UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION I
J.F. KENNEDY FEDERAL BUILDING, BOSTON. MASSACHUSETTS 02203-2211
A Summary Report of a Preliminary Evaluation of the Indoor Air and Work
Environment Qualities of EPA Region 1 Occupied Space - One Congress Street,
and Identified Opportunities for Improvement.
N. A. Beddows. CIH, CSP.
December 20, 1990
Summary
Information is provided to assist individuals and managers to evaluate indoor
air quality, work place environmental qualities, and personal complaints, given
adequate data. Included are matters covering: carbon dioxide, carbon monoxide
and Jormaldehyde indoors; ventilation criteria and system extractor sizing for
smoking rooms; work place noise and illumination; dust and volatile organic
chemicals (VOCs) indoors; associations between VOCs and health and comfort;
and claimed chemical sensitivity. Other points are also addressed.
Results of quantitative tests are presented. Found levels of carbon monoxide,
carbon dioxide and formaldehyde, together with the evidently low occupant density
and other relevant points indicate thai (i) the HVAC-ventilation, and (ii) the air
quality in the office spaces are generally fully satisfactory.
Matters of localized work place noise and illumination; lighting glare and
contrast; and reported personal discomfort (Le., irritation of the eyes and upper
respiratory tract) are discussed. In these aspects, personal practices, physical
arrangements, and certain cleaning operations conducted during the mid-morning
and later periods in the day (involving the use of strong chemical spray cleaners.
and "feather-dustertng"- with redistribution of any settled dust) are identified as
potential problems. In these matters, whether or not actual problems exist or will
occur, depends on the particular conditions, practices and locations, and the
tolerance levels of those who are impacted.
The employer's duty, and prudent actions in responding to complaints are
described. And. opportunities which managers and individuals can take to
improve work place environmental quality are identified. These relate to localized
noise, illumination and ergonomic stressors.
Optional, additional, valuative programs are identified; at some later date.
management might want to have such programs defined and implemented by
outside specialists. To this end. program information is provided on: scope-of-
work; project costs and durations; and contractual considerations for assuring cost
effectiveness and work-quality.
Introduction.
Indoor air and work environment qualities in EPA spaces in One Congress Street have been recent
topics of discussion, following on from two noteworthy, separate claims of EPA employees of alleged
chemical sensitivity (a term which is described later) and distress when working in open space offices
(which are like all the other offices), and about a dozen separate complaints of respiratory irritation,
headache, eye strain, backache or irritability, made to the safety manager. Questions about indoor air
quality have been raised and points have been made on this matter which appear to now need
addressing in a systematic, comprehensive way, in accordance with good industrial hygiene practice.
This report attempts to do this at one time and in one place. And, it is intended to serve as a basis and
format for considering any future inquiries or proposals which may arise. It is not intended as a
response to any particular complaint or any alleged condition or complaint of any employee, although aTo
it might be useful in part for this purpose. '" '
PRINTED ON RECYCLED PAPER
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Four sections are presented which deal with the following major points, and some others:
A. Important background information covering carbon dioxide (CO2), carbon monoxide (CO), other
possible indoor pollutants (dust, volatile/semi-volatile organic compounds, lighting and noise) and
ventilation.
B. Reported CO, and CO test results of tests made on 10/22/90 of EPA spaces by T. Spittler, ESD
Laboratory Director; FORMALDEHYDE tests (eleven in total) of the 10th and 11th floors, made in the
early November to early December period by the writer; and, other pertinent observations and facts.
C. Discussion of reported chemical test results and other observations and facts.
D. Employer's duty; prudent actions; opportunities for improvement of work place quality and employee
morale, including steps that employees can take directly; and a statement of scope of work, which may
be undertaken in the future at the management's direction, re: chemical targets for analysis, and
corresponding program cost estimates for additional, optional technical evaluations.
Some of the points covered in the last two parts relate to comfort or personal productivity. And, they are
discussed quite subjectively from an industrial hygienist's viewpoint; other people may reasonably
disagree with what has been said. In these areas, "one man's meat is another man's poison."
Reading these sections in order will be the best way to get an overall impression of the above captioned
topic. However, each section stands by itself and can be read without having to refer to any other
section, if there is no informational need to do so.
A. Important Background Information
1. Carbon Dioxide Indoors
La. Carbon dioxide (CO2) is a useful index of the adequacy of the supply of outside air to an office
environment to maintain healthy and hygienic conditions.
1.b. There is no national official indoor air quality (IAQ) standard re: CO2 (or for that matter for carbon
monoxide and many of the volatile chemicals which are lAQ-factors). There are, however, some formal
and informal standards covering these substances which are or may be relevant.
1 .c. The DOLOSHA' CO2 standard, permissible exposure limit (PEL) is 5000 ppm. This is based on the
risk of asphyxiation, not hygiene. The OSHA PEL is useless as an lAQ-standard.
l.d. Most industrial hygienists would agree that (1) CO2 concentrations of 600 to 800 parts per million
(ppm) are acceptable in a modern office environment, without regard to any smoking therein; (2) a range
of 800 to 1000 ppm, while possibly acceptable, would be reason to initiate an investigation and
implement appropriate corrective action; and (3) a concentration of 1000 ppm or greater indoors
indicates that a potentially serious problem of inadequate outdoor air ventilation or overcrowding exists.
I.e. The ambient air carbon dioxide level is nominally 0.03% by volume, and is seasonally variable.
