place a match about two inches
above the wick in the rising plume of
smoke; students will see the flame
travel down the unburned participates
of the smoke to relight the candle. Use
these demonstrations as a jumping off
point for a discussion of indoor
pollution created by appliances that
use flames from gas, kerosene, or
wood products: stoves, furnaces, water
heaters, fireplaces, charcoal grills.
Remind them that although flames in
appliances often burn more cleanly
than a candle, each of these is
producing various invisible byproducts
of combustion. Gather instructions and
operating manuals from flame
appliances (those leaflets you stuffed
away in a drawer or put on a shelf
near the furnace) and discuss the
consumer advice that is given there.
End this lesson with a detailed
discussion of the need for proper
ventilation and use of flame-powered
appliances.
• Protection Masks. Have student
volunteers go to a hardware store and
study the instructions and fine print on
air filters, face masks, and respirators.
What protection does a breathing mask
or filter offer a user? Is it a good idea
to use one while, say, sanding down a
floor or jogging on a smoggy or cold
day? What myths and facts can the
kids learn about respirators? How often
should a furnace air filter be replaced?
(As a shocker, bring in a used furnace
air filter, especially if, like most of us,
you don't change the filter at the
recommended intervals.) As a
follow-up, students might put in a call
to the fire department to learn about
how fire fighters protect themselves
from both visible and invisible
pollutants at a fire or accident scene.
• Under the Rug. Students may be
surprised to learn that new carpeting is
a source of pollutants, both from the
chemicals used in the creation of most
carpets and from the adhesives that are
frequently used to hold the carpeting
in place. A visit to a carpet store can
help students learn about a new
consumer information label being
placed on carpets concerning IAQ.
Places to Write
U.S. Environmental Protection
Agency, IAQ INFO, P.O. Box 37133,
Washington, DC 20013-7133.
Telephone 800-438-4318; American
Lung Association (write or phone your
local office); Centers for Disease
Control, Mail Stop K-50, 4770 Buford
Highway, Atlanta, GA 30341; Gas
Appliance Manufacturers Association,
1901 N. Moore Street, Suite 1100,
Arlington, VA 22209; National Cancer
Institute, Building 31, Room 10A24,
Bethesda, MD 20892; National Heart,
Lung, and Blood Institute, Information
Center, 4733 Bethesda Avenue, Suite
530, Bethesda, MD 20814; National
Institute for Occupational Safety and
Health, 4676 Columbia Parkway,
Cincinnati, OH 45226-1998; National
Kerosene Heater Association, 3100
West End Avenue, Suite 250,
Nashville, TN 37203; U.S. Consumer
Product Safety Commission,
Washington, DC. 20207; Wood Heating
Alliance, 1101 Connecticut Avenue,
N.W., Suite 700, Washington, DC.
20036.
Videos
Air Pollution: Indoors', Radon. Princeton,
NJ: Films for the Humanities, 1988. u
-------
CHRONICLED
Legendary Pest Remedies
Miss Muffet should have asked her father
by Christine L. Gillis
Little Miss Muffet sat on a tuffot
her curds and whey. There came a big
spider who sat down beside her and
frightened Miss Muffet away.
—17th century nursery rhvme
Legend has it that little Miss Ntuftel
was the daughter of a real-life
entomologist and "doctor in physick,"
one Thomas Muffel (alias MoulTet or
Moffet), who may himself have been
the author of the nursery rhyme. In
any case, Thomas Muffet is better
known in history lor having published,
in 1658, the first Hnglish work of
entomology. I he work is entitled /lie
Thi'iitrc O( Insects: Or, l.rs.xT Living
Cmifinrs. /is Hi'i's, /"/(Vs. CiJtci'fnlliU'f.
Spiders, Worm*, & C. A Mcs/ Llub^mtc
Work (1028 pp.), and it proffers a host
of "remedies" for getting rid of
unwanted spiders and the like. Clearly,
pest control has been an issue over the
centuries.
