UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
,
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A Consolidated Report Of
Evaluations and Transactions - -
Indoor Air and Work Place Environmental Qualities.
EPA Region 1 Occupied Spaces.
One Congress Street. Boston, MA.
N. A. Beddows, CIH, CSP.
February 28, 1991.
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A Consolidated Report Of Evaluations and Transactions - -
Indoor Air and Work Place Environmental Qualities.
EPA Region 7 Occupied Spaces. One Congress Street. Boston, MA.
N. A. Beddows. CIH. CSP.
February 28, 1991
ABSTRACT
This is a consolidated report and record of previously and separately reported evaluations of indoor air
and environmental qualities and related transactions, and new information dealing with employees'
assessments or complaints of facility conditions, and perceived or actual medical symptoms, as reported
upon by a Public Health Service physician. Also, summary data, for the period of November 1990 to
February 1991, on formaldehyde, target volatile organic compounds and illuminance are provided, as
appendices.
s
In August 1990, federal employees moved from The J.F.Kennedy building to nearby One Congress
Street, Boston. One Congress Street is a low rise building with eleven floors: garage spaces which are
sprinkler protected, on the lower nine levels, and two newly-constructed, sprinkler protected office floors
above. Several Agencies occupy space on the office floors. The total occupied space area is
approximately 231,000 square feet. The total occupancy is about 1200 people; about 550 occupants are
employees of the US. Environmental Protection Agency. The Facility is a no-smoking one. A designated
smoking room exists on the tenth floor, for the use of every agency. Ventilation is achieved by a modern
variable air volume system with conventional filtration. Offices are both enclosed and open, and are of
the usual sizes. For the most part, the floors are very open, and each floor has atrium space in the
centers. The furniture is modular in type, manufactured by Herman Miller, Incorporated. The flooring
is nylon carpet panels. At installation, the carpet squares were secured using a water based, polyvinyl
acetate copolymer adhesive. The wall surfaces were painted using a water-based PVC latex paint. Some
wood work and trim were painted or varnished with solvent-bearing preparations.
Formal complaints and several dozen informal complaints were made to the safety office by EPA
employees on both floors involving claimed chemical sensitivity or one or more complaints of eye
irritation, (upper) respiratory tract irritation, headache, and excessive skin dryness and itching.
In early December, preliminary evaluations were made of the forced ventilation of the work places,
ergonomic stresses, carbon monoxide, carbon dioxide, formaldehyde and dust levels. The findings were
generally favorable, and were presented at an all-employee meeting on 12/21/90. After the December
meeting, work was undertaken to: evaluate target volatile organic compounds (toluene, benzene, diAri-
substituted benzenes, chlorinated alkanes and alkenes, C5 and longer straight chain hydrocarbons,
ketones, and alcohols) in the work place; and, establish a medical type questionnaire for the confidential
reporting of employees' concerns or complaints to the management, through a public Health Service
physician, and a questionnaire to report complaints to the Facilities Branch Chief. Also, other aspects
of evaluating indoor air and work place environmental qualities also were considered. These matters are
reported on to employees through a supplementary report dated 1/27/91, and a second open meeting.
The summary findings to date are that the ventilation (fresh air in) level is fully satisfactory. However,
there are localized problems of thermal balance and air-throw, especially at the corner-wall locations
on both floors. There is no infiltration of carbon monoxide from the garages below. Formaldehyde level
is consistently low. The level of target volatile organic compounds are consistently low. Dust level is low,
and no inorganic fibrous mineral is present in dusts; Lead in drinking water has been tested, and is not
a problem. Noise and illuminance are localized problems. Excessive dryness of air is a seasonal problem
on both floors. The frequency of complaints formally raised to date is low. Approximately one hundred
responses to the medical questionnaire have provided to the occupational physician. Analyses of
complaints in these questionnaires will take some time, and will be made available by the physician.
Based on the quantitative assessments which we have made, and which are reported herein, the writer
believes that there are no recognizable health hazards in the work places.
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I. ACKNOWLEDGMENTS.
Dr. Tom Spittler and Mr. Peter Kahn made the on-site analyses of carbon dioxide,
carbon monoxide gas and target volatile organic compounds analyses using portable
infra-red (Miran) and GC-PID (Photovac) equipment. Dr. Mary Beth Smuts arranged
for the initial formaldehyde (passive dosimeter) evaluations, made by the state of
Massachusetts.
Mr. Howard Davis provided analyses of supplied dusts. Mr. Robert Wade gave me
the lighting survey data. Mr. Jeffrey Davidson, Mr. David Smith and Mr. Julius Jimeno,
provided information on materials and outgassing, and helped me by their discussions
and comments. Mrs. Barbara White helped in arranging the employee lAQ-survey, as
did Dr. Alvero O'Campo, who kindly agreed to confidentially appraise the returned
medical questionnaires.
I gratefully acknowledge the truly excellent cooperation and assistance which these
colleagues have given me.
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Table Of Contents In Order Of Presentation.
I. Acknowledgment
II. Introductory Remarks.
III. Incorporated Materials.
o A Summary Report Of A Preliminary Evaluation, 12/21/90.
o Open Meeting Announcement. Meeting Of 12/29/90.
With Agenda and Hand-out.
o Report Of A Study Of The Operation & Capacity Of The HVAC
System.
o Report Of The Meeting Of 12/29/90.
o Supplementary Report of 1/27/91. An Addendum To The Summary
Report Of 12/21/90.
o Notice Of Update Meeting.
o Report Of Update Meeting.
o View-Graphs Shown In The Update Meeting.
o Letter Of Request To Complete Questionnaires.
1. Medical Questionnaire.
2. Facilities Questionnaire.
o Letter To the Occupational Physician.
o Current Information From Questionnaires
IV. General Discussion.
V. Summary Of Conclusions.
VI. Recommendations.
Appendix
1. December, 1990 Formaldehyde Data (Beddows et al).
2. December, 1990 Target VOC Data (Spittler et al).
3. Febuary, 1991 Illuminance Data (Wade, R.).
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II. INTRODUCTORY REMARKS.
In August 1990, EPA employees moved from The J.F.Kennedy building to nearby One
Congress Street, Boston. Approximately 600 employees and contractors' staff relocated
to assigned space of approximately 190,000 square feet.
One Congress Street is a low rise building with eleven floors: garage spaces which
are sprinkler protected, on the lower nine levels, and two newly-constructed, sprinkler
protected office floors above. Several Agencies occupy space on the office floors.
The total occupied space area is approximately 231,000 square feet. The total
occupancy is about 1200 people. The Facility is a no-smoking one. A designated
smoking room exists on the tenth floor, for the use of every agency. Ventilation is
achieved by a modern variable air volume system with conventional filtration. Offices
are both enclosed and open, and are of the usual sizes. For the most part, the floors
are very open, and each floor has atrium space in the centers. The furniture is
modular in type, manufactured by Herman Miller, Incorporated. The flooring is nylon
carpet panels. At installation, the carpet squares were secured in place by a partial
application of a water based, poly vinyl acetate copolymer adhesive. The wall surfaces
were painted using a water-based PVC latex paint. Some wood work and trim were
painted or varnished with solvent bearing preparations. This treatment was minimal with
respect to surface area. Also, for several months after the first occupancy, part of the
eleventh floor was in construction; this part was essentially walled in and off-limits to
all occupants.
Shortly after the relocation and for a period of several months, several formal
complaints and several dozen informal complaints were made to the safety office by
occupants of both floors. These involved two complaints of chemical sensitivity.and a
dozen or so complaints of eye irritation, (upper) respiratory tract irritation, headache,
and excessive skin dryness and itching.
In early December, the writer began a preliminary evaluation of the forced ventilation
of the work places and looked at some aspects of ergonomic stress. Later in the
month, evaluations of carbon monoxide, carbon dioxide, formaldehyde, and dust levels
were made by T. Spittler, Howard Davis and the writer. These evaluations were
reported in a formal report, issued 12/21/90 by the writer. Also, they were presented
at an all-employee meeting, held on 12/21/90. The report was made available to all
employees in January, 1991.
As a outcome of the December meeting, additional work was undertaken to:
e Evaluate target volatile organic compounds (toluene, benzene, diAri-substituted
benzenes, chlorinated alkanes and alkenes, C5 and longer straight chain
hydrocarbons, ketones, and alcohols) in the work place.
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• Establish (i) a medical type questionnaire for the confidential reporting of
employees' concerns or complaints to the management, through a public Health
Service physician, and (ii) a questionnaire to report complaints to the Facilities
Branch Chief.
Other aspects of evaluating indoor air and work place environmental qualities also were
considered. All of these matters were formally reported in a supplementary report dated
1/27/91, by the writer. The supplementary report was made available to all employees
in February, 1991.
The purpose of this consolidated report is twofold. It is to (i) bring together all of the
information of the evaluations and transactions which took place in the period from
early December 1990 to late February, so that a comprehensive record can be
established in one place; and (ii) provide information which may be useful in addressing
any future complaints and in other programs for looking at issues of indoor air and
work place environmental qualities.
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III. INCORPORATED MATERIALS.
The following materials are directly incorporated in this report in order to establish a
single, comprehensive record:
• A Summary Report Of A Preliminary Evaluation, 12/21/90.
• Open Meeting Announcement. Meeting Of 12/29/90.
With Agenda and Hand-out.
• Report Of A Study Of The Operation & Capacity Of The HVAC System.
• Report Of The Meeting Of 12/29/90.
• Supplementary Report of 1/27/91. An Addendum To The Summary Report.
• Notice Of Update Meeting.
• Report Of Update Meeting.
• View-Graphs Shown In The Update Meeting.
• Letter Of Request To Complete Questionnaires.
(1) Medical Questionnaire. (2) Facilities Questionnaire.
• Letter To Occupational Physician.
• Current Information From Questionnaires.
• Copies of Notices.
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THE SUMMARY REPORT OF 12/21/90.
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A Summary Report of a Preliminary Evaluation.
Indoor Air and Work Environmental Qualities.
EPA Region 1-Occupied Spaces, One Congress Street.
And Identified Opportunities for Improvement.
N. A. Beddows. CIH, CSP.
December 21, 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 formaldehyde
indoors; ventilation criteria and system extractor sizing Jor 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.
Results of quantitative tests are presented. The levels of carbon
monoxide, carbon dioxide, and formaldehyde, together with the
evidently low occupant density and other relevant points, indicate
that (i) the HVAC mechanical ventilation fresh air supply, and (ii) the
air quality in the office spaces are generally fully satisfactory.