2. Carbon Monoxide Indoors
2.a. Carbon monoxide (CO) is a sentinel of health hazard arising from infiltration of air contaminated with
automobile exhaust gases and other products of combustion.
2.b. The OSHA general industry standard permissible exposure limit, as an 8 hour time-weighted
average, for carbon monoxide ) is 50 ppm. This standard relates to industrial processes and
atmospheres. It has no value as an lAQ-standard. The US. EPA NAAQS for carbon monoxide is 35
ppm for 1 hour, and 9 ppm for an 8 hour exposure; the 9 ppm/8 hour exposure limit is useful as an
upper limit re: indoor air quality; it is not a criterion of acceptable, average (IAQ) CO-concentration.
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2.c. Most industrial hygienists would agree that (1) a maximum CO concentration, read on a CO-meter
or color indicator tube, of one to two ppm would be acceptable in a modem, no-smoking office
environment; and (2) any CO concentration greater than two parts per million would be cause to make
an investigation of infirtration of contaminated air from a nearby garage or combustion site.
2.d. In a dedicated smoking-room, even with forced ventilation in operation, CO concentrations would
be elevated. In this context, considering the physiological effect (blood CO-heme/CO in air equilibrium),
and the feasibility of using forced ventilation, CO concentrations greater than 10 ppm are unacceptable,
in the writer's judgment. The carbon monoxide level (and smoke - the far greater chronic health hazard)
should be maintained as low as practicable using forced ventilation with direct outside exhaust.
3. Ventilation, and CO Standard for a Smoking-Room
3.a. Ventilation conditions which the writer would impose as a standard are: at least (i) 150 cubic feet
of force-supplied air per minute per smoker, supplied by a low-noise level fan, and (ii) an air velocity of
150 feet per minute at three feet above the floor, at the room center, without regard to any use of an
electrostatic or charged-ion smoke capture device. As an example of such ventilation, a 20'x25'x10'
smoking-room (maximum of 10 people) would be ventilated (at 18 volume changes/hour) with air
supplied at a minimum at a rate of 1500 cfm. To achieve this (with a low, 2" of water total pressure,
duct/entry/friction HVAC-type loss, 15 foot run of 1 sq. ft. area duct to the exterior), a ([1500 x 2J/[6350
x 0.7 (m.e.)]) nominal 3/4 H.P. (with a slightly greater than required flow) axial flow fan would be used,
preferably in a push-pull arrangement. The duct-hood area would be sized and positioned to get the 150
foot velocity, according to the circumstances.
3.b. A maximum concentration limit of five ppm in a smoking-room is proposed by the writer. And a
goal of one ppm is proposed, based on a personal assessment of an engineered option.
4. Noise Indoors
4.a. There is no known risk of experiencing any type or degree of hearing impairment, nor any other
known health risk of any other type arising from indoor office noise at the usual levels in offices.
4.b. Noise in the work station which varies in level and/or pitch is believed to be a factor of both the
sense of personal well-being and productivity; freedom from disturbance is important to employees.
4.c. The use of masking or "white" (variable frequency/similar sound pressure level in each frequency)
noise is no longer credible (but background music may have a place in some areas).
4.d. Carpeting is used by acoustical engineers as a way to acoustically treat a room.
5. Illumination Indoors
5.a. Illumination, glare and contrast lighting at the work station are factors of the sense of well-being,
and productivity. A minimal level of (i) illumination (100 ft. cdles?) and (ii) a minimal value (3?) of (task-
background) luminance ratio is necessary for reading comfort. Inferior illumination and excessive glare
are believed to cause eye strain and headache; and, they may contribute to ergonomic stresses.
5.b. Indirect lighting of adequate uniform level is much preferable to direct lighting in looking at video
screens. When direct overhead lighting is used in offices,, optical diffusers (plastic lens) should be used
for comfort; large (6" square) open metal grid "diffusers" in office locations may be found by some
people to be allow too much of the lighted fluorescent tubes to be seen directly, causing excessive glare.
Also, a soft yellow light is easier to read in than a hard white light (the eye is optimally sensitive to
yellow).
5.c. The quality of direct lighting at work surfaces depends on (i) the type of lighting (diffuser lens on
fluorescent lights reduce direct glare); (ii) the height, distribution and angularity of the fixtures, and (iii)
the luminance (task-background) differences. Work place shadow pattern is an indicator of quality.
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5.d. Detail work (drawing, mapping) requires at least 100 fl.Cdls. of illumination at the task surface; a
general office requires lighting levels at desk surfaces of at least 50 ft.Cdls., and some people would find
this (50 ft. cdls.) level to be marginal for their office work needs.
5.e. The OSHA safety illumination standard (at 29CFR 1910/1926), 30 ft. cdles for offices, is not well
suited for application to reading in modern office settings. An ANSI standard (ANSI-11.1,1973) provides
luminance and luminance ratio guidelines which are relevant, but possibly conservative. These guidelines
are useful for assessing office area and task lighting quality.
6. Dust Indoors
6.a. It is well known that fibrous asbestos, silica dusts, and dusts laden with pathogens can pose
significant health hazards. However, these types of dusts are not expected to be present in new offices.
6.b. Benign dusts may be found to a varying extent in a modem office environment, however, there is
no recognizable health risk with such dusts in such a setting.