So what were some of the pest
remedies recommended by the good
Doctor Muffet? Dr. Muffet notes that
"for as Virgil hath it in his Georgicks:
The weevil spoils a mighty heap of
corn." Thus, lor weevil infestations in
corn, the prescription is as follows:
"Against Weevils, that are a certain
plague to Corn, it is good to dawb the
walls [husks] with lime and hair both
within and without." Alternatively, the
weevils might be persuaded to leave if
you "sprinkle on salt water where
Garlick hath been infused, or Hops,
Elder-leaves, worm-wood, Rue, Migella
feed, wilde mints, Walnut leaves,
Savoury, Lavender, Southern-wood,
Flea-wort, Bean trifoly, boyld [boiled]
in vinegar ot squills."
To control nematodes in fig
orchards, Dr. Muffet suggests "ashes
laid to fig trees, drive away worms, for
it hath the force of salt, though not so
(Gillis is ivi Assistant Editor of HI'A Journal on
ttftail from the Office i>{ I'estk'iile Programs.)
• l-l
strong." With remedies such as
"pouring often upon the roots, Bulls
gall, and lees of Oyl...," says the
doctor, "Peaches, Pomegranates,
Quinces, Pears, Apples, Olives, and
Okes, and other trees are kept sound a
long time, and almost free from
worms." Problems with spiders? The
good Dr. Muffet dedicates several
chapters to getting rid of arachnids.
By the 18th century, according to
James Whorton, author of Before Silent
Spring: Pesticides & Public Health in
Pre-DDT America (1974), "there had
accumulated a veritable
'pharmacopoeia' of insect remedies that
leaned quite heavily on herbal and
animal preparations similar to those
which dominated the official lists of
drugs for human illnesses." Organic
insecticidal preparations such as
ground tobacco, the Pyrethrum flower,
and organic plant materials containing
rotenone continued to be widely used
in the 19th century. (In the last decade
of the 20th century, Pyrethrum-based
and rotenone-based insecticides are still
widely used—for example, in pet
sprays, industrial sanitation sprays,
and products to protect stored foods in
warehouses.)
Most popular in the mid- 19th
century were inorganic pesticides such
as the so-called Paris Green and
London Purple products, both of
which belong to a group of compounds
called arsenicals. The story goes that
the insecticidal properties of Paris
Green (composed of copper
acetoarsenite) were discovered by a
farmer who, after painting his window
shutters with the green paint,
discarded the remaining paint by
throwing it over his beetle-infested
potato plants. Whorton also notes that
Paris Green's rival, London Purple,
was a byproduct of the aniline dye
industry, and was composed largely of
calcium arsenite. For years it had been
dumped at sea (another story) because
of its toxicity and presumed
uselessness until the dye producer
began shipping packages of London
Purple to American agriculturalists for
testing as an insecticide.
The release of DDT during World
War II heralded the era of synthetic
pesticides. DDT gained popularity as a
pesticide for controlling insects on a
variety of crops, including cotton,
peanuts, and soybeans, among others.
But by 1962, due in part to the
publication of Rachel Carson's book,
Silent Spring, DDT became a widely
publicized topic of concern over its
adverse environmental side effects. In
1972, all of DDT's domestic uses,
except for public health and
quarantine, were canceled based on
studies confirming its deleterious
effects on the environment.
With the advent of DDT and the
post-World-War II era of chemical
pesticides, many organic remedies such
as Dr. Muffet's prescriptions fell out of
fashion. Now, half a century later,
there is a groundswell of interest in
reducing overall use of chemical
pesticides. The current administration
is developing a comprehensive
regulatory and nonregulatory strategy
designed to reduce pesticide use by
discouraging the use of higher risk
products and encouraging alternative
methods of pest management, such as
Integrated Pest Management and
Sustainable Agriculture, including
biological and cultural systems. Who
knows? Maybe some of Doctor
Muffet's remedies deserve
reconsideration. Q
EPA JOURNAL
-------
ON THE MOVE]
Michael Vandenbergh
Michael Vandenbergh is
EPA's new Chief of Staff.
He advises the'
Administrator on policy
and budgetary matters
and serves as White
House liaison for policy
matters. Vandenbergh
joined EPA as a Special
Assistant to the
Administrator in January
1993 and also served as
Associate Deputy
Administrator prior to
this appointment.
Vandenbergh is an
environment.it attorney
who has worked for two
private firms in
Washington, DC, Latham
& Watkins and Hogan &
Hartson, and for the
National Wildlife
Federation. Prior to
joining EPA, he was the
North Carolina Field
Director for the
Clinton 'Gore campaign
and Associate Counsel to
the Presidential
Transition.