Matters of observed localized temperature variations, work place
noise and Ulumination. lighting glare and contrast; and claimed
personal discomfort involving irritation of the eyes and upper
respiratory tract are discussed. Also, related potential problems are
identified. These include: personal practices; physical arrangements,
and certain cleaning operations conducted during the mid-moming
and later periods (involving the use of strong chemical spray
cleaners and "feather-dusting" - with redistribution of any settled
dust). 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 vahiative 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. This covers: scope-of-work: project costs and
durations; and contractual considerations for assuring cost
effectiveness and good work-quality.
Post-script. This report is supplemented by a formal report dated January 21.1991.
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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
it might be useful in part for this purpose.
Four sections are presented which deal with the following major points, and some
others:
A. Background Information. This covers carbon dioxide (CO2), carbon monoxide (CO),
other possible indoor pollutants (dust, volatile/semi-volatile organic compounds, lighting
and noise) and ventilation.
B. Test Results. These cover (i) CO2 and CO test results of tests made on 10/22/90
of EPA spaces by T. Spittler, ESD Laboratory Director;(ii) formaldehyde test results re:
tests (eleven in total) of the 10th and 11th floors, made in the November-December
period by the writer; and (iii) other pertinent observations and facts.
C. Discussion. Re: reported chemical test results and other observations and facts.
D. Other Matters. These cover (i) the employer's duty; (ii) prudent actions; (iii)
opportunities for improvement of work place quality and employee morale, including
steps that employees can take directly; and (iv) 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 parts C and D relate to comfort or personal productivity.
These points are discussed from an industrial hygienist's viewpoint; other people may
reasonably disagree with what is 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.
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A. Important Background Information
1. Carbon Dioxide Indoors
1 .a. 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 DOL/OSHA CO2 standard includes a permissible exposure limit (PEL) of 5000
ppm. This limit is based on the risk of asphyxiation, not on IAQ industrial
hygiene/ventilation needs. The OSHA-PEL has no value as an lAQ-standard.
1.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 over 1000 ppm 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.
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
modern, no-smoking office environment; and (2) any CO concentration greater than two
parts per million would be cause to make an investigation of infiltration of contaminated
air from a nearby garage or combustion site.
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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 particulate - 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 Smokina-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 2]/[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.
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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 (50 ft-cdle?) 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.
5.d. Detail work (drawing, mapping) may need at least 100 ft-cdle. of illumination at the
task surface; a general office requires lighting levels at desk surfaces of at least 50
ft-cdle., and some people would find this level to be marginal for their needs.
5.e. The OSHA safety illumination standard (at 29CFR 1910/1926), 30 ft-cdle for
offices, is marginal for reading and working in a modern office setting.
5.f. 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 modern 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 minor irritation
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hydrocarbons include compounds which are capable of causing local minor irritation
(eye, respiratory tract) to some people at/above some low (a few parts per million)
threshold level, with relatively short (a few hours) exposures. 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-phenylcyclohexene, 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 7.a have characteristic odors, and
can be (subjectively) detected by odor and/or local irritation (eye blinking), at a few
parts per million concentration. Some strongly irritating compounds (dienes, mercaptans,
aldehydes) can be detected similarly at or below a part per billion concentration.
Formaldehyde (and some other VOCs) irritate ones eyes and respiratory (URT) at less
that the corresponding odor detection threshold concentration (which is a fractional part
per million).
9. Formaldehyde in Newly or Recently Furnished Office Spaces
9.a. Formaldehyde may be present in (and diffuse from) new furniture, depending on
the construction materials used. It may exist in offices at concentrations which cause
eye irritation or respiratory distress to some occupants. The peak concentration will
depend on the particular emissivity (temperature dependent!) of the furniture pieces in
the case, the number of pieces in place, the ventilation turn-over time (the reciprocal
of the air exchange rate) and other factors. With passing time, the concentration of
formaldehyde (and any other VOC) in the furnished, ventilated space will decrease in
a logrithmic fashion.
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9.b. A significant percentage (10 - 20% ?) of the population are hypersensitive to
formaldehyde. Hypersensitivity to formaldehyde and other haptens may be
demonstrated using standard Type 1 allergenic tests (direct skin; RAST); and, in some
cases, by a respiratory air flow restriction, as measured by FEV, „ spirometry.
NOTE. People of ordinary sensitivity may experience irritation of the mucosa upon
short-term exposure to formaldehyde at concentrations which they may be unable to
detect by its distinctive, pungent odor.
9.c. The (i) average-person's (approximate) odor detection limit, and (ii) the action level
is 0.05 ppm (50 parts per billion).
9.d. lA-formaldehyde measurement can be made inexpensively using a 7-day passive
dosimeter in conjunction with the universally used, chromatropic acid-spectrographic
analytical method. A slightly more expensive but more accurate ( reported resolution,
5 ppb; CV = 10%, claimed) method, based on passive dosimetry with DNPH-HPLC
(2,4-dinitrophenylhydrazine reagent, with high performance liquid chromatography), is
available from the GMD Co., Hendersonville, PA. 412 742-3600. This company also
makes/analyses toluene diisocyanate (TDI) dosimeters, for use in evaluating urethane
foam-rubber "outgassing" problems.
9.e. The 7-day exposure/chromatropic acid, passive dosimeter's limit of detection is
reported to be 20 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 five (?) or more may be appropriate to apply to the reported
limit of detection, when reviewing data close to the claimed limit of detection. An
interesting corollary, given the reported odor detection limits, is that a person with a
sensitive smell for formaldehyde may be able to grossly classify indoor air, in terms of
the formaldehyde action level (0.05 ppm), with about the same accuracy as a passive
(chromatropic acid chemistry) dosimeter, while other persons may not smell it.
9.f. The outdoor air formaldehyde level is approximately 0.005 ppm (MA-DPH data).
9.g. 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 few 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.
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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 relative humidity (e.g., 15% -20
% R.H.) 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 concentrations, and health or comfort appears to be largely unknown. However,
a 1985 study by L. Molhave et at, 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-FID);
duration 2 3/4 hours. Accordingly, total volatile organic compound level, "measured"
as toluene, by GC.FID, at about 1 ppm is considered by the writer to be the very
outside upper limit for offices. One should apply an uncertainty (safety) factor of at
least 10 to "set" an upper limit for permissible hydrocarbon contamination, in the
writer's judgment.
12. Outclassing 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 "outgas." 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.
12.b. It is now (well reported) 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. Its value is negated by
a daily use of solvent-containing cleaners.
13. Other lAQ-Factors.
13.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.
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8
13.b. Volatile organic compounds (including formaldehyde) can not be directly removed
from circulating air using a high efficiency paniculate (HEPA) filter, as is sometimes
asserted.
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 situation is distinct from those involving
those conditions which are fully recognized to exist, affect perhaps 20% of the
population, and have a known etiology (such as IgE-mediated allergic response of
asthma with re-exposure to methylene diisocyanate; hay fever, from pollen).
Some medical authorities, while obviously recognizing immunity as a basis for allergies,
and 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). Some others who are similarly aware of the
immunologic aspects appear to content that it low level chemical exposures invariably
are responsible for some claimed "chemical sensitivity' effect.
14.b. A few volatile/semi-volatile organic chemicals (dienes, aldehdydes) which may
occur in some offices and homes environments are evidently capable of acting as local
irritants at low (parts per billion) concentrations, and they may act systemically in some
known mechanistic way at somewhat higher levels. However, the notion that chemicals
at trace concentrations universally act singly or in concert in some currently unknown
mechanistic way to adversely affect the health of, or incapacitate, individuals in general,
as appears to be the case made by some doctors, is disputed by many allergists and
other medical clinicians. Some experts express difficulty in seeing a diagnostic
significance to such claims, and question the value of on-going, lifetime-duration "shot"
treatments (versus periodic/seasonal drug treatment) which some doctors prescribe.
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.
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B. Results of (1) COj/CO, and (2) Formaldehyde Tests. Other Observations.
1. CO,. CO Tests.
1.a. Dr. Tom Spittler, 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).
1.b. The maximum CO2 concentration reported for any office space was 360 ppm.
Also, the average of the reported CO2 levSte is comparable to the outside level.
I.e. 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): 0.018 part per million.
CLOSED TYPE OFFICE (364): 0.023 part per million.
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. The cleaner used is 3M's "Trouble-Shooter."
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10
(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:
o The presence of trace amounts of ozone at the time when cleaning solvents
are used (as has been observed by the writer) may increase the risk of acute
eye irritation in the computer room, via either actual products of reaction of the
pollutants (peroxy organic compounds: strong eye irritants) or by an additive or
synergistic effect.
(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. This is an unknown factor at this time.
As in any office, it might be a seasonal concern.
(vii) Illumination level and "open- grid" fluorescent lights have been mentioned as a
problem by some employees, who describe the problem as one of feeling the need to
wear eye-shades (visors).
NOTES:
• Light fixture placement has been mentioned as a reason for the perceived
poor level of lighting in some situations. Dark carpeting and furnishings in areas
remote from the atrium may require being off-set by additional overhead lighting,
and/or repositioning of existing fixtures for balance.
• 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.
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11
(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.
(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.
(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.
NOTES:
• Hoods can be used (and required to be consistently used) to control such
noise generators.
• 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.
4. Extent and Seriousness of the Expressed or Evident Concerns.
4.a. The concerns described in section C.S.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.
4c 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.
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12
C. Discussion
1. HVAC-Ventilation
1 .a. 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 not less than about 8 cfm per person, using information in
the "Industrial Ventilation" handbook (in this case, the carbon dioxide level / ventilation
/ occupancy density - curves did not allow any higher value to be estimated).
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 CO2
concentrations from rising over about 500 ppm; and (iii) the removal of objectionable
body and furnishing-type chemical odors which might otherwise be present.
l.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.
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13
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 shin 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.
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 (such an undertaking would be relatively inexpensive and short-term).
(iii) Daily "feather-dusting" is less preferred than vacuuming.
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4.c. Employer's Duty.
(i) 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.
(i) 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.
1.b. Use a yellow (Cellophane) filter on (the outside of) the cabinet lights for material-
reading comfort.
1 .c. Use an anti-glare (PC) screen to reduce eye strain and fatigue.
1 .d. Use (flat-black) desk-pads to reduce desk level glare, and improve reading comfort.
1 .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 the following 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.
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15
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. The 10th floor copying room is a candidate for improvement (isolation-ventilation).
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 = 15% ?) 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:
o MINIMIZE GROUP DISCUSSIONS IN OPEN OFFICE AREAS. DO NOT HOLD
EXTENDED CONVERSATIONS "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. USE TELEPHONES FOR BUSINESS ONLY. AND, KEEP
CONVERSATIONS BRIEF.
