U.S. Environmental Protection Agency
Region X
COMPARATIVE RISK PROJECT
BUDGET PROPOSAL
RISK MANAGEMENT STRATEGY
for
Indoor Air
September 1988
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INDOOR AIR POLLUTION BUDGET PROPOSAL
Region 10 Comparative Risk Project
ABSTRACT
People spend nearly 90 percent of their time indoors and,
for many pollutants, indoor air pollution levels are considerably
higher than outdoor levels. National trends toward energy
conservation, increased use of synthetic chemicals, reduction in
air exchange rates, and increased use of household pesticides
all have led to a rise in indoor air pollution. Estimated risks
are quite high compared with other risks in the region.
Region 10 proposes implementation of a two-part strategy as
a demonstration of what can be done to mitigate the human health
risks posed by this source of pollution. First, EPA Region 10
proposes to coordinate efforts with other agencies to provide a
program of public information and outreach for both residential
and commercial building owners. Second, EPA would provide
support for establishment of a model state program in Oregon to
deal with a wide range of environmental pollutants. The model
program would work through building codes to establish standards
for commercial buildings, establish product standards relative to
indoor emissions, and accredit laboratories for indoor air
testing. "
The Region 10 Air and Toxics Division has 0.5 FTE available
and a tentative commitment from the regional office for an
additional 0.5 FTE in overceiling allocation to support a full
time regional - indoor air pollution position. From EPA
Headquarters $38,000 in additional travel and contractual funding
is required, $18,000 annually for the three year trial period
($3000 in travel, $5000 for a toll free hotline, $10,000 in
workshop and educational materials costs) and $20,000 for FY 89
only ($10,000 for a survey and $10,000 additional for the first
year brochure). We propose using approximately $30,000 of the
existing regional 105 air program grant funding to support the
development and passage of a model state program in Oregon. The
Oregon program, if passed, would be fee supported.
Summary of Comparative Risk Project Process
Region 10's Comparative Risk Project, the primary
impetus for this proposal, is one of a series of regional
adaptations of the national Unfinished Business study, a national
comparative risk project initiated by EPA Administrator Lee
Thomas in 1986. Like similar pilot projects in Regions 1 and 3,
Regions 10's Comparative Risk Project is modeled on the national
study, and shares its fundamental objectives: to compare a wide
range of environmental problems in terms of the risks posed to
human health and the environment, and to incorporate that
information into environmental decision-making and planning.
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In Region 10, the project involved a four-step process which
began with rigorous assessments of the actual and potential human
health and ecological risks associated with the top 21
environmental problems in the Pacific Northwest, as identified by
a diverse group of Regional experts. The participants used the
results of these analyses, and their best professional judgment,
to group and rank the problem areas in terms of the seriousness
of the risks posed. Next, participants solicited and generated
strategies for managing or reducing risks in all of the 21
problem areas. Finally, a team of experts ranked the strategies
based on programmatic factors (such as legal and technical
feasibility), effectiveness factors (such as the degree of risk
being addressed and the likelihood to success), and cost factors.
Of the more than 40 strategies generated, six are being actively
pursued, including the one that is being presented here.
Risk Assessment Findings
Indoor air pollution was ranked in the highest category of
human health risks by the Human Health Work Team, along with
indoor radon, pesticides and air toxics (including PM-10). The
ranking was due primarily to the relatively high estimated cancer
incidence and numerous chronic and acute noncancerous effects (e.g.,
headaches, pulmonary irritation, increased infection) associated
with this''form of air pollution. That result was consistent with
the national comparative risk study, in which indoor air
pollution (other than radon) was ranked 7th of 31 problem areas
assessed* The major pollutants of concern include environmental
tobacco smoke, (i.e. passive smoke), formaldehyde, volatile
organic mixtures, and microbiological contamination.
In addition, research conducted during the risk assessment
indicated there were few established human health standards for
indoor air pollutants and a dearth of information about how to
achieve those levels in residential and commercial buildings.
Description of Strategy
The proposed regional program is a two-pronged effort to
give EPA Region 10 a leadership role in coordinating efforts to
provide public education and outreach, and to support development
of a comprehensive state program to reduce risk from several
pollutants of most concern. The public education and outreach
program would require a full time regional office person to:
1. Establish a focal point for regional indoor air
pollution control initiatives;
2. Develop a data base for determining public awareness and
needs;
3. Establish a multi-agency agency communication network;
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4. Publish a comprehensive list of resources and services
available to the public; and
5. Initiate an active program of training, public
information, and expertise for homeowners and public/
commercial building owners.