Vandenbergh
graduated from the
University of North
Carolina at Chapel Hill
with a B.A. in /oology in
1983 and from the
University of Virginia
School of Law in 19K7,
where he was the
Editor-in-Chief of the
Virginia /.im' Rcivcic.
William Finister has been
appointed Deputy Chief
of Staff. He brings to the
position extensive
experience in
administrative
management, human
resources, budget, and
policy development and
implementation.
Finister joined F.PA in
1983 and since then has
served in several
positions in the Office of
Administration and
Resources Management
OCTOBER-DECEMBER 1993
William Finister
(OARM). From 1987 until
his present appointment,
he was Deputy Director
of the Office of
Administration.
Previously, he was
Director of the Facilities
Management and Services
Division (1985-1987),
Director of the OARM
Program Operations
Support Staff (1983-1985),
and Special Assistant to
OARM's Deputy
Assistant Administrator
(1983).
From 1970 to 1983,
Finister was a field
representative at the
Office of Management
and Budget, working
with state and local
officials to resolve
intergovernmental issues.
During this period, he
also served as the
Assistant Director for
Administration and
Management for the
Council on Wage and
Price Stability.
Earlier experience
includes work for the
Office of Economic
Opportunity and tor
VISTA. Finister served as
a Peace Corps volunteer
in the Philippines
(1961-1963).
He holds a B.S. in
Education from Duquesne
University (1958) and did
graduate work at the
University of San
Francisco.
Jean Nelson, FTA's new
General Counsel, comes
to EPA with extensive
experience in
administrative law,
genera! business
litigation, and
government, as well as in
environmental issues.
From 1989 until 1993,
Nelson was Chief Deputy
Attorney General lor tin-
Tennessee Attorney
General. There she
Jean Nelson
managed an office of 200
people (110 lawyers),
supervised legal work on
specific major actions of
the office, initiated
changes within the office
for more effective
execution of priorities,
and managed tight
budgets and
reorganizations within
the office. She also
worked with the Attorney
General in establishing
legal policy for the state
and as liaison between
the Attorney General's
Office and all parts of the
Tennessee state
government. During her
tenure as Chief Deputy,
she was a leader in the
National Association of
Attorneys General.
From'l979 to 1988,
Nelson was a partner at
the law firm of Gullett,
Sanford, Robinson and
Martin in Nashville,
Tennessee, and an
associate from 1975 to
1979. During that time,
she held leadership
positions in state and
local Bar activities and
numerous other
community organizations.
Her interest in the
environment led her to
serve as member of the
Executive Committee,
Southern Environmental
Law Center; Chair of the
Greenvvavs Commission
for Metropolitan
Nashville and Davidson
County; Board member of
the Tennessee
Environmental Council;
and President ot the
Environmental Action
Fund.
Nelson was Chief of
Staff for Tipper Gore in
the 1992 presidential
campaign. During the
1988 Gore-for-President
campaign, she served as
Tennessee Campaign
Manager and as delegate
Mary Nichols
to the Democratic
convention.
She received a B.A.
(1969) and a J.D. (1975)
from Vanderbilt
University.
Mary Nichols has been
confirmed as Assistant
Administrator for Air and
Radiation. She brings to
the Agency extensive
experience in
environmental law and
policy and public
administration.
From 1989 to 1993,
Nichols served as Senior
Staff Attorney and
Director of the Los
Angeles office of the
Natural Resources
Defense Council.
Previously, as one of
California's first
environmental lawyers,
she brought some of the
first test cases under the
federal Clean Air Act and
California air quality laws
while a staff attorney for
the Center for Law in the
Public Interest.
From 1979 to 1982,
under Governor Edmund
G. Brown, she chaired
the California Air
Resources Board, which
sets air quality and
automotive standards. In
that capacity, she
sponsored some of the
original research on
economic incentives for
emissions control. In
California, she also acted
as Secretary for
Environmental Affairs,
the cabinet-level agency
responsible for air, water,
and solid waste
management. Her public
service experience
includes being
Commissioner for the Los
Angeles City Recreation
and Parks (1984 to 1990)
and the city's Department
Lynn Goldman
of Water and Power (1990
to 1992).