• ARRANGE FOR ACOUSTICAL TREATMENT OF (WALLS AND CEILINGS OF)
SELECTED OFFICES TO REDUCE SOUND TRANSMISSION.
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16
• POST "PLEASE KEEP THIS AREA QUIET" SIGNS, AS MAY BE NEEDED.
o RESPECT OTHER PERSONS' NEEDS.
FOR CONTROL OF VISUAL AND ERGONOMIC STRESSES: These steps may help:
e ADJUST CHAIR HEIGHT TO MINIMIZE (1) GLARE/CONTRAST AND (2)
POSTURAL PROBLEMS.
• USE SUPPLEMENTARY LIGHTS IN POOR LIGHTING SITUATIONS.
e 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.
e USE A BLACK DESK PAD FOR IMPROVED CONTRAST AND COMFORT IN
READING.
e 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 KEYBOARD (A
20" x 6" x 3/4" FOAM PAD WILL BE USEFUL WHEN PLACED AT THE LEVEL
OF, AND ABOUT TWO INCHES FROM, THE KEYBOARD. CONTROL FINGER
IMPACT FORCES. PERIDICALLY DO RELAXATION EXERCISES.
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.
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17
5.b. The chemical analytical schemes and methods, and the physical testing in the
case of an acoustical investigation which might be used 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 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 in 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 using measured CO2 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 hypersensitive to formaldehyde), whenever there is an actual lAQ-problem one
would expect to "see" a corresponding level of specific complaints - not merely a few
assorted ones - from a large (several hundred) and vocal occupant population.
8.d. Individuals who need medical help for some condition or suspected allergy may
want to ensure that the treating physician is fully trained in allergy - one who has
passed the examination administered by the American Board of Allergy and
Immunology.
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18
APPENDIX
1. NOTICE OF OPEN MEETING
2. PROPOSED AGENDA
3. ADVISORY NOTICE - WAYS TO IMPROVE THE
WORK PLACE ENVIRONMENT.
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OPEN MEETING ANNOUNCEMENT.
MEETING OF DECEMBER 21, 1990.
AGENDA & HANDOUT
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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.
Janis E. Carreirro, 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 MINUTES OR AS REQUIRED).
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TO EMPLOYEES •- EFFORTS YOU MIGHT MAKE 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 CONVERSATIONS "OVER" PARTITIONS. ACROSS OR IN AISLES OR
THE ATRIUM.
• KEEP TELEPHONES ON "LO", AND KEEP CONVERSATIONS etc.. AT
REASONABLE SOUND LEVELS. TALK CONFIDENTIALLY.
t MIMIMIZE THE USE OF TELEPHONES; AND KEEP CONVERSATIONS BRIEF.
e 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 PERSONS' NEEDS.
FOR CONTROL OF VISUAL AND ERGONOMIC STRESSES. Take these Steps:
• ADJUST CHAIR HEIGHT TO MINIMIZE (1) GLARE/CONTRAST, AND
(2) POSTURAL PROBLEMS.
• USE SUPPLEMENTARY LIGHTS IN POOR LIGHTING SITUATIONS.
e USE AN ANTI-GLARE SCREEN; ADJUST SCREEN POSITION FOR
OPTIMUM COMFORT.
e 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).
e CONTROL FINGER IMPACT FORCE IN STRIKING THE KEYS.
• PERIODICALLY. LIGHTLY MASSAGE YOUR FINGERS AND WRISTS.
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REPORT OF STUDY OF OPERATION &
CAPACITY OF THE HVAC-SYSTEM
JANUARY 15,1991
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REO.ON,
J F. KENNEDY FEDERAL BUILDING. BOSTON. MASSACHUSETTS 02205-2211
SOME COMMENTS ON THE ACTUAL VENTILATION (DESIGN, OPERATION, CAPACITY,
ISSRSS STANDARDS) OF THE HVAC SYSTEM and PERCEIVED COMFORT -
EPA OCCUPIED SPACE, ONE CONGRESS STREET, BOSTON, MA
N.A. Beddows
1/15/91
THE FOLLOWING COMMENTS AND POINTS ARE BASED ON ™E WRITERS
SINCE THESE[EITHERI DO NOT EXIST OR ARE NOT CURRENTLY AVAILABLE TO THE
WRITER.
A. ACTUAL VENTILATION
UNITS.
WRITER) FROM THE SYSTEM COMPUTER TERMINALS FOR EACH AND EVERY VAV UNIT.
3 A TOTAL OF 168 VAV UNITS COMPRISES THE INTERIOR AIR SUPPLY AND AIR HEATING
PORTION OF THE TOTAL SYSTEM. AT ANY ONE TIME IN A WORKDAY. MOST (90%) OF THE VAV
UNITS OPERATE SIMULTANEOUSLY.
MX/AC SYSTEM SERVES A CURRENT COMBINED POPULATION OF
TWO FLOORS WITH A COMBINED AREA OF
225.000 SQUARE FEET.
FOR THE ENTIRE FACILITY.
PRINTED ON RECYCLED RAPE"
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•2-
6. THE 1989 ASHREA -VENTILATION FOR ACCEPTABLE INDOOR AIR QUALITY- STANDARD «62-
1989. AT TABLE 22, -INSTITUTIONAL FACILITIES -CLASSROOMS. LIBRARIES. AUDITORIUMS-.
REQUIRES A MINIMAL VENTILATION RATE OF 15 CFM PER PERSON (LOW-RISE OFFICE
VENTILATION IS NOT SPECIFICALLY ADDRESSED). THIS REQUIREMENT IS BASED ON
ATTAINING COMFORT. AND CONTROLLING ODOR AND CARBON DIOXIDE LEVELS TO ASSURE
AN ADEQUATE MARGIN OF SAFETY AND HEALTH.
7. EPA GUIDANCE (NOW IN DRAFT FORM ONLY)
REQUIREMENT IN THE ASHRAE 62-1989 STANDARD.
REFERENCES THE VENTILATION
FIGURE 1 ILLUSTRATES THE BASIC VAV UNIT CONFIGURATION.
2>AMP£Ji
WftU.
Co in A.
bursioi
AtR $
OCCUf>lLl>
S'*C£
o-
FIXE.D SUPPLY
PAW
OFHSATK&S (PACALLEL
HAS
FIGURE 1. BASIC VAV CONFIGURATION.
BASED ON THE ABOVE MATTERS OF ACTUAL VENTILATION. AND WITH DUE REGARD TO OTHER
STUDIES ( i.e., carton dioxide, carbon monoxide, tormaldeyde) REPORTED ON 12/20/90. THE
WRITER BELIEVES THAT THE ACTUAL VENTILATION AT ONE CONGRESS STREET, EXCEEDS (BY
160%. IN THE CASE OF OUTSIDE AIR PER PERSON SUPPLY) THE VENTILATION RATE NEEDED
FOR HYGIENE FOR THE CURRENT LEVEL OF OCCUPANCY. ALSO. THE WRITER JUDGES THE
INTERIOR SPACES AND THE VENTILATION SUPPLY AIR TO BE CLEAN. BASED ON DUST TESTS
MADE IN EARLY JANUARY BY THE WRITER (REPORTED ON SEPARATELY IN A JANUARY
REPORT PRESENTED AS AN ADDENDUM TO THE DECEMBER 21. 1990 IAQ-REPORT.
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B. COMFORT LEVEL
1 IN THE FIRST AND SECOND WEEKS OF JANUARY. NUMEROUS COMPLAINTS OF BEING COLD
WERE RECEIVED FROM EPA EMPLOYEES, ESPECIALLY THOSE LOCATED IN EPA (and DOL)
OFFICES ABUTTING THE SOUTH-WEST WALLS OF BOTH FLOORS.
2 IN SOME OFFICES. THERE APPEAR TO BE PROBLEMS OF (I) A COLD DRAFT FROM ABOVE
HEAD HEIGHT LEVELS. AND (ii) SIGNIFICANT. I.E.. GREATER THAN 4-5 DEGREE (F) DIFFERENCE.
TEMPERATURE GRADIENTS. FROM DESK TOP TO FOOT LEVELS.
3 TEMPERATURES IN THE ELEVATORS HAVE BEEN RATHER FRIGID. AT TIMES. LARGE AREAS
OF THE FLOOR AREAS ADJACENT TO THE ELEVATORS HAVE BEEN FRIGID.
4 TEMPERATURE SETTINGS ARE SET FROM CONTROLLERS MOUNTED AT 4 FOOT HEIGHTS
ON THE WALLS. HOWEVER. THE COLD IS MOST KEENLY FELT. ACCORDING TO THE
COMPLAINANTS. AT FOOT LEVEL.
5. THE NET EFFECT IS PERCEIVED BY MANY TO BE DISTINCTLY UNCOMFORTABLE. AT THIS
TIME.
6 IT IS WELL ESTABLISHED IN INDUSTRIAL HYGIENE THAT PERCEIVED COMFORT RELATES
TO AIR MOVEMENT. ROOM (DRY BULB) TEMPERATURE. AND RELATIVE HUMIDITY. ALSO. AS
RELATIVE HUMIDITY FALLS (AS OFTEN HAPPENS IN WINTER MONTHS). TEMPERATURES MUST
BE INCREASED TO MAINTAIN EQUIVALENT COMFORT LEVEL.
7 BASED ON LONG STANDING ASHRAE CRITERIA FOR COMFORT FELT BY THE MAJORITY
(97%) AT ANY EXTENSIVELY (I.E.. 3 HOURS/DAY) EXPOSED PART OF THE BODY. WHEN ROOM
AIR MOVEMENT IS IN THE NORMAL RANGE OF 15 -25 FEET PER MINUTE (AND BEARING IN MIND
THAT RELATIVE HUMIDITY OFTEN CAN BE 30 %, OR LOWER. INDOORS IN OFFICES. IN THE
WINTER MONTHS), ONE WOULD WANT TO 'SEE' THE TEMPERATURE AT THE EXPOSED SKIN
LEVEL TO BE ABOUT 72 DEGREES F.
8 SINCE THE SENSORS ON THE WALLS ARE SHIELDED FROM DRAFT AND EVEN NORMAL AIR
TURBULENCE (WHICH COULD ACTUALLY BE AT RELATIVELY LOWER TEMPERATURE - OF
COURSE THERE IS NO CHILL FACTOR INVOLVED WITH INSTRUMENTATION) AND THEY ARE
PLACED'AT LEAST THREE FEET HIGHER THAN FOOT LEVEL. AND SINCE SIGNIFICANT
TEMPERATURE GRADIENTS EVIDENTLY EXIST BETWEEN DESK TOPS AND FOOT LEVELS. AT
LEAST IN SOME OFFICE LOCATIONS. THERE IS AN EVIDENT NEED TO SET SOME WALL UNIT
CONTROL TEMPERATURES HIGHER THAN THEY ARE HAVE BEEN SET IN THE LAST SEVERAL
COLD DAYS.