7. Volatile and Semi-Volatile Organic Chemicals Indoors.
7.a. It is well known that the classes of volatile and semi-volatile organic chemicals known as (1).
aldehydes, (2) aromatic hydrocarbons and (3) aliphatic cyclic-hydrocarbons include compounds which
are capable of causing local irritation (eye, respiratory tract) at/above some (low ppm) threshold level.
These classes of compounds exist, together with a host of other compounds of different classes, such
as ketones, alcohols, alkanes, chlorinated alkanes and alkenes, to a varying and trace extent indoors.
7.b. These and other compounds arise from construction pressboard (e.g., formaldehyde); carpets (e.g.,
formaldehyde, 4-phenyl cyclohexene. acetone); carpet adhesives (e.g., toluene, benzene, styrene,
acrylonitrile); and industrial cleaners (e.g., 1,1,1, trichloroethane, tetrachloroethylene, methylene chloride,
ethoxylated 2nd alcohols, ethylanolamine, butoxyethanols).
7.c. The use of solvent-containing cleaners in office spaces, especially at the start of the work shift can
add significantly to the indoor contaminant level; this burden can be persistent throughout the day. The
use of such products is to avoided. If they must be used, they should only be applied after regular
hours or controlled as to application times.
7.d. Users must be instructed in the safe and proper use of chemicals, and material safety data sheets
(MSDS's) must be made available to users, under both federal and state "Right To Know " laws.
8. Personal Detection Limits For lA-VOCs.
8.a. Most of the compounds referenced at section A.7 have characteristic odors, and can be
(subjectively) detected by odor and/or local irritation (eye blinking), at a few parts per million
concentrations. Some strongly irritating compounds (dienes, mercaptans, aldehydes) can be detected
at sub-part per billion levels. Also, formaldehyde (and others) irritate ones eyes and URT at less that
the corresponding odor detection threshold concentration, which may be a fractional part per million.
9. Formaldehyde in Newly or Recently Furnished/Carpeted Office Spaces
9.a. Formaldehyde may be present in newly furnished offices, depending on the construction materials
used, at concentrations which cause eye irritation or respiratory distress to some occupants. With
passing time, the rate of out-gassing from furnishing containing formaldehyde resins decreases.
9.b. A significant percentage (10 - 20% ?) of the population are hypersensitive to formaldehyde, which
is "seen" in some cases as increased respiratory air flow restriction measured by spirometry--FEV10.
Also, people of ordinary sensitivity may experience irritation of the mucosa upon exposure to
formaldehyde at concentrations which they may be unable to, detect by its distinctive, pungent odor.
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9.c. The (i) average-person's odor detection limit, and (ii) the action level is 0.05 ppm (50 ppb).
9.d. lA-formaldehyde measurement can be made inexpensively using a 7-day passive dosimeter in
conjunction with the universally used, chromatropic atid-spectrographic analytical method. A more
expensive, more accurate (privately communicated resolution: 3 ppb, with a CV =0.12) method, based
on "one day" dosimetry, with DNPH/HPLC (2,4-dinitrophenylhydrazine / high performance liquid
chromatography), is available (GMD Inc., Hendersonville, PA 412 742-3600).
9.e. The "7 day" exposure - chromatropic acid, passive dosimeter's limit of detection is about 10 parts
per billion. This should be interpreted carefully because such limits are inherently imprecise and tend
to be measured under optimum developmental conditions. A factor of two or more may be appropriate
to apply to the reported limit of detection, when reviewing data close to the claimed limit of detection.
9.f. A person with a sensitive smell for formaldehyde may be able to detect formaldehyde at the action
level (0.05 ppm or 50 ppb), while other persons may not smell it.
9.g. The outdoor air formaldehyde level is approximately 0.005 ppm or 5 ppb (MA-DPH data).
9.h. Testing office spaces for formaldehyde (and also for organic diisocyanates: TDI, MDI). and
conducting differential spirometry on affected employees, should be considered when upper respiratory
tract (URT) irritation is reported by employees who work in newly/recently furnished spaces.
10. Analytical Instrumentation Sensitivity.
10.a. The analytical instruments now in use have such good sensitivity that many of these (i.e., those
listed in 7.b.) compounds and some tens or hundreds of other organic chemicals may be detected or
measured at a tew parts per billion, and lower levels. Accordingly, many organic compounds may be
shown to be present in trace amounts, indoors, when modern analytical instruments are employed.
11. Associations (Re: Comfort, and Well-Being)
11.a. A range of 72 to 80 degrees (F), with a corresponding range of 45 to 50 percent relative humidity
(an indicator of how much of the maximum retainable water exists in the air) is the recognized comfort
range for office type activities and occupancies. As the temperature within the range increases, the
percentage of relative humidity must reduce to maintain equivalent personal comfort. Low %RH (e.g.,
15% or less) causes and/or contributes to (i) the condition known as "dry eye", and (ii) URT-irritation.
11.b. The association between the presence of volatile organic chemicals at parts per billion or sub-
part per billion concentrations and health or comfort appears to be largely unknown. However, a 1985
study by L. Molhave et al, in Denmark has shown that a mixture of hydrocarbons which are known to
be common indoor air pollutants will cause eye, nose and throat irritation in healthy adults, which is not
adaptable, at an exposure of: concentration of approximately one part per million (measured as toluene;
GC-FIO); duration 2 3/4 hours. Accordingly, total volatile organic compound, measured as toluene -
GC.FID, at about 1 ppm is the outside upper limit for allowable respective contamination. One should
apply a safety factor of at least 10 to "set" an upper limit for permissible hydrocarbon contamination, in
the writer's (admittedly, subjective) judgment on this point.