Nichols, who has
written and taught widely
on environmental and
legal issues, received a
B.A. degree from Cornell
University in 1966 and a
J.D. degree from > ale
Law School in 1471.
Lynn Goldman is EPA's
new Assistant
Administrator for
Prevention, Pesticides.
and Toxic Substances.
A pediatrician and
epidemiologist, Dr.
Goldman previously
served in California's
Department of Health
Services as Acting Chief
of the Division of
Environmental and
Occupational Disease
Control. There she was
responsible for
environmental
investigations,
occupational health,
childhood lead-poisoning
prevention, and birth
detects monitoring. She
has written and
published extensively in
these areas.
Goldman, a fellow ot
the American Academy of
Pediatrics, is a member of
its Environmental Health
Committee. Prior to
joining F.PA, she was a
member ot the National
Research Council's Water
Science and Technology
Board and its Committee
on Environmental
Epidemiology. In
addition, she served as a
member of the U.S.
Centers for Disease
Control Advisory
Committee on Childhood
Lead Poisoning
Prevention.
Goldman received a
B.A. in Conservation of
Natural Resources in 1976
and an M.S. in Health
45
-------
Robert Pcrciascpe
and Medical Sciences in
1979 from the University
of California, Berkeley.
She also holds an M.P.H.
from John Hopkins (1981)
and an M.D from the
University ot California,
San Francisco (1981).
Robert Pcrciasepe, F.PA's
new Assistant
Administrator for tin-
Office of Water, is
responsible for the
national water quality
management program.
The program includes
water quality criteria and
standards; drinking water
criteria and standards;
National Pollution
Discharge Elimination
Systems (NPDFS) permits
for point sources of water
pollution; storm water
sources; and the polluted
rumill (nonpoint sonn el
control program.
In addition, Perciasepe
is in charge of linking
ecosystem management
with water quality
programs; the State
Revolving Fund program
for constructing
municipal waste water
treatment plants; and
working with the U.S.
Army Corps of Engineers
for wetlands regulation
and disposal of dredged
material.
Before joining the
Agemv, I'erciasepe was
Secretary of Maryland's
Department of
Environment (MDE) from
1991 to 1993, directing
pollution control and
environmental protection
for the state. Prior to
that, he served as MDF's
Deputy and Assistant
Secretary for Planning
and C'apital Programs.
Previously, he was
Assistant Director of
Planning for the City ot
Baltimore, covering
• li,
Klliott P. Laws
capital budget,
infrastructure, and
environmental issues.
Perciasepe also worked
with county and regional
planning agencies in New
York and at the State
University of New York.
He received his B.S. in
environmental sciences
from Cornell University
in 1974 and a master's
degree in planning from
the Maxwell School of
( iti/en.ship and Public-
Affairs at Syracuse
University in 1976.
Elliott P. Laws has been
appointed Assistant
Administrator for Solid
Waste and Emergency
Response.
Prior to his
appointment at the
Agency, he w.is a partner
specializing in
environmental law and
legislation and munkipal
representation at the law
firm of Pattern, Bc>££s &
Blow. There he focused
primarily on CERCLA,
air, water, and recycling
issues.
Before joining Patton,
Hoggs & Blow, Laws was
a trial attorney in the
Environmental Defense
Section at the U.S.
Department of Justice.
There he conducted
litigation primarily on
behalf of EPA but also for
other federal agencies,
including the
Departments of the Army
and the Air Force. His
representation of EPA
involved both District
Court and Court of
Appeals litigation under
Superfund, the Clean
Water Act, and other
environmental statutes.
From 1984 to 1985,
Laws was an enforcement
attorney with EPA's
Water Enforcement
Division.
Jonathan Cannon
Laws has been
Co-Chair of the
Environmental
Committee of the Bar
Association of the District
of Columbia (1991 to
1993) and is co-author of
several articles and books
on environmental issues.
He began his legal career
as an Assistant District
Attorney in New York
County (Manhattan). Ik-
is a graduate of
Georgetown University
Law Center (1980) and St.
John's University (1977).
He is a member of the
bars of New York and the
District of Columbia.