IN CONCLUDING ON THE COLDNESS COMPLAINTS. WHILE AN ISSUE OF WHO DOES WHAT MAY
EXIST IN THE MATTER OF SUPPLYING HEAT. THERE SHOULD BE NO ISSUE ON THE POINTS.
RELEVANT TO THE SITUATION AS OF THIS DATE. THAT:
• MORE HEAT IS NEEDED THROUGHOUT AT THE TIMES OF COLD DAYS.
• IMPROVED CONTROL OF HEATING WITH VENTILATION IS NEEDED.
• CONTROL OF (COLD) DRAFTS IS NEEDED IN SOME OFFICE AREAS.
• ELEVATORS NEED HEATING.
• THE 10th AND 111h FLOOR FOYERS ADJACENT TO THE ELEVATORS NEED HEATING, OR
IMPROVED CONTROL OF THE EXISTING HEATING DEVICES.
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CALCULATION OF REQD. VENTILATION.
SMOKING ROOM AT ONE CONGRESS ST.
1. Rubin Co proposal: 1/4 HP/ One phase. 3/8 inch water static
(duct) drop, for 800 cfm.
2. 800 cfm from ?
3. EPA ORDER: "at least 60 cfm/person. of FRESH air." Order does
not say all vent, air must be fresh. N.B. CAN NOT RETROFIT at
this point. Use equivalent amount of interior air.
4. Rubin says "20 % intake air in supply air to floor(s)."
Then, use (60 x 5) 300 cfm/person, floor air (supply) for
ventilation.
5. Assume 10 active smokers at any one time. We need 3000 cfm
of supply air from the general ventilation.
6. Velocity pressure (VP) is - 3000 = 4005 x 0.8 (Ce) (VP) El/2.
(3000/3200)El/2 -VP. O.9 El/2 - 0.8 inches of water for air
flow. TOTAL pressure -0.8 + 3/8 inches - 1.2 inches water.
7. A 1 HP fan at 60 % mechanical efficiency (a good number)
gives about 3700 cfm @ 1 inch total pressure drop. We need
3000 cfm.
Use (3000/3700) — 3/4 H.P., with the duct set up as
proposed.
THIS IS NOT A DESIGN SPEC. RUBIN CO IS RESP. FOR D.EJ3IGN .
/
Norm Beddows.
1/3/91.
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REPORT OF THE MEETING OF 12/21/90.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
! REGION!
J.F. KENNEDY FEDERAL BUILDING. BOSTON. MASSACHUSETTS 02203-2211
MEMORANDUM
DATE: December 24, 1990
SUBJ: Meeting of 12/21 re: Indoor Air Quality. Planned Additional Work.
FROM: N.A. Beddows
TO: Distribution
1. The Meeting
The above captioned meeting was well attended (47), given its
proximity to the year end. This meeting was scheduled for the earliest
date following on from the availability of the formaldehyde data ( which
were only made available on the 19th December). It had been realized
that the timing would not satisfy everyone's need, but it was also
realized that it was important to provide data and opportunities for'
questions at the earliest time; if a repeat presentation was needed,
this would be done. At this meeting, a summary report was distributed;
the key findings contained in the report were discussed.
2. Perceived Needs.
An outcome of the discussions which followed the brief technical
presentations was the perceived need to:
(a) conduct a survey using a format which could specifically
identify potential problems (and locations) in such a way that
response bias could be detected, and identities could be
protected from disclosure.
(b) perform a qualitative assessment of particulate in air in the
vicinity of HVAC (supply) dusts, with special regard to
siliceous material.
NOTE: a 0.8 micron, MCE filter/polarized light microscopy
method is recommended for this I.H purpose.
(c) perform a total VOC quantitative test re: the 10th and 11th
floors.
(d) hold another open, informative meeting in the near future.
3. Planned Actions to Address These Two Points Are As Follows:
(a) the writer will ask the Lexington Laboratory to perform
tests re: TVOC, and particulate. Such testing should be
completed if possible by late January 1991;
(b) the writer will convene a meeting in early January to arrange
for the survey to be established and implemented.
PRINTED ON RECYCLED PAPER
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SUPPLEMENTARY REPORT OF 1/27/91.
ADDENDUM TO THE REPORT OF 12/21/90.
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SUPPLEMENTARY REPORT
INDOOR AIR and WORK PLACE
ENVIRONMENT QUALITIES in EPA
OCCUPIED SPACE.
ONE CONGRESS STREET, BOSTON, MA.
N.A. Beddows, CIH, CSP
January 27, 1991
Addendum to
11 A Summary Report Of A Preliminary Evaluation
Of The indoor Air and Work Environment Qualities
of EPA Region 1 Occupied Space - One Congress
Street, Boston, MA. December 21, 1990."
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Acknowledgments
Dr. Tom Spittler and Mr. Peter Kahn made the carbon dioxide, carbon monoxide gas
and volatile organic compounds analyses by infra-red and portable GC-PID. Dr. Mary
Beth Smuts arranged for the initial formaldehyde measurements to be made by the
state of Massachusetts.
Mr. Howard Davis provided analyses of supplied dusts. Mr. Robert Wade gave me the
lighting survey data. Mr. Julius Jimeno, Mr. Jeffrey Davidson, and Mr. David Smith
provided information on materials and outgassing, and they helped me in other ways.
Mrs. Barbara White helped in arranging the employee lAQ-survey, as did Dr. Alverez
O'Campo.
I gratefully acknowledge the truly excellent cooperation and assistance which these
colleagues have given me.
N.A.B.
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Summary
Since the December 21 meeting on indoor air quality in One Congress Street, new
information and data have become available. This report deals with this material
Information and data are presented onfrumiture materials and VOC-outgassing;
dust in air; target VOCs in air; lead in drinking water; the design and operating
characteristics oj the HVAC system; ventilation-the supplying ojfresh air-and air
exchange rate in the building; luminance; relative humidity; employee (LAQ)
surveying; and opportunities to improve some matters of comfort and ergonomics.
Based on the information and data we have now collected and reported to all
affected EPA employees, the writer believes that:
9 The frequency of formal and referred employee complaints of health
problems is low (less than 1%) in regard to the total number of employees.
Also, the complaints raised do not appear to have been so severe as to
involve a significant amount of reportable lost work time.
9 Formaldehyde and volatile organic compounds, reported by the
manufacturer to be present as traces in the Herman Miller furnishings, are
not contaminating any EPA work place.
9 No infiltration of the offices by carbon monoxide is occurring from the
nine garage Jloors, immediately below the offices or any other place.
o Work places are very clean. Dust is very low, and no mineral fibers are
present in the indoor air.
9 The extent of forced ventilation of the two office Jloors is excellent, and
exceeds all known relevant and applicable standards
& There is no problem of lead in the water from the drinking fountains
9 Problems exist re: localized heating, drafrs, direct and rejlected lighting,
noise, and (winter) indoor air dryness. The current problems are not
classed as occupational recognizable health hazards. Correction of some
of these problems could be made in simple ways involving physical
rearrangements and personal practices; some others would require the
work of engineers and tradesmen (corrective actions were discussed in the
December 21, 1990 Report).
9 An in-depth environmental analysis is not currently justifiable. It would
be possible to extend the studies made to-date to include sophisticated
methodology employing off-site gas chromatography with mass
spectroscopy and other methodologies. Such methods would provide
evidence of the presence of trace amounts of a plethora of volatile and
semi volatile compounds in the indoor air from the furnishings and the
occupants, such is the great sensitivity of modem analysis. However, the
toxicologic significance of mere traces of organic compounds in indoor air
is unfathomable.
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1. Introduction.
An EPA - Region I Open Meeting on the captioned subject was held on December 21,
1990 at One Congress Street, Boston, MA. At this meeting we presented analytical
data on formaldehyde, carbon dioxide and carbon monoxide, and we provided an
evaluation of the quality of the work environment.
47 people attended. This small a number was expected. The date was close to the
year-end vacations. We knew that some people would not be able to attend this
meeting. Nevertheless, it was decided to hold it as planned to keep a promise to
employees to keep them fully informed on ongoing tests at the earliest opportunity -
which was December 21. The meeting followed the outline included in the Notice Of
Meeting, which is an appendix to the Summary Report, dated December 21, 1990.
During the discussion, several participants said that the presentation should be repeated
for others sometime in January. Also, several people asked to have an Indoor Air
Quality Questionnaire distributed so that employees' concerns could be made known
anonymously. One participant asked about siliceous material being in the air, and
expressed concern about fiberglass particles. Another person wanted information on
the modular furniture materials and "outgassing" of organic compounds, the VOC levels,
and the HVAC system operation and air recirculation. The concern expressed was
whether or not an adequate amount of fresh, clean air was being supplied to all the
office spaces.
It was agreed at the conclusion of the meeting that another one would be held soon,
and any new information also would be made available. The earliest available date for
holding this second meeting was determined to be January 31, 1991.
New information and technical data are now available. These deal with furniture
construction materials and outgassing; dust sampling and analyses; target volatile
organic compounds, and relevant standards; lead in water from drinking fountains; the
design, operation and capacity of the HVAC system; luminance in the work place; and
a format, based on a NIOSH IAQ Questionnaire, and a proposed protocol for
conducting an employee-survey.
The intent of this report, which is an addendum to the 12/21/90 Summary Report, is
to:
• Report New Information and Data on:
* Furniture construction materials and "outgassing"
* Target volatile organic compounds in indoor air.
* Dust suspended in indoor air.
• Disseminate Information on Lead in Drinking Water.
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e Report on the HVAC System and Work Place Ventilation.
a Discuss Ventilation and Relevant Standards.
• Mention Some Current Problems, and Opportunities.
• Present an lAQ-Survey Questionnaire and Protocol.
• Summate Principle Points and Findings.
2. Furniture Construction Materials and Outgassing.
2.1. Furniture.
The furniture installed in EPA spaces One Congress Street is manufactured by Herman
Miller Incorporated (HMI), Zeeland, Michigan. It is modular construction. It uses plastic
covered panel tops and files and drawers, and fabric covered acoustical and non-
acoustical panels. The cores of the panels and file cabinets are made of high density
press-board. And pine wood is used in some panels. Chairs contain closed cell
urethane foam.