12. Out-passing and Diminution In a Ventilated Building ("Airing-Out").
12.a. It is known that volatile compounds which are or may be initially present in new office furnishings
and carpeting "out-gas." Some kinetic studies using environmental chambers have shown that out-
gassing of volatile compounds in new carpeting in a simulated force-ventilated office type environment
follow first order kinetics, and the compounds are relatively short-lived, having half-lives in terms of
weeks. If this is the general case, continual airing out by the continuous operation of a HVAC system
would be expected to result in the virtual elimination of offending volatile compounds present in new
carpeting and furnishings in a period of about two months.
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12.b. It is now common practice to "air-out", and sometimes "bake-out", volatile organic compounds from
a new office facility by operating the HVAC system for one or more weeks before the offices are
occupied. The practice is well reported on. Its value can be negated when solvent-containing cleaners
are regularly used.
13. Other lAQ-Fadors.
I3.a. Oxides of nitrogen and sulphur, and biological entities are potential contaminants, but normally they
are not concerns in new office buildings; they are concerns in older homes and other constructions
which use gas for cooking, or coal for heating. Ozone is a concern in some (enclosed, high-activity)
copying operations which are not force ventilated directly to the outside.
I3.b. Volatile organic compounds (including formaldehyde) con not be removed from circulating air using
high efficiency paniculate (HEPA) filters, as has been erroneously suggested by some individuals.
14. Claimed "Chemical Sensitivity" and the Indoor Office Environment
14.a. A highly controversial issue currently exists with respect to "chemical sensitivity of no known
etiology" and people being affected or claiming to be affected, in some way, in some indoor situations.
This type of condition is distinct from those conditions which are widely recognized to exist and which
have a known etiology (such as an evident IgE-mediated allergic response of asthma with re-exposure
to methylene diisocyanate in the fabric coatings industry). On this issue, some medical authorities, while
recognizing that chronic low exposures to chemicals might interfere with normal cellular activities or
damage cells, suggest that some claims are likely to have a psychological component (e.g., anxiety
panic), while some other medical authorities, who appear to be the minority, invariably content that it is
low level chemical exposures which are invariably responsible for claimed "chemical sensitivity1 effects.
I4.b. Certain volatile or semi-volatile organic chemicals at the low (part per billion) levels found in some
office and home environments are evidently capable of acting as local irritants and systemic toxicants,
and they may act systemically in some known mechanistic way. However, the notion that chemicals at
trace concentrations act singly or in concert in some currently unknown mechanistic way to adversely
affect the health of. or incapacitate, some individuals, as appears to be the case asserted by some
clinical ecologists and doctors involved in holistic medicine, is disputed by many allergists and other
medical clinicians, who express difficulty in seeing a diagnostic significance to such claims.
14.C. Without commenting further on the issue of chemical sensitivity, it is noted that in a modern office,
which has been constructed and furnished, and is operated, so as to minimize a burden from volatile
organic compounds, the quality of the (filtered and exchanged) air is superior to many home
environments in regard to aldehydes, hydrocarbons, formaldehyde, and oxides of nitrogen, sulphur and
carbon (which are common pollutants from kitchens with gas cookers), molds, animal dander, and
cigarette smoke, when smoking occurs. Also, old, uncleaned carpeting and furnishings, wherever they
are found, are reservoirs of a host of animate and inanimate allergens.
B. Results of (1) COj/CO, and (2) Formaldehyde Tests. Other Observations.
1. CO,. CO Tests.
La. Dr. Tom Spitller, ESD laboratory director, tested the EPA-occupied office spaces on the 10th and
11th floors, and the 10th floor smoking-room for CO2 and CO concentrations. The tests were made on
10/22/90 in the late morning and mid-afternoon period (for specific values, please refer to Dr. Spittler's
summary report of 10/25/90).
l.b. The maximum CO2 concentration reported for any office space was 360 ppm. Also, the average
of the reported CO2 levels is comparable to the outside level.
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1 .c. The maximum CO concentration reported for an office space was 0.9 ppm.
1.d. The CO concentration reported for the 10th floor smoking-room (when it was occupied by five
people who were smoking - about half-full, and when the two "smoke-eaters" were in operation, as
observed by the writer) was 5 ppm.
2. Formaldehyde Tests
2.a. The 10th floor was tested quantitatively for formaldehyde in the first week of November. The writer's
open-floor plan office (10-319) and a closed type office (10-364) were tested using a passive dosimeter
which was exposed for 160 hours, during a normal work period which included a week-end period. The
MA state DPH made the analyses (which were kindly arranged for by Dr. Mary Beth Smuts, of the EPA
Region 1, Air Toxics and Pesticides Division). The MA-DPH reported results, as simple average values
for the 160 hour sample time, as follows: OPEN OFFICE AREA (10-319): 0.015 part per million.
CLOSED TYPE OFFICE (10-364): 0.023 part per million.
2.b. Additional formaldehyde (nominally 23-hour) tests using DNPH-HPLCD dosimeters in open and
enclosed office spaces on the 10th (7 tests) and 11th floors (3 tests) were made on 12/10/90.
Summarily, the reported concentration range was: 0.0097 to 0.018 ppm. The maxima were: 10th floor,
0.018 ppm; and, 11th floor, 0.014 ppm. The geometric mean (n=9) is 0 .014 ppm (14 parts per billion);
the corresponding GSD is 1.3.