Jonathan Cannon is
Assistant Administrator
for the Office of
Administration and
Resources Management.
He brings a long,
distinguished career at
EPA to his new post.
In 1993, Cannon held
three top Agency posts:
Special Advisor to the
Administrator, Acting
Deputy Administrator,
and Acting Assistant
Administrator of the
Office of Policy,
Planning, and Evaluation.
From 1992 to 1993, he
was Director of EPA's
Gulf of Mexico Program.
Other Agency positions
he has held include
Acting Assistant
Administrator (1989) and
Deputy Assistant
Administrator (1988) of
the Office of Solid Waste
and Emergency
Response; Deputy
Assistant Administrator
(Civil), Office of
Enforcement and
Compliance Monitoring
(1987-1988); and Deputy
General Counsel,
Litigation and Regional
Operations, Office of
DtnLse Graveline
General Counsel (1987).
Cannon's non-EPA
background includes his
work at Beveridge &
Diamond, P.C. (1975 to
1986 and 1990 to 1992),
where he became a
partner in 1980, and his
service as law clerk to the
Honorable David L.
Bazelon at the U.S. Court
of Appeals, DC Circuit.
He graduated cum latiili'
from the University of
Pennsylvania Law School
in 1974 and was
Editor-in-Chief of the
Law Review. He attended
Oxford University's
Worcester College (1968)
and graduated from
Williams College with a
B.A., stounitt i'uin liuutt', in
1967.
Denise Graveline is the
new Deputy Associate
Administrator for
Communications.
Education, and Public
Affairs. Her background
includes extensive
experience in journalism,
policv research, media
and public relations, and
management and
budgeting.
She tomes to HI'A from
the American Association
for the Advancement of
Science (AAAS), where
she directed the Office of
Communications and
served as primary
spokesperson for the
world's largest general
scientific organization.
Her duties at AAAS
ranged from interpreting
and releasing research
findings from the
association's
peer-reviewed journals,
including SnVmv, to
successfully managing the
communications office's
budget. Among other
responsibilities, Graveline
directed production of
AAAS publications such
as Science Sources, a
popular annual directory
for reporters.
From 1987 to 1990, she
directed media relations
and served as primary
spokesperson for the
Robert Wood Johnson
Foundation in Princeton,
the nation's largest health
care philanthropy with
more than $2 billion in
assets. In this post, she
generated coverage hy
the print and broadcast
media on medicine,
education, health policy
and financing, and
philanthropy. As a
member of the
foundation's program
staff, she supervised
grants and contracts
related to news media,
including the PBS series
now called The Ht-altli
Quarterly.
As an independent
writer and consultant
(1984 to 1987), sin-
authored articles on
health and education for
magazines including
Keller Hume* and Gardens,
Ms., and l-'amily Circle-
Previously, she worked
as an editor and writer
for Whittle
Communications, a
national maga/ine
publisher.
She graduated inagna
cum laudc from the Boston
University School of
Public Communication
with a B.S in Journalism.
EPA JOURNAL
-------
Kathryn S. Schmoll
Kathryn S. Schmoll is the
Agency's new
Comptroller.
Before her recent move
to EPA, Schmoll was the
Assistant Associate
Administrator tor
Institutions in the Office
of Space, Science, and
Applications (OSSA) at
the National Aeronautics
and Space Administration
(NASA) At OSSA, she
performed a wide range
of business management
duties, institutional and
external relations
management functions,
and oversight oi all
human resources
activities for OSSA and
the Coddard Space Flight
Center.
Other positions held by
Schmoll in OSSA include:
Director of the
Administration and
Resources Division and
Acting Director and
Deputy Director of the
Mkrogravity Science and
Application Division.
Schmoll is a member of
several Agency-level
committees and boards,
including the Equal
Opportunity Council and
the Contract Adjustment
Board. She has received
numerous awards,
including the William A.
Jump Award for
Exemplary Service in
Public Administration,
the 1991 Outstanding
Achievement Award for
Women in Aerospace, a
1991 Presidential Rank of
Meritorious Executive,
and a NASA Outstanding
Leadership Medal in
1992.
Schmoll graduated
from Indiana University
in 1975 and recently
attended Harvard
Business School's
Advanced Management
Program.
r .