The materials used, like any other furnishing materials, are potential sources of volatile
and semi-volatile organic compounds: specifically, formaldehyde, benzene, toluene and
terpenes, but also a host of derivatives of these and other parent classes. What is
important is not so much knowing every substance which may be evolved from these
materials, but what are the respective rates of evolution, and how do these rates
change over time in a ventilated office space.
2.2. Outgassing of HMI-Furniture.
Until recently, quantitative data on the outgassing of formaldehyde and other specific
volatile organic compounds from new furniture set-up in a typical ventilated office layout
were unavailable. This changed in early 1990, when HMI arranged for a study to be
made By Air Quality Sciences of the evolution of formaldehyde and other specific
organic compounds from a typical assembly of new HMI furniture in a moderately-
ventilated, test chamber.
The AQS Inc. report, entitled "Indoor Air Quality Evaluation of a Work-station for
Herman Miller, Inc., Report #01018-02, May 17, 1990" is available from Herman Miller
Inc., c/o Mr. T. Ankney, CSP, Senior Product Safety Engineer (616) 772-3577.
In the study, a representative office set-up of 72 hour old (newly-made) furniture was
used. The furniture was shipped in sealed plastic. The test chamber was ventilated
(2.53 air changes per hour), and held at 77 degrees Fahrenheit and 50% relative
humidity.
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Monitoring was conducted for a period of six weeks. The test conditions appear to
represent a credible conservative-case scenario, in the writer's judgment. All
the shipping, installation and testing arrangements were witnessed, as reported by HMI,
by the State of Washington.
The findings, reported by Air Quality Services, Inc., on formaldehyde and total volatile
organic compounds, were expressed in terms of a warm, average size (140 square
feet) office with average forced ventilation. Summarily, they showed:
1. A peak formaldehyde concentration of 15 parts per billion.
2. The (dynamically changing) first-day formaldehyde concentration was reduced
by fifty percent after 40 days.
3. The peak concentration of total volatile organic compounds (TVOC) was 250
micrograms per cubic meter.
4. The first-day, TVOC (mass) concentration was reduced by fifty percent in 5
days, and the rate of change was logarithmic.
These data and the information obtained from a discussion with Mr. Tom Ankney, CPS,
Senior Product Safety Engineer are consistent with the data which we now have on
this facility.
NOTES.
• The low (10-18 parts per billion in December, 1990) traces of formaldehyde
we had found in the work place air are believed to be from the HMI-furniture.
The levels found in December are close to the urban air background (10 ppb)
level. This is consistent with the expectation from the concentration and decay
data given in the referenced AQS study, and the facts that (i) ventilation of the
building is excellent, and (ii) the furnished office spaces were extensively aired-
out for three weeks before occupancy was allowed, and ventilation has been on-
going.
• In the case of volatile organic compounds in this building, assuming a first-
order decay with a half-life of about 5 days applies (which is reasonable judging
from the AQS-data), one would not expect now to "see" any appreciable VOCs
contamination, which in fact is the case.
• As a practical matter, the quantitative data which we now have on the EPA
office spaces in One Congress Street are very reassuring.
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3. Dust-in-Air.
3.1. Sampling. Preparation. Examination And Findings.
3.1.1. Sampling.
Sampling of dusts from the 10th and 11th floors occupied by EPA was performed in the
period 12/28/90 to 1/3/91 by the writer. These samples were examined subsequently
by the writer and, separately, Mr. Howard Davis, EPA Lexington Laboratory.
Samples of air-borne dust from each floor (locations: 10th floor: NAB-JL OFFICE AREA;
11th floor, ER OFFICE) were collected on 37 mm diameter, 0.8 micron pore size, MCE
filters, supported on pads in open-face cassettes. The cassettes were mounted laterally
at a height of 3 feet above the floor. A (precalibrated, orifice controlled) flow rate of
11 liters per minute was used. The sampling times were selected to be 2 1/2 hours,
based on prior experience in the methodology and similar environments. The sampling
periods employed were exactly timed.
The air-borne dust samples are identified as follows:
DUST SAMPLE A: 1980 liters of air. Collected 12/28/90. N.Beddows'/J. Lau' Offices
Aisle Space.
Note. The filter after (1980 litre) sampling was unstained. This indicates at least that
the air was free of coarse particulate (visual soiling increases as the squares of the
diameters of the visible-range particles).
SAMPLE B: 1903 liters of air. Collected 12/28/90. E.Riemer's office.
Note. The used filter was unstained indicating, at least, freedom from coarse particulate.
3.1.2. Preparation for Microscopy.
After sampling, the (two) filters were cut to provide I/8 sectors for examination. Each
sector was cleared using acetone, and covered with a slip-cover. The prepared wedges,
were (i) examined immediately by the writer, and (ii) preserved and respectively
identified by "NAB markers" for subsequent independent examination By Mr. H. Davis
( who was on vacation until 1/8/91).
3.2.3. Examination (Microscopy) And Findings.
3.2.3(a). Report of Findings-1/3/91.
The prepared wedges (Samples A and B) were examined on 1/3/1991 by the writer
using polarized light microscopy (PLM) to identify materials and (secondarily) size the
particulate. This involved looking at several hundred optical fields of each of the
prepared wedges using a nominal 400X magnification with PLM.
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DUST SAMPLE A (Note. The optical fields were scarcely loaded).
OBSERVED: Rough round mineral particles. Cellulose, cotton, and hair fibers.
j
ABSENT: Mineral fibers (e.g., asbestos, fiberglass, rockwool). Clearly crystalline
mineral particles.
DUST SAMPLE B (Note. The optical fields were scarcely loaded).
OBSERVED: Round mineral particles. Cellulose and hair fibers. Cottons and synthetics.
Round (about 10-15 micron diameter) particles, found in about 5 optical fields, and
tentatively classed as "vegetative".
ABSENT: Mineral fibers. Clearly crystalline mineral.
3.2.3(b). Report of Findings of H. Davis-1/8/91.
An independent microscopic examination of the supplied dust sample wedges was
performed on 1/8/91 by Mr. Howard Davis, EPA Lexington Laboratory (Laboratory
Project No: 91072). Summarily, Howard confirmed the 1/28/91 findings. Additionally,
he identified pollen (10 micron diameter round particles) in sample B, reported that one
glass fiber was observed on the inspected wedge from the sample A filter, and found
starch particles in the two samples.
4. Evaluation of Volatile Organic Compounds (VOCs) & Standards.
4.1. Sampling and Evaluation Of VOCs-Floors 10 & 11.
4.1.1. Sampling.
Selection of representative floor locations for sampling and sampling were done by Mr.
Peter Kahn and the writer. A minimum of five air samples per floor were taken in open
center and end area spaces. Also, the 10lh floor smoking room (with 5 active smokers
in the room) was sampled.
4.1.2. Target Compounds.
Certain common chemicals were targeted in the analysis. These were selected
because either they evolve from office furnishings or are found in cleaning agents. The
compounds are principally toluene, benzene, the o.m.p xylenes, halogenated aliphatic
and aromatic hydrocarbons, and simple and ethoxylated alcohols. Other (GC.PID-
responsive) low boilers were also sought.
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4.1.3. Evaluation.
Target volatile organic compounds in the indoor air were evaluated on 1/8/91 using a
portable gas chromatograph with a photoionization detector (PID at 10.2 ev). Analyses,
using reference VOC blends prepared in advance, were made on site by Dr. Tom
Spittler and Mr. Peter Kahn, EPA Lexington laboratory.
4.2. Findings: VOCs-Floors 10 & 11.
4.2.1. Preliminary Observations- 1/8/91.
Dr. Tom Spittler kindly provided a prompt verbal report of his initial observations: "only
a few parts per billion each of toluene, benzene and a few other volatile compounds
[were] present", and "the 10th and 11th floors are consistently clean."
4.3.2. Formal Report.
A formal report is in preparation by Dr. Tom Spittler and Mr. Peter Kahn. It is planned
for completion on 2/8/1991, after which date, copies will be available from the
laboratory.
The findings were reviewed extensively by the writer with Peter on 1/28/91. Summarily,
the review affirmed the findings given to the writer in the verbal report of 1/8/91.
Benzene, toluene, and trichloroethane were found to be present at approximately 5
parts per billion, and this correspond to the background outdoor levels which were
measured on the same day. Thus, only trace concentrations were found in the air on
either floor. The combined total of the target compounds found was much less than
115 parts per billion, which is the concentration which is used by the writer as indoor
air quality (TVOC) guidance (please see section 3.4.3).
4.4. Standards For VOCs In Indoor Air.
4.4.1. The Washington State 1989 TVOC-Standard.
Washington State has established a compliance standard re: a total of known volatile
organic compounds (TVOCs) in indoor air which is relevant and applicable to our study.
The daily average limit of exposure is 500 micrograms per cubic meter.
4.4.2. Relevance of the Washington State 1989 TVOC Standard.
The (mass concentration) limit of 500 micrograms per cubic meter is only directly
convertible to a "total parts per billion" term, when the actual mixture of the VOCs
present is known. This is not usually the case, especially when field evaluations are
made using a portable GC instrument, which is generally the easiest way to make an
evaluation.
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Generally, one does not need to know the complete array of (the traces of) the
common garden variety air contaminants which are usually present indoors. Such
information may not be especially helpful because very low dose-response toxicity data
on room temperature-volatile chemicals in indoor air appear to be either scant,
speculative or highly imprecise. This leads one to look for a general approach to
assessing data on indoor air.
-4.4.3. A Volumetric Standard for Common VOCs in Office Air.
It is possible to arbitrarily and sensibly set a corresponding "total parts per billion" limit
for a mixture of suspected common garden variety organic contaminants which are
believed only to have additive toxicity and similar (only moderate acute irritating)
properties -- properties which manufactures of furnishings and office cleaning
compounds are careful to consider and evaluate. This entails using an arbitrary
reference. A known compound or blend of compounds (whose molecular weights are
also known) is used. The reference compound or blend must have appropriate volatility
and toxicity characteristics.
The o.m.p zylenes (C8H,0. M.W. = 106), being slow to evaporate at room temperature
and moderately irritating (eye), in the writer's judgment, can serve as the reference
chemical to derive an assumed-equivalence, volumetric standard for the common
garden variety volatile organic compounds likely to be found (but unlikely to be fully
characterized) in an on-site, indoor air quality investigation.
Using this approach, the (xylene assumed equivalence) limit is 115 parts per billion, for
•the common garden variety VOCs in indoor air, viz: [500 x 24.45 (the mol.volume)/106
= 115 ppb]. This value is about an eighth of the volumetric concentration (1 part per
million) of a known blend of 22 common organic compounds shown to be minimally
acutely irritating, in tests made in 1985 by L. Molhave et al., (referenced in the
12/21/90 report). It could be used as a go-no go gage for use in deciding to further
consider doing additional (GC-MS) analysis.