Although a number of informative articles have appeared
in (the popular press (local and national), little information is
available on specific actions the public can take to reduce the
health risks associated with.indoor air problems. After
conducting a public awareness survey, a consumer oriented guide
or booklet addressing mitigation practices for residential and
commercial building* dwellers and owners would be developed.
Workshops, a toll free hotline, and public speaking engagements
would be used to educate the public on ways to deal with specific
concerns and who should be contacted if they have specific
questions and concerns.. A comprehensive guide to the resources
available would be prepared.
Second, EPA Region 10 would, support development of a
model state program using 105 grant funding. Currently there is
public support in Oregon for dealing with this problem and the
Oregon Department of Environmental Quality (DEQ) has the approval
of the Governor to develop* indoor air pollution legislation for
the next session of the legislature. EPA Region 10 should
provide maximum support toward development, passage, and
implementation of a model program in Oregon. If the legislation
is not successful, the momentum established can be used to see
what, can be done to get a program established within existing
legislation. Again Oregon would probably, but not necessarily
,be the key state in such an effort.
Preliminary thinking in Oregon is that legislation for a
program would include:
-establishment of a public information, education, and
assistance program.
-identification of acceptable concentrations for selected
indoor air pollutants.
-initiation of a regulatory program to achieve compliance
with ventilation and pollutant'concentrations in
commercial buildings.
-authorization for establishment of product standards
relative to indoor emissions.
-requiring building code modifications to protect indoor
air quality in_ new and remodeled residential buildings.
raccreditation'of laboratories for indoor air testing.
-low cost passive monitors to Oregon residents.
The Oregon Department of Environmental Quality envisions a
fee supported program to accomplish these objectives.
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Measures of Progress
For EPA Person:
-Establishment of a multi-agency task force or working group
-Strategy for the EPA effort (an effort coordinated with other
agencies)
-Preparation and distribution of a consumer oriented booklet (or
booklets since commercial and residential issues need
separation)
-Evaluation of program effectiveness 3 years after initiation
For Oregon Model Program:
-Submittal of model program to Oregon legislature
-Passage of legislation
-If legislation passes, evaluation 3 years after initiation
-If legislation is not passed, strategy for dealing with indoor
air problem under existing legislation.
Current Regional Efforts in Indoor Air Pollution
The current effort consists of answering any phone calls
which arise (nothing is done to solicit calls) and referrals of
individuals with indoor air asbestos problems to testing and
removal agencies.
Resources
Resources Required
-1 FTE for a regional indoor air person
-$38,000 initial year contractual and travel funding ($5,000
for a hotline, $20,000 in contract funding for the
brochure, $10,000 for a public survey, and $3000 for
travel), with $18,000 in subsequent years (hotline,
travel, small materials, brochure and educational expense
fund)
-1 state person (Oregon) funded by 105 special project funds
Proposed Sources of Resources
The Air and Toxics Division has a tentative commitment from
the Regional Office to allocate an additional 0.5 FTE to add to a
0.5 FTE of Air Program Branch resources for a new position.
Anything less than a* full position will not be effective in
development and implementation of a program of this magnitude.
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EPA Headquarters is being asked to provide $38,000 initially
and $18,000 in two subsequent years to support the travel,
hotline, and educational materials support costs for the public
outreach program.
The Air and Toxics Division will work with state agency
directors to secure grant support for at least 1 FTE in Oregon to
develop and work with the state legislature on passage of model
state legislation. The Governor supports development and passage
of such legislation.
The Region 10 air program is at a minimum core level so
additional internal reallocations are not possible without severe
program disruption.
Attachments
Attachment 1 Overview of the Comparative Risk Project
Attachment 2 Summary of Ecological Work Team Process and Results
Attachment 3 Summary of Human Health Team Process and Results
Attachment 4 An Overall Summary of Ranking Process and Results
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SCHEDULE - INDOOR AIR
TASK
10
FY89
20 30
10
FY90
2Q 30
10
FY91
20 3Q
Hi re Posi t ion
- Establish Multi-Agency Task Force
Work Group
- Work with Task Force/Work Group to
Respond to Publi c
- Develop Strategy for C^A Effort
- Prepare Consumer Oriented Booklet
"For Residential (Homes)
"For Commercial Apartment Buildings
"For 0(fices
- Di slribute Booklets
Cv.ilujlc Program Effectiveness
[ijj:_Qretjpn Model Program
- Submit Model Program to Oregon
Legi slature
Passage of Legislation
F v,i 1 u.i t i on of I rrj i s 1 a I i on
If Legi slation Fails
"Develop Strategy for Program
under existing Legislation
"Implement Active Outreach Program
"Re-submit Legislation
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