Kathleen Aterno
Kathleen Aterno has
been appointed Deputy
Assistant Administrator
for Management and
Administration in the
Office of Administration
and Resources
Management.
She previously held
positions as Acting
Executive Director and
Managing Director for
Clean Water Action from
1987 to 1993. There,
among other tasks, she
developed and
implemented budgeting
and financial systems,
organizational and
personnel policies, and
legislative and constituent
strategies.
In 1990, she was
Executive Director for the
Michigan Democratic
Party coordinated
campaign. In that
capacity, she developed
and directed statewide
campaigns for federal,
state, and local leaders.
From 1984 to 1985,
Aterno served as
Administrative Assistant
for Representative Bill
Richardson (D-New
Mexico). From 1977 to
1984, she was
Administrative Assistant
for Representative David
Bonior (D-Michigan).
Aterno graduated from
George Washington
University with a major
in political science and
earned a master's degree
in public administration
from George Mason
University, n
List of Contributors
Bob Axelrad (6607])
Indoor Air Division
Environmental Protection
Agency
401 M Street, SW.
Washington, DC 20460
Phone: (202) 233-9316
Fax: (202) 233-9555
Steve Bayard (8602)
Human Health
Assessment Group
Office of Research
and Development
Environmental Protection
Agency
401 M Street, SW.
Washington, DC 20460
Phone: (202) 260-5722Fax:
(202) 260-3803
Carol Browner
Administrator (1101)
Environmental
Protection Agency
401 M Street, SW. '
Washington, DC 20460
Phone: (202) 260-9828
Fax: (202) 260-0279
Fran Du Melle
American Lung
Association
1726 M Street, NW.
Suite 902
Washington, DC 20036
Phone: (202) 785-3355
Fax: (202) 452-1805
Brian Leaderer
John B. Pierce Laboratory
290 Congress Avenue
New Haven, Connecticut
06519
Phone: (203) 562-9901
Ext. 255
Fax: (203) 624-4950
Hal Levin
Indoor Air Bulletin
P.O. Box 8446
Santa Cruz, California
95061-8446
Phone: (408) 425-3946
Fax: (408) 426-6522
John R. Lott, Jr.
Wharton School
University of
Pennsylvania
Philadelphia,
Pennsylvania 19104-6372
Phone: (215) 898-8920
Fax: (215) 898-7635
Brad Nelson (6601J)
Office of Radiation
and Indoor Air
Policy and Emergency
Response Branch
Environmental
Protection Agency
401 M Street, SW.
Washington, DC 20460
Phone: (202) 233-9365
Fax: (202) 233-9629
(confirm at 202-233-9368)
Ken Sexton (8501)
Director, Office of
Health Research
Office of Research
and Development
Environmental
Protection Agency
401 M Street, SW.
Washington, DC 20460
Phone: (202) 260-5900
Fax: (202) 260-4997
Kirk R. Smith
Program on Environment
East-West Center
Honolulu, Hawaii 96848
Phone: (808) 944-7519
Fax: (808) 944-7298
Stephen Tchudi
University of Nevada
Department of English
Reno, Nevada 89557-0031
Phone: (702) 784-6728
Fax: (702) 784-6266
Lance Wallace
Environmental
Photographic
Interpretation Center
Office of Research
and Development
Environmental
Protection Agency
Vint Hill Farms Station
Warrenton, Virginia 22186
Phone: (703) 341-7300
Fax: (703) 341-7575
Robert G. Hansen
Amos Tuck School
of Business
Dartmouth College
Hanover,
New Hampshire 03755
Phone: (606) 646-2079
Curtis Havrnore
Rosemarie Odorn
Socio-Technical Research
Applications, Inc.
110 Wilson Boulevard
Suite 1700
Arlington, Virginia 22209
Phone: (703) 243-9863
Ext. 21
Fax: (703) 243-4975
Jennifer Jinot
Human Health
Assessment Group
Office of Research
and Development
Environmental Protection
Agencv
401 M Street, SW.
Washington, DC 20460
Phone: (202) 260-8913
Fax: (202) 260-3803
Mary Nichols (6101)
Assistant Administrator
for Air and Radiation
Environmental
Protection Agencv
401 M Street, SW.
Washington, DC 20460
Contact: Jeannine Tucker
Phone: (202) 260-7400
Fax: (202) 260-5155
Andrew M. Pope
National Academy
of Sciences
Institute of Medicine
Room FO-3034
2101 Constitution
Avenue, NW.