Until a standard, covering typical indoor air contaminants, which is either mandatory or
well based on toxicological data comes forth, 115 ppb will be regarded by the writer
as a guide to an acceptable daily exposure to common garden variety indoor VOCs
(excluding formaldehyde, for which a standard exists).
5. Other Tests and Information.
5.1. Luminance: Levels and Standard.
5.1.1. Recent Spot Measurements.
The overhead illumination of certain offices, as measured at open desk top areas, is
evidently sub-standard in some offices, especially in late afternoon winter periods.
Reportedly, luminance at desk top levels, unobscured but without the under-cabinet
lighting being on, is less than 15 foot-candles in some cases, and use of the under-
cabinet lighting does not remedy the problem.
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8
NOTES:
• The illumination from a particular candle power source, at some location at
a specific distance, and at a specific angle of incidence varies inversely with
the distance squared and directly as the cosine of the angle. With the current
lighting fixture grid, in the worst case, the incident angle, relative to the middle
of the office(s) served, is about 45 degrees (cosine, 0.707). In this case, the
illumination could not be increased by more than about a third (0.3) by
repositioning the fixture so as to be directly overhead. This fact needs to be
kept in mind when one evaluates the alternatives of repositioning fixtures or
adding new overhead lighting in problem offices were the desk level illumination
is less than 40 foot candles, and 50 foot candle illumination is needed. In such
a case, an additional fixture would be required for a office.
• Adding more overhead office lighting could cause a power overload. This
happens now when lamps and heaters are used in some offices. Any addition
of office lighting may have to be offset by removing some of the lighting fixtures
in the aisles and elsewhere.
5.2. Lighting Survey
A comprehensive evaluation of office lighting is now being made by Mr. Robert Wade.
His findings will be reported separately, and could be used as a basis for future
corrective action.
5.3. Illumination Standard.
The prevailing EPA Region 1 's standard for lighting for desk-tops is 50 foot candles.
This level of lighting was incorporated by the writer in a set of (1989) preliminary
specifications (for a new EPA facility) which were to be provided by EPA Region 1 to
GSA.
50 foot candles at the task is a higher standard than the (30 foot candles) requirement
for library reading rooms that one sees in older literature. However, the anticipated
prolonged reading and writing duties of many of the staff persuaded the writer to
propose the 50 foot candle, task illumination limit; the perceived need has not changed.
5.4. Lead in Drinking Water. Findings and Standards.
5.4.1. Sampling.
Water (from fountains and sinks on the 10Ih and 11Ih floors) was sampled for lead in
December, 1989 by Mr. Albert Pratt, Lexington laboratory. Four drinking fountains and
some sinks were (first-flush) sampled.
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5.4.2. Findings.
Each sampled drinking fountain provided water which was determined to contain lead
only at or below a concentration of 6 micrograms per liter - the level which is the limit
of sensitivity of the test. One (first-flush) sample of sink water was reported to have
a lead concentration of 28.4 microgram/litre. However, a duplicate sample (insta-
ntaneously taken) of this supply was reported to contain lead only at or below a
concentration of 6 microgram/liter (ug/L). In this case, the first lead level is an
undetermined anomaly.
5.4.3. Lead-in-Drinking-Water Standard.
The current standard for lead in drinking water is 50 ug/L. A proposed (for 1991)
national standard is 15 ug/L ("first-flush" sampling).
5.4.4. Status of the Water Supply And Assurance.
There is no problem with Lead in the drinking water from fountains on the floors. For
continued assurance, annual sampling and testing of all the fountains is recommended.
6. The HVAC-System. Capacity And Standards.
6.1. The System.
The HVAC system in the building is a modern design, variable air volume (VAV)
system. It utilizes individual VAV-units, each VAv unit has individual ducts for air
intake, air recirculation, and air supply (this is unlike the case in the former EPA
premises at Government Center which employed the ceiling plenum as the low-
velocity, high volume exhaust component of the HVAC).
The variable air volume (VAV) system arrangement is shown and described in the
report entitled " Some Comments On The Design, Operation, And Capacity Of The
HVAC System", issued by the writer on 1/14/91, and reproduced in the Appendix.
As a summary, the system comprises a total of 168 sub-units (VAVs) each of which
employs an outside air-to-supply air ratio of a minimum of 20%, and this level of fresh
air intake value may increase in the spring and fall. The filtration employed is
conventional (not HEPA). The filters are required to be changed twice a year. In the
event, however, that they are not changed at this rate, filtration only improves,
however, the cost of operation of the HVAC fan drives increases; ultimately, flow rate
is reduced significantly.
6.2. Capacity.
As stated previously, the VAV system employs 168 units, some of which have different
flow rates, ranging from a minimum of 800 cfm (HVAC drawing designation: A-Boxes)
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10
to a maximum of 3240 cfm (designation; B-Boxes). It is not practical to make a precise
estimate of the rate of supply of outside air per person at this time because "as-built"
drawings are not available to either EPA or the building management, and checking the
setting of each VAV unit can not be done now. However, it is possible to conservative-
ly estimate the outside air supply rate per person, by spot checking individual VAV units
for intake and output flow rates and by using a mean value for the average (VAV box)
unit supply capacity. This has been done by the writer.
The level of outside air supply per person is estimated by the writer to be approximate-
ly 25 cfm per person; and the air change rate is estimated to be approximately four per
hour. This level of ventilation exceeds all known relevant standards for non-smoking
offices. Fresh air ventilation is judged by the writer to be excellent on both floors.
For a more detailed explanation, please see the referenced report in the Appendix.
6.3. Ventilation (Fresh Air) Standard.
The ASHREA Standard of 1989 specifies 15 cfm to 20 cfm for the types of occupancy
which are relevant. For more detailed information, please see the referenced report in
the Appendix.
7. IAQ Questionnaire: Survey Form and Protocol.
7.1. Form.
NIOSH and EPA have jointly established a format for assessing indoor air quality
through an employee-survey. The format has been provided in a draft of a proposed
document which has not yet been released as public guidance.
The elements of the format are completely incorporated in the form reproduced in the
Appendix. This form has been tentatively approved by the Union President and the
Medical Director, PHS - Division of Federal Occupational Health, Boston, MA) for use
in conducting an IAQ Survey at EPA Region 1, One Congress Street, subject to the
safeguarding of any required confidentiality.
7.2. Protocol
At the December 21s' EPA open lAQ-meeting, several participants made the point that
a confidential survey of occupants ought to be taken. This point was accepted by the
management. To assure confidentially would be provided and maintained, the following
key steps or an equivalent procedure could be followed:
1. The manager of safety distributes an approved survey to either all or
some appropriate sample number (as determined by the management)
of the EPA employees, One Congress Street.
-------
11
2. Employees send their responses in a sealed envelope to the Medical
Director, Public Health Service - Division of Occupational Employee Health
(Government Center, JFK Federal Building, E120).
3. The Medical Director assesses the information, assures confidentiality, and
provides a written summary report to the EPA HQ Safety Director, with
copies to the Union President, the Safety Manager, and other EPA
personnel who are authorized in any way to get a copy from the medical
Director.
4. The Safety Manager, from the information provided, will identify any
needed corrective action, and report the need to the management.
8. Other Relevant Points.
8.1. Recent Articles-aspects of chemical sensitivity.
Several short articles appeared in December in the Boston Globe and the Ma Safety
Council magazine (please see the appendix).
8.2. Relative Humidity. Comfort Limits. Levels. Controls.
8.2.1. Relative humidity (RH%).
This is a term which expresses as a percentage the water vapor in the air relative to
the maximum amount of water vapor that the air can hold at the particular temperature
and pressure. Relative humidity does not indicate in an absolute sense how much
vapor is present.
8.2.2. Comfort Limits.
Most (97%) occupants doing indoor sedentary work will feel comfortable in the winter
months provided the relative humidity does not go below 30 percent when the minimum
indoor (dry bulb) temperature is 70-72 degrees Fahrenheit, and the air movement
(draft) is not more than about 15-20 linear feet per minute with any prolonged head,
neck, shoulder or leg (skin) exposure.
When air movement is at or greater than 20-25 linear feet per minute at the skin, a
definite draft will be noticed.
One can expect to receive complaints from occupants of dry skin and irritation of the
mucous lining (eye, nose) when the winter time indoor relative humidity is less than 10
- 15%, despite the fact that the temperature is adequate for comfort.
-------
12
8.2.3. RH% Levels. December/January.
In the period of mid-December to mid-January, relative humidity values in the range of
20% to 30% were measured repeatedly by the writer using an accurate sling
psychrometer.
8.2.4. Controls
8.2.4(a). Engineered Control.
The building is not equipped to control winter-time relative humidity. It is not practical
to retrofit such control to the HVAC in this building.
8.2.4(b). Use of (Safety) Approved Humidifiers.
The use of (U.L. approved) humidifiers in offices during regular work hours is not
prohibited. All relevant electrical and fire safety controls and hygienic practices must be
employed when they are used. They can not be used where they will trip the electrical
circuit breaker. The use of a humidifier in an open office space may not be effective.
8.2.4(c). Personal Hygiene.
Certain over-the-counter skin emollients, nasal sprays and eye drops appear to be
beneficial in offsetting the effects of dryness experienced in offices during winter
months. If such products are used, one should take care to ensure that they do not
aggravate the condition being treated; this can occur in some cases.
8.3. Engineered Control of Office Noise.
It is feasible to economically acoustically treat some problem offices, but other areas
may not amenable to treatment. The engineered control of office noise is a specialist's
job. Further discussion of the subject is beyond the scope of this report. However,
typical literature which illustrates what might be useful to control noise and speech
transmission in some problem offices is given in the Appendix.
9. Key Points in Summation.
Based on the information we have garnered to date, the following key points are
offered:
o The frequency and severity of employee complaints are relatively low. Formal
(two intotal) and referred (about 10) complaints concerning health or safety
problems equate to less than one percent of the total number of employees on
the two floors. However, the current level of complaints about cold areas, drafts,
and air dryness is high; and the cold and draft complaints are evidently mostly
valid.
-------
13
» Formaldehyde and volatile organic compounds are not significantly contaminat-
ing the work place. These compounds are present at trace levels in the Herman
Miller furnishings, but they have only been found at low (parts per billion) llevels
in EPA work places.