Other Observations
3.a. General Indoor Conditions, and Some Localized Reported/Observed Problems.
(i) There is no discernible general chemical odor, nor new carpet odor, nor formaldehyde odor in any
of the EPA-office spaces.
(ii) Several complaints of eye irritation and having to leave the area after the janitors clean the
Information Center (usually in the morning around 9 a.m.) with a spray-cleaner have been made.
NOTE: the cleaner is 3M's "Trouble-Shooter." It contains VOCs which are known eye irritants.
(iii) Ozone is detectable by odor in the 10th floor copying room during intensive periods of copying, and
in the computer room during the initial operation of the Laser-printer.
NOTE: The simultaneous short-term presence of (a) trace amounts of ozone, and (b) reactive cleaning
solvents (as has been observed by the writer) may cause acute eye irritation (via products of reaction -
peroxy organic compounds: strong eye irritants).
(iv) There is no discernible surface dust in the offices. However, this observation is only directly
relatable to coarse, visible dusts; it does not relate to, but it may parallel, fine dust which is not directly
visible but which is respirable (10 micron and smaller) paniculate. No information on indoor respirable
dust (PM10) is available.
(v) Air temperatures are generally very comfortable, but some localized insolation problems in August
were reported for the atrium areas and in the south-west corner of the 11th floor. At the time of the
problems the HVAC system on the 11th floor was being worked on by the owner. This problem may
become a seasonal issue. Installation of translucent sun-screens in the atrium areas and on selected
windows on both floors would probably eliminate evident insolation problems.
(vi) Humidity, and more particularly air dryness, is an important component of comfort and the condition
of the eyes, nose and throat. There is no current tracking. These factors might be a seasonal concern.
(vii) Illumination level and "open- grid" fluorescent lights have been mentioned as causing a glare
problem; some employees have said they need eye-shades (visors).
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Light fixture placement has been mentioned as a reason (or the perceived poor level of lighting in some
situations. Dark carpeting and furnishings in areas remote from the atrium may require being oft-set by
additional overhead lighting, and/or repositioning of existing fixtures for balance.
NOTE: Direct lighting can cause direct and indirect glare. Indirect area lighting - which is less efficient
electrically but is more comfortable - for example, upwardly directed, shielded wall-lights, is beneficial
in office areas. Recent (ergonomics) literature references the preference for office indirect lighting in
computer (PC) operation.
(viii) Noise propagation in the building is a concern to some employees in some locations. Reportedly,
some employees use ear-muffs (which may be radios) at their work stations.
3.b. Work Station Conditions.
(i) Excessive noise intrusion and lack of business privacy have been mentioned as problems in some
areas of both floors. Personal practices, computer printers, and the current physical/structural
arrangement appear to be about equally responsible for at least some of these problems.
(ii) High pitched noise from certain printers (e.g., the Epson LQ 1050) when operating outside of a noise
reducing hood (which are available in-house) in open areas (especially in the atrium spaces) is very
intrusive and possibly disturbing to many employees.
NOTE: Hoods can be used (and required to be consistently used) to control such noise generators.
(iii) Direct glare, and lighting contrast, especially in offices in the atrium area offices, are concerns. Some
anti-glare screens are being used in some of the problem areas.
NOTE: 200 anti-glare attachment screens (CURTIS Ltd. MA., manufacturer) were made available in the
last week of November. The usefulness of the screens with respect to current concerns is not
completely established; however, one of these screens used by the writer does reduce the glare and
improve contrast in a major way in the particular situation.
(iv) Physical stresses (back, neck, hand and eye), related to posture and work positioning in using
computers, have been mentioned as a concern by some employees.
4. Extent and Seriousness of the Expressed or Evident Concerns.
4.a. The concerns described in section C.3.a. are reported on the basis that at least one EPA employee
has made a relevant comment to the safety manager.
4.b. Comments have been made as a part of the complaints of headaches, eye or throat irritation,
irritability, and backache.
4.c. The actual or perceived extent and seriousness of complaints is not currently known; the comments
or complaints made to the safety manager have been relatively few, and only an informal survey has
been made. An EPA protocol to formally assess concerns is available.
C. Discussion
1. HVAC-Ventilation
La. The ventilation level of the EPA-occupied office spaces is evidently fully adequate to ensure that
CO2 concentrations do not rise above an acceptable level, based on the reported tests of 10/22/90.
1.b. Based on the current level of volume/occupancy (in excess of 1000 cubic feet per person) and the
reported CO2 levels, the supplied outside air ventilation rate per person is estimated (N.A.B) to be
minimally about 8 cfm per person.
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1.c. The level of ventilation throughout the open office spaces is judged by the writer to be adequate
to ensure (i) the required oxygen content; (ii) the prevention of COj concentrations from rising over about
500 ppm; and (iii) the removal of objectionable body and furnishing-type chemical odors which might
otherwise be present.
1.d. "Legionella" is not considered to be a risk; the HVAC cooling-intake does not involve, and is not
in proximity to, pooled or sprayed water.
2. Formaldehyde.
2.a. The reported results of (the November, 1990) tests for formaldehyde and the evident absence of
its distinctive odor indicate that there is no problem of formaldehyde in the 10th or 11th floor offices.