Washington D.C. 20418
Phone: (202) 334-1716
Fax: (202) 334-2939
Congressman Henry A.
Waxman
House of Representatives
Washington, DC 20515
Phone: (202) 226-7620
Fax: (202) 225-7092
Jerome Wesolowski
(deceased)
Environmental Health
Laboratory Branch
Department of Health
Services
2151 Berkeley W.iv
Room 334
Berkeley, California 94704
Office: (510) 540-2469
Fax: (510) 540-3022
OCTOBER-DECEMBER 1993
47
-------
LETTERS!
Progress or Illusion?
i agree with Mr. Nitre's
"four critical elements in a
successful technology
cooperation strategy"
mentioned in his article
entitled "Stopping the
Waste" lApril-June 1993
EPA Journal, pages 31-33). I
question, however, the third
reason he states as to why
it will be possible "to
reduce the average amount
of pollution and natural
resources depletion per unit
of income." He says, "the
richer industrialized
countries are already
moving in the direction of
more service-oriented, less
resource- and
pollution-intensive
economies, and a number
of developing countries are
beginning to follow.
Information processing and
telecommunications are
inherently less polluting
and resource intensive than
steel or paper
manufacturing."
Are the richer
industrialized countries
really using less paper and
steel, or have they just
exported the pollution of
manufacturing to less
developed countries? If all
countries are to move
toward "paper pushing"
(service), who is going to
do the paper
manufacturing? If you
manufacture less paper per
unit of income, but more
total paper (due to
increased total income), has
there really been any
improvement7 I agree that
technology itself is not the
problem, but it is important
to differentiate between real
progress in reducing
pollution and illusion
created because the
pollution is out of sight.
Mary Bergs
Resident Research
Associate
National Research Council
Athens, Georgia
\VilIinni A. \itzc /r/'/ics:
My colleagues ci( the Alliance to
Ni;v inergi/ and I share your
concern that the e\port of such
pollution is ii potential proMcin.
(Mil iMir rt'si'illV/l (ills tl'lllll/ IH)
evidence thut it if aclualhi
ng place, nl least Irotn the
United Slates. In our anuh/sis.
resource- and pollution-intensity
is declining in most countries,
including major developing
countries. For example. China's
energy intensity has dropped hv
about 3 percent per near for
almost 10 years. 7/n' real
prohlem is m>[ that richer
countries are exvorting pollution
to poorer countiies, but that the
oivratl lavl of pollution
runfiiiiit's to increase as the
global economy grows. The only
way to reverse tins trend is to
accelerate the decline in
pollution per unit of output on
a global basis. Achieving this
goal will in turn require more
rapid structural change and
deployment of green technologies
within and among richer and
poorer countries alike.
Access to Safe
Drinking Water?
I can't believe our nation
does not know the
percentage of users who
have access to safe water,
but all six others do on
your map displayed on
pages 8 and 9 of the
April-June 1993 EPA
Journal. I read on the front
page of USA Today
(September 27, 1993), that
"120 million may get
unsafe drinking water."
How does this relate to
"access to safe water (rural
population)?" Or can we
not agree on the definition
of safe water?
A subscriber named Bob
EPA Journal replies:
I igurcs lor Bangladesh, Hrazil.
China, Ethiopia, Romania, anil
y.iinbalnn' itvrc obtained from
Hit' sources cited on the map
(Thf 1993 Information I'lwise
Environmental Almanac and
the Atbs of the
Environment). A comparable
figure was mif niiiilable for
U.S. access to safe water (rural
population). Such a figure
would need to include the 15
percent of nil Americans U'ho
get their water from private
water wells. Because l.PA does
not have tin- authority to
regulate domestic U'clls, the
Agency is nut in a position to
generalize about the safety of the
wells serving this population.
As mentioned in the USA
Today article you cited, EPA
Administrator Carol Browner
docs indeed belinv drinking
water regulation should be
toughened. This administration
will be working with Congress
on legislation to improve the
nation's 200,OIK) public water
systems, of which the majority
sen'e under a thousand people.