• No infiltration of the offices by carbon monoxide is occurring. Carbon
monoxide levels are at "background" concentrations; no evidence exists to even
suggest that infiltration occurs from the (nine) garage floors immediately below
the offices.
e Work places are clean. The dust is very low, and no mineral fibers are
present in the indoor air.
e The extent of forced ventilation is excellent. Outside air is suplied to the two
office floors in amounts which exceed the ventilation requirements in all known
relevant and applicable standards. Ventilation level is excellent but temperature
balance is poor at this time.
0 There is no problem of lead in the drinking water from the drinking fountains.
• Problems of heating, lighting, noise and air drvness exist. These problems
relate locally to either heating uniformity, drafts, direct and reflected lighting or
noise. Also, (winter) indoor air dryness is a problem. These matters are not
currently classed as recognizable health hazards, but they may very well be
strong "dissatisfies." Correction of some of these problems can be made in
simple ways involving physical rearrangements and personal practices; some
others will require the work of engineers and tradesmen. Corrective actions were
discussed in the December 21,1990 Report.
NOTE.
t The problems of lighting, noise and temperature control are being
addressed by the services branch. The problem of periodic dry air can
not be resolved in an engineered way. However, some of the practices
mentioned earlier on this point should be beneficial to many of those
people who are only minimally affected by the winter-time indoor air
dryness.
• Taking an Indoor Air Quality (IAQ) survey is planned. This action is planned
in response to requests from a small number of employers and the recommen-
dations of some EPA supervisors and the Medical Director of the Public Health
Service, Division of Federal Employees Occupational Health. Such a survey is
intended to elicit information in confidence any on any actual or perceived health
or comfort problem.
-------
14
The writer has offered a technical format, based on a formal joint NIOSH-EPA
method, and a protocol to implement the plan, and has made arrangements for
any assessment to be made in full confidence. All completed survey forms would
be sent directly to the Medical Director.
The survey may provide information indicating that one or more occupational
hazards exist, or that changes could be made to improve ergonomic matters.
If this turns out to be the case, the recommendations provided by the Medical
Director will be responded to properly.
Despite the above matters, the planned survey is neither endorsed nor opposed
by the writer. No occupational health problems are known which would cause
one on these grounds alone to take one side or the other. Of course, the
apparent imbalance in the heating and lighting systems and other considerations
may suggest to the management the need for the survey.
• Forced ventilation of the smoking room is evidently needed. This matter was
fully reported in the report of 12/21/90. At this time, a recommendation to install
a 3/4 HP axial fan (for 60 cfm/person), with total exhausting to the outside, has
been concurred with by GSA, and a work order has been processed.
• An in-deoth environmental analysis is not currently justifiable. It would be
possible to extend the studies made to-date to include sophisticated methodol-
ogy employing off-site gas chromatography with mass spectroscopy and other
methodologies. Such methods would provide evidence of the presence of trace
amounts of a plethora of volatile and semi volatile compounds in the indoor air
from the furnishings and occupants, such is the great sensitivity of modern
analysis.
The toxicologic consequence of indoor air exposure to a few parts per billion of
a single chemical or a blend of chemicals of the types and classes which are
ubiquitously present seems to be unfathomable, even when extraordinary efforts
are made. Stated simply, there are few if any relevant low dose-response data.
And, the data which exist are speculative and may have many orders of
magnitude of uncertainty. Also, associated costs would be major. In short, no
health risk or possible likely health or likely benefit of any kind is known
currently to the writer to justify expending tens of thousands of dollars which
surely would be needed for such a pursuit.
N.A.B. 1/27/91.
Post Script.
On 2/19/91, the building owner installed a roof-mounted 3/4 HP fan extractor (with an 18 inch square
duct to the outside of approximately 20 ft/straight section; and 1.2 in. water total pressure drop). The
regular smokers report the improvement is very good. They were all pleased. There is no excessive
noise, draft, or negative pressure in the room. The door (sans grid) opens easily against the exhaust.
A draft is discernable at the center of the room. A 3/4 HP unit seems to be just about right, as
calculated, for this 30X20X10 room.
-------
Appendix
-------
MASSACHUSETTS BAFETYCOUNC.U. INC.
Occupational Asthma Alert /
People who develop asthma as
adutis and have more symptoms
during the work week than on
weekends may be suffering from
occupational asthma.
The disease Is often caused by
exposure to irritants in the work-
place. These irritants may be biolo-
gical agents such as grain, flour.
animal dander and antibiotics like
penicillin, or chemical agents in-
cluding formaldehyde, naphthalene
and toluene di-isocyanate (TDI).-
Asthma symptoms include wheez-
ing, tightness in the chest and
difficulty breathing. When the dis-
ease is diagnosed early end
patients avoid the irritating sub-
stance, they are able to recover
complete lung function. Longer
exposure may result in more
severe health problems such as
pneumonia.
Employers are advised to be aware
of asthma symptoms among their
workers and improve working con-
ditions when necessary.
p—0, nnht tor VDT« / indirect
office Jigging can significantly
reduce eye problems and toss In
worker productivity caused by
glare from video display terminals.
according to a recent study con-
ducted by Cornell University.
The study, begun In 1988 at a
Xerox Corp site In New York, stu-
died the effects two different types
of lighting had on computer-screen
glare. Han the offices were equip-
ped with conventional ovemead
fluorescent lighting or downlight-
mg The other halt had indirect
fluorescent lighting that directs
light toward the ceiling, called
uplighting.
Nearly a fourth of the computer
users in offices with downlighting
said they tost 15 minutes or more
each day because of difficulty
focusing on the screen and more
than 10 percent complained of
watering or Itchy eyes, compared
to onry 1 percent of workers in
offices with indirect lighting. In
addition, loss of productive work
lime caused by tiredness or leth-
argy was four times greater In the
group with conventional computer
area down lighting.
A follow-up study 12 months later
found 71 percent of the employees
preferred the indirect lighting sys-
tem. Furthermore. 74 percent of
those working under convention
downlighting said they preferred
indirect lighting.
-------
November 27,1990
Occupational Hearth
$8 Million Ergonomics Program Launched At Pacific Bell
OAKLAND. Calif.-(By a BNA Staff Correspondent)—Pacific Bell in
California aims to cut down stress and strain among employees who work with
video display terminals (VDTs) in a two-year ergonomics program that will
retrofit existing offices and furnish employee training.
The company has been developing its ergonomics program since 1985.
according to Jill Foley, Pacific Bell's manager for public affairs. All ff' tiK
55.000 Pacific Bell employees who use VDTs are to receive ergonomic training
b\ the end of 1992. she said,
' Foley said thai one office in Concord, Calif., which employs 101 operators
had already been retrofitted prior to the announcement that the firm s program
was being oonned-up. Operators in the retrofitted office can adiust the height
of their chairs and desks so they can sit or siand while working and use
keyboards in a suaigrn-wrisi position. Walls in the working area and partitions
"a. 'workstations have been coaled with fabric to cm down on noise leve'y
' According to Foley. a survey is now under way to determine wmcn depart-
ments should be considered first for retrofitting and training. The results should
be in and the retrofitting and training started by the first quarter of 1991. she
* The Pacific Bell ergonomic program is being eyed with interest in San
Francisco, where a proposed ordinance that would regulate VDT use in firms
employing more than 15 VDT workers is before the Board of Supervisors
The San Francisco Chamber of Commerce is drafting guidelines for its own
set of voluntary VDT-use standards as a proposed alternative to the ordinance
under consideration. The chamber's voluntary guidelines are expected to be
ready by the beginning of 1991. "We think that the Pacific Bell program is one
of the models." Carol Piasente. the chamber's communications director, said.
However Joan Moore, secretary for the Communications Workers of Amer-
ica Local 3310. which represents 3.300 Pacific Bell employees, questioned the
phone company's commitment to extending its ergonomics program beyond
what Moore termed a "showpiece" office in Concord.
"They have 300 offices in California and that s only one. according to
Moore, who also serves as safety chairwoman for the unions Northern
California and Nevada Council. ^
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•UUFT1N M274.0
Modular Sound-Absorptive
Panels Foil Powerhouse .-.-
Noise P/oblem i \g
-.!*•• ^r-Z>fc^.*t-Q.TriL j ,'^JV.?ji
Amid the scenic Blue Ridge Mountains in northeast
Georgia not far from the Tennessee state line. Carters
Lake glistens in the sunlight. The sparkling waterbody
wuh a wooded shoreline contributing to its natural beauty
is man-made to serve as a flood control and power-genera-
tion resource by a dam on the Coosawattee River.
Situated at the foot of the 445-ft (136m) high Carters
Lake dam is a 390-ft (119m) long by 115-ft (35m) wide
hydroelectric powerhouse. To produce electricity, runoff
water which the lake collects from a 375-square mile
surrounding area, flows through four 18-ft (5.5m) (inside
diameter) penstocks to the powerhouse, rotates pump
turbines activating 125.000-kw-capacny hydrogeneraiors.
and discharges inio a reregulanon reservoir below the
powerhouse. Water is pumped back into the mam lake
when demand for power is low. usually during the night
and on weekends.
According to the US Army Corps of Engineers. Mobile
District. South Atlantic Division, managing the Carters
Lake project and operating the powerhouse, power
releases and pump-back of the water cause levels of the
reregulation pool to vary as much as 10 feet (3m) w.th.n a
6-hour period, to rise up to 22 feet (6.7m) from Monoay to
Friday, and to drop as much as 22 feet (6.7m) over a
weekend Pump-back results m weekend fluctuat-ons in
Carters Lake of up to 4 feet H 2m) The powerhouse
engineering staff credits reuse o< the water with suosian-
tially increasing capacity ot the facility
INDUSTRIAL ACOUSTICS COMPANY
-------
—Environmental Management Includes
Noise Control—
Administration of this hydroelectric resource includes
maintenance and improvement of the powerhouse envi-
ronment outside and inside. Noise control has been a
major accomplishment in the interior. With pumps and
generators running, noise levels have been as high as 97
dBA. a condition amplified by reverberations resounding
from the hard-surface, sound-reflective concrete ceiling
and walls of the powerhouse.
In a project aimed at reducing these noise levels below
OSHA limits, the Corps of Engineers specified prefabri-
cated sound-absorptive Noise-Foil panels which Industrial
Acoustics Company designs and manufactures. Installa-
tion called for panels to be suspended vertically from the
ceiling and flush mounted on the walls.
So. from the ceiling were hung 550 cable-supported.
pre-fmished. white, aluminum 3-inch-thick (76mm)
modules (Noise-Foil III) 48-in (1219mm) wide by 78-m
(1981mm) long containing verminproof and mildew-resis-
tant fiberglass fill for a 14.300 sq. ft. (1328) sq.m.) total of
acoustical treatment. Since all six of its sides are designed
for sound-absorption, each panel maximizes the beneficial
effects of sound-wave diffraction. Overall surface ex-
posure and panel acoustical interaction were factors in-
fluencing choice of this Noise-Foil System to improve
environmental conditions in the powerhouse.