3. Reason for the Perceived Current Absence of General Chemical Odors.
3.a. There is no discernible persistent odor of volatile organic compounds of the type which characterize
new furnishings in any of the open office spaces, and none is expected because: (i) no urethane foam
backed partitions nor any organic solvent-based paints were used in the installation; (ii) carpet tiles
which had very little odor when they were new were used instead of carpet stock in rolls which appear
to hold on to the distinctive smell of new rolls of carpet; (iii) only a water-based poly vinyl acetate (PVA)
glue was used with the carpeting, and not all of the carpet tiles required gluing down (they mechanically
lock in-place in the lay-down); and (iv) the building was aired out before occupancy occurred for at least
three weeks, using the HVAC system, after the carpet tiles and the office furnishings were installed.
3.b. Notwithstanding the absence of a persistent general chemical odor of the new furnishing type,
cleaning chemical-odors (and associated acute eye irritation) exist at times in the Information Center, as
observed by the writer.
4. Specific Matters and Appropriate Responses.
4.a. Reported concerns and evident matters.
(i) Concerns raised by employees are: (1) intruding noise and sound transmission and resulting lack of
privacy; (2) illumination and glare in some spaces; (3) illumination of working surfaces and shadowy
office lighting and (4) glare, contrast lighting, and placement at the computer -- causing eye strain,
backache and neck-ache.
(ii) Some of these types of concerns may be associated with chronic health risks, and they are all
associated with comfort.
(iii) With neither excessive indoor noise nor inferior indoor general lighting is there any basis to think that
any threshold shift in aural or visual acuity would occur. However, certain physical discomforts and
localized interferences with business privacy and productivity exist locally and need resolving.
(iv) Minimal dust and minimal noise in a large, carpeted office are mutually exclusive; a balance is
needed, based on the facts, recognizing that carpeting is needed for noise control.
4.b. Appropriate responses to specific matters and situations.
(i) Volatile/semi-volatile Organic Compounds: as mentioned previously, aldehydes, alcohols, substituted
cyclo-aliphatic compounds, and other classes of organic compounds which have been associated with
some known offending furnishing materials often have odors which can be detected by people at sub-
part per billion levels. When there is no chemical odor or a significant level of complaints of eye or
respiratory tract irritation in the offices, and when materials were selected with a view to not having
volatile organic compounds released into the work place (as in this case), it seems that conducting a
broad total volatile organic analysis would not be necessary; however, spot checks in areas could be
useful.
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If a preliminary analysis were to be required for any reason in such a situation, it would not be
expensive. Such testing might not yield information that would be useful to an industrial hygienist, given
the current scarcity of acute low dose-response information on many compounds.
(ii) Benign Dusts: as mentioned, there is no visually observable surface soiling or dusting currently in any
of the EPA office spaces. Absent visual evidence of dust or a significant level of employee complaints
of respiratory irritation there would not seem to be any need to undertake to classify or characterize
paniculate in air in the office spaces.
NOTE: Such an undertaking would be relatively inexpensive and short-term.
(iii) Daily "feather-dusting" is less preferred than vacuuming, and is undesirable.
4.c. Employer's Duty.
(!) The relevant (by reason of an Executive Order) and applicable employee health and safety regulation
on duty is the OSHA general duty clause [at 29 CFR.1910(5)(a)(1)]. This requires the employer to
provide work and work places free of recognized hazards.
(ii) The OSHA General Duty standard does not impose a duty to conduct special investigatory tests or
scientific research when a hazard is not recognized to exist by a competent industrial hygienist, after a
comprehensive inquiry has been made.
4.d. Prudence of Responding by Undertaking Special Studies.
(!) Not withstanding the absence of a duty, it will be prudent to undertake special studies (VOCs;
Lighting; Computer use & use conditions) in some circumstances. The likely benefits (meaningful data)
and costs would need to be considered beforehand.
D. Possible Opportunities.
1. Current Factors/Conditions, and Ongoing Occurrences.
1.a. Selectively retro-fit diffuser lens to ceiling lights where glare is a major problem.
Lb. Use a yellow (Cellophane) filter on (the outside of) the cabinet lights for material-reading comfort.
i.e. Use an anti-glare (PC) screen to reduce eye strain and fatigue.
l.d. Use (flat-black) desk-pads to reduce desk level glare, and improve reading comfort.
I.e. Arrange (i) relative positions, and (ii) lights to prevent or minimize (a) reflected glare from desk
lights, and (b) direct glare from O/H lights with no open,small-grids or optical lens. See diagram.
<-•-- Ok! NOT OK! >
Reflected Light Light In Eyes.
Does Not Coincide Via (I) Indirect Glare, and/or
With Angle of View. (II) Direct Glare From
O/H Non-diffuse Light
1.f. The use of organic chemicals for cleaning, and cleaning using organic chemicals in the mornings,
as opposed to evening cleaning, are evident candidates for improving the work environment. Prohibiting
the use of chemical cleaning agents during regular hours in the computer room -information center
should lead to improved air quality and work place comfort.
1.g. Isolation-ventilation of the 10th floor copying room is a candidate for improvement.
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2. Team and Specialist Making Evaluations.
2.a. Matters of employee complaints of nuisance noise, lack of privacy, insolation, illumination, computer-
work visual and postural stresses might be investigated by an EPA team to (i) identify problems, and
(ii) propose needed and justified changes to practices and/or physical arrangements or equipment.
2.b. After an initial investigation by the team, specialists could undertake preliminary technical
evaluations. The specialists involved would be chosen for competence in acoustical engineering,
industrial lighting, and industrial hygiene, as appropriate.