Salute to Peace Corps
Experience
Thank you for the
wide-ranging discussion of
sustainable development in
the April-June 1993 issue of
EPA Journal. I was
surprised to note, however,
that no reference was made
to the work of Peace Corps
volunteers, particularly
when so many returned
volunteers work for EPA.
Contributors made valid
points about the
importance of capacity
building, local level
involvement in program
planning, dissemination of
appropriate technologies,
and the effects of
widespread poverty on the
potential success of
development strategies. For
most volunteers, however, I
suspect these were among
the first lessons learned in
the field.
It's been said that there
are probably as many
different volunteer
experiences as there are
returned volunteers, but
some common themes run
through our stories. Many
of us worked to reinforce
existing local community
networks, to empower
small groups to manage
their own resources, to
provide technical support to
local government agencies,
and to help people gain
access to credit that would
allow them to try new
technologies. We know that
some of the strategies
described in the Journal are
likely to succeed because
we have experienced their
successes first hand; we've
also learned, the hard way,
why some approaches are
more likely to fail.
I hope that EPA will look
to the returned volunteers
on its staff for practical
insights to sustainable
development at the
grassroots level, and
especially for input on
working with community
groups and local
government in other
countries.
Judi Brown,
Program Analyst
Planning and Evaluation
Branch
Office of Policy and
Management
Region 2
Risk and Arithmetic
An error appeared in Robert
Scheuplein's article entitled
"Uncertainty and the
Flavors of Risk" on page 17
of the January-March 1993
EPA Journal. The error
occurs in the last sentence
of the first column: "Cancer
risks of less than 10-6^-one
in a million per lifetime or
one in 14,000 per year or 7
per 100,000 per year or
0.007 percent—are usually
not considered worth
regulating." The next
sentence correctly reads,
"Lifetime risks are
approximately 70 times
higher than annual risks if
the risks are similar from
year to year for a lifetime."
However, the risk number
of "one in a million per
lifetime" is erroneously
much smaller than the
calculated annual risk of
"one in 14,000." The writer
has mistakenly multiplied
where he should have
divided by 70.
Leo Casey
U.S. Department of
Transportation
Cambridge, Massachusetts
Robert J. Scheuplein
replies:
Correct, ihc sentence should
read, "Cancer risks of less than
10-6?—one in a million per
lifetime or out I'M 70 million
per year or 0.01)14 per year per
WO.OOO or 0.0000014 percent-
are usually not considered worth
regulating."
Radon and Pollution
Prevention
In the boxed article "An
Ounce of Pollution
Prevention" in the
July-September 1993 EPA
Journal (page 8), the
radioactive gas radon was
used as an example of a
pollutant which cannot be
prevented. While it is true
that the decay chain of
uranium, which produces
radon, cannot be stopped
under our house
foundations, harmful radon
radioactivity can be
redirected so that it does
not come in contact with
occupants. Radon can be
funneled through a
gas-tight vent pipe from
beneath the floor out above
the roofline where it
dissipates harmlessly into
the atmosphere.
This winter, EPA and the
National Association of
Home Builders will publish
a guide for using
radon-reduction techniques
in constructing homes,
entitled Model Standards
and Techniques for Control
of Radon in New
Residential Bui/dings. To
install a radon-reduction
system at the time of
construction, the average
cost per home is only $350
to $500—compared with an
average 51,250 for
retrofitting a home for
radon removal.
Therefore, we believe that
the phrase "an ounce of
prevention is worth a
pound of cure" can be
applied to radon, if
preventative radon control
systems are installed at the
time of construction of a
home in an area where
there is a high potential for
elevated indoor radon
levels.
Stephen D. Page
Director of EPA's Radon
Division
EPA Journal replies:
"Your point is well taken.
Neivrthelcss, the strict meaning
of the term "pollution
prevention" is sninvi1 reduction
(as opposed to source control),
and thai is the sense in which
we meant to use the lcrn< in the
short commentary entitled "An
Ounce ol Pollution
Prevention." '
EPA JOURNAL
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Home is one of many indoor environments we inhabit
Richard Quataen photo tor Folio, me
(Back cover)
Pollen grains from trees and plants—these
common allergens easily find their way indoors
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Printed on Recycled Paper
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