2.c. The use of specialists to perform preliminary evaluations, in accordance with the approach described
above, would be relatively inexpensive, and costs could be completely controlled, if a fixed fee, best
technical effort-type contract were to be established in every case.
2.d. Formaldehyde indoors could be measured accurately (CV = 5%) using the DNPH-HPLG/passive
dosimeter method; testing, if deemed required, could be made on short notice. COST (for 20 tests):
$1000. TIME: 5 WEEKS.
2.e. Temperature and humidity meters could be installed (so as to be in full view of the employees) on
both floors. COST: $1000. TIME: 4 WEEKS.
3. Individual Efforts For Improving The Work Place Environment.
FOR LOCALIZED NOISE CONTROL. The following suggestions are offered:
• MINIMIZE GROUP DISCUSSIONS IN OPEN OFFICE AREAS. DO NOT HOLD EXTENDED
CONVERSATIONS "OVER" PARTITIONS, ACROSS OR IN AISLES OR THE ATRIUM.
• KEEP TELEPHONES ON "LOn, AND KEEP CONVERSATIONS etc., AT REASONABLE SOUND
LEVELS - TALK LIKE YOU WANT TO KEEP IT CONFIDENTIAL. USE TELEPHONES FOR
BUSINESS ONLY. AND, KEEP CONVERSATIONS BRIEF.
• ARRANGE FOR ACOUSTICAL TREATMENT OF (WALLS AND CEILINGS OF) SELECTED OFFICES
TO REDUCE SOUND TRANSMISSION, WHEN PRIVACY IS CRITICAL.
• POST "PLEASE KEEP THIS AREA QUIET" SIGNS. AS MAY BE NEEDED.
• RESPECT OTHER PERSONS1 NEEDS.
FOR CONTROL OF VISUAL AND ERGONOMIC STRESSES. The following steps may be helpful:
• ADJUST CHAIR HEIGHT TO MINIMIZE (1) GLARE/CONTRAST, AND (2) POSTURAL PROBLEMS.
• USE SUPPLEMENTARY LIGHTS IN POOR LIGHTING SITUATIONS.
• USE AN ANTI-GLARE SCREEN; ADJUST SCREEN POSITION FOR OPTIMUM COMFORT.
• USE A YELLOW FILTER ON THE OUTSIDE OF THE LENS OF THE DESK LIGHTS.
• USE A BLACK DESK PAD FOR IMPROVED CONTRAST AND COMFORT IN READING.
• WHEN USING A PC, TAKE FREQUENT BREAKS -- REST YOUR EYES; STRETCH YOUR BACK
AND NECK MUSCLES. AND SHAKE YOUR WRISTS AND FINGERS TO RELAX THEM.
• SUPPORT YOUR LOWER FOREARMS IN FRONT OF THE KEY BOARD (A 20" x 6" x 3/4" FOAM
PAD WILL BE USEFUL WHEN PLACED AT THE LEVEL OF, AND 2 INCHES FROM , THE
KEYBOARD. CONTROL FINGER IMPACT FORCES. PERIDICALLY RELAX.
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4. Scope of (Optional) Work (applicable to each specialty)
4.a. In the event that an additional, optional, preliminary study is required involving all of the specialties
likely to be used (acoustical engineering; industrial lighting; air quality evaluation; and industrial
hygiene/epidemiological assessment), the scope of the work for each contract could be limited to the
following elements: (i) establish targets and methodology, in conjunction with the industrial hygienist; (ii)
make a preliminary evaluation; (iii) report observations; (iv) classify findings; (v) identify opportunities for
changes; and (vi) report and recommend.
5. Identification of Chemical/Other Targets, and Methods.
5.a. The organic compounds listed in A.7.b., and some others including chlorinated aromatic compounds,
would comprise the target compounds for the purpose of the preliminary evaluation described in
4.a..above. The chemical analytical schemes and methods, and the physical testing, in the case of
conducting an acoustical investigation, would be established by the industrial hygienist in consultation
with the respective specialists who would be engaged.
6. Preliminary Evaluation Program - Cost and Duration
6.a. The initial total worth for the combined contracts, as described above, could be set at $40,000, if
the management agreed with the described approach, and authorized the work.
6.b. A ten week-long period should be sufficient for completion of this optional program.
6.c. A second phase of investigation of some particular lAQ-component might be necessary after the
preliminary results have been evaluated.
7. Informative Meetings with Employees.
7.a. A lunch-time, employee information session to (1) explain the analytical findings reported herein; (2)
inform employees of good personal practices which will minimize work place stress and fatigue and
improve the working environment (as identified in section D.3, herein); and (3) address relevant concerns
and questions, which our employees and other occupants may have, could be held sometime after mid-
december.
7.b. Other agencies in the building might want to have their employees participate.
8. End Notes & Comments.
8.a. Employees can make improvements in the environmental quality of the work place by giving due
consideration to personal practices. And, managers must involve themselves in administrative and
engineered efforts to achieve optimal work place quality.
8.b. IAQ checks, via measured C02 and CO, should be made periodically, and whenever the level of
employee complaints suggests the need.
8.c. Given that some percentage of the population at large appears to be especially sensitive or
susceptible to airborne chemicals (for instance, it appears that perhaps 20 % is hypersennsitive to
formaldehyde), when the is a real or potential lAQ-problem, one would expect a cooresponding level of
complaints, as distinct from one or two complants. from a large population (several hundreds) of
uninhibited employees.
8.d. Individuals who believe that they definitely need medical advice or help for some condition or allergy
which they attribute to some exposure or condition in the work place (or elsewhere, for that matter), may
want to ensure that the treating physician is fully trained in allegy - one who has passed the examination
administered by the American Board of Allergy and Immunology. This may be important, given the
plethora of doctors and organizations now offering allergy testing and treatment for chemical sensitivity.
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APPENDIX
1. NOTICE OF OPEN MEETING
2. PROPOSED AGENDA
3. ADVISORY NOTICE - WAYS TO IMPROVE
THE WORK PLACE ENVIRONMENT.
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EPA REGION 1 OPEN MEETING
An Evaluation Of The Indoor Air and Work
Environment Qualities Of EPA Spaces
At One Congress Street"
***
INVITED SPEAKERS
***
Norm Beddows, Health and Safety Manager, EPA Region 1.
Janls E. Carrelrro, RA, DOL-OASAM.
Julius Jimeno, Director, EPA-OHSS.
Pat Meaney, ARA, EPA Region 1.
Tom Spittler, Laboratory Director, EPA-Lexington Laboratory.
Dr. Ocampo, Medical Director, Div. Occ. Fed. Occ. Health, PHS.
Barbara White, National President, AFGE-Union.
Date — DECEMBER 21
Time NOON to 1:30
Place EPA 11fl. Conference Room.
One Congress Street.
Information will be presented to help managers and
individuals to evaluate: indoor air quality; work place
environmental qualities, and personal complaints, given
adequate data. Included in this are matters covering:
carbon dioxide, carbon monoxide and formaldehyde
indoors; ventilation criteria and system extractor sizing
for smoking rooms; work place noise and illumination;
dust and volatile organic chemicals (VOCs) indoors;
associations between VOCs and health and comfort; and
chemical sensitivity.
Results of quantitative tests will be reported. The
significance of the found levels of carbon monoxide,
carbon dioxide and formaldehyde, occupant density, other
relevant points, and evident opportunities will be
discussed.
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AGENDA - 12/21/90. NOON - 1:30.
MODERATOR - PAT MEANEY
PRESENTATIONS
INTRODUCTION - 5 MIN. PAT M.
EPA CONCERNS - 5 MIN. JULIUS J.
DOL CONCERNS - 5 MIN. JANIS C.
EMPLOYESS
CONCERNS - 5 MIN. BARBARA W.
CARBON MONOXIDE &
CARBON DIOXIDE - 10 MIN. TOM S.
FORMALDEHYDE - 5 MIN. NORM B.
CHEM. SENSITIVY,
& RECENT CLAIMS - 15 MIN. Dr. O
PANEL • ABOVE NAMED
Q&A PERIOD
(40 MIN. OR AS REQUIRED)
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EFFORTS YOU MIGHT TAKE TO IMPROVE YOUR WORK ENVIRONMENT
FOR LOCALIZED NOISE CONTROL. The following suggestions are offered:
• MINIMIZE GROUP DISCUSSIONS IN OPEN OFFICE AREAS. DO NOT HOLD EXTENDED
CONNVERSATIONS "OVER" PARTITIONS, ACROSS OR IN AISLES OR THE ATRIUM.
• KEEP TELEPHONES ON "LO", AND KEEP CONVERSATIONS etc.. AT REASONABLE SOUND
LEVELS - TALK LIKE YOU WANT TO KEEP IT CONFIDENTIAL.
0 USE TELEPHONES FOR BUSINESS ONLY, AND KEEP CONVERSATIONS BRIEF.
• ARRANGE FOR ACOUSTICAL TREATMENT OF (WALLS AND CEILINGS OF) SELECTED OFFICES
TO REDUCE SOUND TRANSMISSION, WHEN PRIVACY IS CRITICAL.
• POST "PLEASE KEEP THIS AREA QUIET1 SIGNS, AS MAY BE NEEDED.
• RESPECT OTHER PERSONS' NEEDS.
FOR CONTROL OF VISUAL AND ERGONOMIC STRESSES. The following steps may be helpful:
t ADJUST CHAIR HEIGHT TO MINIMIZE (1) GLARE/CONTRAST, AND (2) POSTURAL PROBLEMS.
o USE SUPPLEMENTARY LIGHTS IN POOR LIGHTING SITUATIONS.
• USE AN ANTI-GLARE SCREEN; ADJUST SCREEN POSITION FOR OPTIMUM COMFORT.
• USE A YELLOW (CELLOPHANE FILM) FILTER ON THE OUTSIDE OF THE LENS OF THE UNDER-
CABINET DESK LIGHTS.
9 USE A BLACK DESK PAD FOR IMPROVED CONTRAST AND COMFORT IN READING.
• WHEN USING A PC, TAKE FREQUENT BREAKS -- REST YOUR EYES; STRETCH YOUR BACK
AND NECK MUSCLES, AND SHAKE YOUR WRISTS AND FINGERS TO RELAX THEM.
• SUPPORT YOUR LOWER FOREARMS IN FRONT OF THE KEY BOARD (A 20" x 6" x 3/4" FOAM
PAD WILL BE USEFUL). CONTROL FINGER IMPACT FORCE IN STRIKING THE KEYS.
PERIODICALLY, LIGHTLY MASSAGE YOUR FINGERS AND WRISTS.
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