Noise-Foil II (walls) and III (ceiling-suspended) are two
of four sound-absorptive, modular designs with vary-
ing construction characteristics offering wide appli-
cation options. All panels provide a practical and
effective means of reducing noise levels associated
with reflected sound in industrial plants. Installation
of the panels in the Carters Lake powerhouse was
coordinated by the (AC area representative. H. Clay
Moore & Assoc. of Atlanta.
Carters Lake powerhouse as teen from the top of the
dam site.
Complementing the ceiling installation are 1.250 wall-
mounted Noise-Foil II pre-finished. white, aluminum 2-
inch-thick (51mm) panels Each is 18-in (457mm) wide and
120-in (3048mm) long with the fiberglass fill bagged ir.
sealed, dustproof plastic to prevent deterioration from
humidity and dirt accumulation. Bolted to interior sur-
faces, the panels are tightly integrated with pre-pa>nte;
joiners and connectors for an altogether secure echo-
preventing system.
—Acoustical Systems Benefits Are Multiple—
In combination, the ceiling panels and wall liners cu:
noise levels through sound absorption. Each Noise-Fo'i
System is characterized by a Noise Reduction Coefficier,:
(NRC) of O.SO. meaning that 90% of the sound energy
incident to surface of a panel is absorbed High perfor-
mance in low frequencies (63 Hz and 125 Hz—typical o-
the rumble of powerhouse pumps and generators) tones
down the boom and echo in these troublesome ranges
Provided in response to an analysis of the bes: way to
neutralize the noisy conditions of this hydroelectric facility.
the Noise-Foil Systems were installed without interfering
with powerhouse operations. Acoustical performance has
been checked at various locations throughout the plan;
showing that noise levels at all points do not exceed the
OSHA exposure limit of 85 dBA during the normal eigr:-
hour working day The modular acoustical treatment fc:
this powerhouse is considered exemplary of the type of
sound-absorption that can be introduced-into hydrc-
electric and other categories of industrial plants.
Carters Lake powerhouse is capable of producing an
average of 500.000.000 kilowatts annually (roughly
enough electricity for 50.000 customers). Wattage gener-
ated is delivered at the switchyard to the Georgia Power
Company under a contract supervised by the Southeast
Power Administration. No one. then, living and working m
northeast Georgia who expects an immediate response
from flicking on a light, plugging in an appliance, turning on
a machine, or making any of the innumerable daily oe-
mands for electric current, need be concerned that service
will not be instantaneous—thanks to the environmentally
enhanced Carters Lake powerhouse
nt
ir _. _ _ _. ..
INDUSTRIAL ACOUSTICS COMPANY
1110 COMMERCE AVENUE IROM.KW TOM 10*61 fHOiMIMJUOOO TEIEMISMO IM:I1J«nill
Garden Giove.CA 92643 10971 Ga.der, C-ove Boulevard Phone: 714-6365440 hr "<"B-»««
Siainu Middlesei U K. - Central Trading. Estate - Phone (078414<651 Tele«:2SJ.1B f»:
4055 Ncdeiiruchten. W. Gnmanv Phone: (21631 8431/2 Telw 652261 Fax: 1
TECHNICAL REPRESENTATION II PRINCIPAl CITIEI mOUCHOUT TNI WORLD
• USA.
-------
Study: Environmental illness a mental disorder
CHICAGO (AP) - People who think the mo-
dern, chemical-saturated environment Is mak-
ing them sick may simply be suffering mrnlal
problems, a University of Iowa research group
says. Critics called their study naive and sloppy.
Patients diagnosed with the syndrome known
as environmental illness often get sick after
exposure to everyday Items like piucessed foods,
newsprint, gasoline and clothing.
Relief in the condition, also called multiple-
chemical sensitivity, varies in the medical com-
munity, with some doctors doubting Its exis-
tence altogether.
"It's my belief thai people diagnosed as hav-
ing environmental Illnesses m most cases do
have something wrong: a garden variety emo-
nonal disorder." said Dr. Donald W. Black, who
bended a study at the university's medical
school published today In the Journal of the
American Medicine Association.
Beginning in June 1988, Black's research team
studied 23 people diagnosed as suffering from
environmental illnesses. Fifteen, or 65 percent.
showed symptoms of past or ptuwnt mental
disorders like depression, anxtety or obwsslve
compusive behavtor. the study said.
In a 4frmember control group of henlthy
pie. n. or 2B prmmt. showed symptoms of
mental disorders, the study said.
The rrscarrli was naively romt-ivrd and nr«>r-
ly set up. said \Jr. \fo C.allaiid. a New York
Internist who treats prople dlar.uow-d with en-
vironmental illness.
Comparing tlic mental conditions of environ-
mental illness patients against hrallhy |«iipl«.
rather than the rnvntnl states of puiiph; suflering
medically accepted chronic ailments, was a criti-
cal flaw. Galland said.
"Being skk tends to make people deptwwd."
he said. "I don't think there's evir been a study
done comparing healthy community iro-mln-rs
with a group of patients wlio suffer fnnn a
chronic illness that hasn't found more psyrho-
pathology among the patient group."
Compiiring the mental conditions of environ-
mental Ulness sub)rcts with th»»w of pijoph; with
asthma, for example, might have proved his
claim, lie said.
A group of medical practitioners rallnl rlinl-
cal rcolngists believe that aminnm cluinlmls In
the air and physical environment can «i|isi-l Ihe
h»«ly's Immtino system, (railing to nausiii. n-spl-
mliiry jmililrms.'hrarfachrs nnd nlhrr ailments-.
Hit- slinly said.
! jntlcnts Kive reported hypersensltlvlty
In nigs. paiH-ling. deodoranl. bedding and other
i-vury«l«y sulisljuices. Some sufferers have
sought out "toxic frm environments" by giving
up ll«-lr urban Jobs and moving to the desert or
mountains.
A lack of an acceptable definition for environ-
mental illntss. as well as a lack of an established
lust for the disease, has ted much of the medical
community to dismiss the concept, the research-
rrs wrote.
Another critic saM even If the towa team's
conclusions were valid, toxms in the environ-
ment could have contributed to the mental
disorders.
"I don't think any psyctuatrbt can teU me
what causes mental Illnesses like depression
and neunisis." said Dr. Max Costa, professor of
environmental medicine and pharmacology at
New York University Medical School.
IMark's resvnrch team also crltfcted the use
of non-junx-en treatments on people diagnosed
with inivlnwnncnlal Illness. Those treatments
Inrlwte Mirclal dk-ts. wearing filter masks and
using dmrlws or enemas of spring water, coffee
nr vuguri.
-------
NOTICE OF UPDATE MEETING OF 1/31/91.
-------
EPA REGION 1 UPDATE OPEN MEETING
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.
Jeff Davidson, EPA HQ-OHSS, Washington.
Pat Meaney, ARA, EPA Region 1.
Dr. Ocampo, Medical Director, Div. Occ. Fed. Occ. Health, PHS.
Tom Spittler, Laboratory Director, EPA-Lexington Laboratory.
Barbara White, National President, AFGE-Union.
Date JANUARY 31
Time NOON to 1:30
Place—EPA 11fl. Conference Room.
One Congress Street.
Information will be presented on indoor air quality, and work place
environmental quality. Included will be information and data (on
carbon dioxide, carbon monoxide, and formaldehyde concentrations)
which were presented at the December 21,1990 open meeting on the
above captioned subject. Also, supplementary and new information
will be presented in response to our Intention to keep employees
fully appaised of work place quality factors, and the questions and
points raised by the participants In the December meeting. This
information covers specific furniture construction materials and
qaseous evolutions; measured lead in (fountain) drinking water,
stardards, and sampling plan; ventilation system type, and outside
air supply a'nd standards; dust characterization; quantitative analyses
for volatile organic compounds; a plan and format to survey EPA
Region 1's employees, and other relevant points and opportunities.
-------
REPORT OF UPDATE MEETING OF 1/31/91.
-------
Indoor Air & Work Environmental Qualities
One Congress Street, Boston, MA
Report of Update Meeting, January 31, 1991.
January 8, 1991.
1. Pre-meeting Notices.
The schedule for the above captioned meeting was extensively advertised (two weeks)
in advance Notices were sent to EPA personnel and supervisors in the building, and
were posted on the 10lh and the 11Ih floors, at the respective reception desks.
2. Panel and Attendance.
The panel comprised J. Davidson, P. Meaney, B. White and the writer. Dr. O'Campo
(US.PHS) and T. Spittler were invited, but they were unable to attend.
Sixteen people participated. These included five human relations specialists; three
facilities specialists; people who had raised concerns on earlier occasions and other
people.
3. Documentary Material Presented.
The Supplementary Report, dated 1/29/91, on the captioned topic was distributed. A
summary presentation of the report was made using overhead visuals (copy attached)
All of the information available to date was provided at this meeting. Copies (100) of
the Supplementary Report were placed at the reception desks on the two floors,
immediately following the meeting.
4. Points of Discussion.
The principle points which were made dealt with the following matters (responses are
reported at section 5):
4.1. Reported Lead in drinking Water.
(A) One participant said that the number used by the laboratory as a reference
level i e "less than 6 micrograms per liter of lead", should be a lower number,
and the person said this was a "good laboratory practice" requirement; "5 g/l
was mentioned as a possible number but lower values of concentration were
also mentioned at the same time.
-------
(B). Another participant raised the point that the (sink) water which reportedly
had 24.8 ug/L was a concern, and objected to the sampler's verbal "unexplained
anomaly" description which was included in the writer's Supplementary Report
of 1/29/91. This participant also wanted to know - -
(C). Was lead-bearing solder used in the fountains/water supply.
4.2. Formaldehyde in Air in Earlier Periods.
Another person said that there must have been a formaldehyde problem at the start,
considering that the HMI furniture study data indicated a 40 day half-life, and the
writer's data showed 10-14 opb. in December.
4.3. Carpet Pile "balling".
The same person said that when chairs are moved over the carpet, fibers "ball up",
and he was concerned about the respiratory hazard from the fibers being released.
4.4. Interim Construction Hazards.
Another commentator said that construction (on the 11lh floor) of offices, using plaster-
board and water and solvent paints, was in progress after the time EPA personnel first
occupied their offices. He wanted to know what air-data we had on this activity.
4.5. An lAQ-survev. and Attaining and Maintaining Confidences.
Several people asked about the extent and timing of the survey.
4.6. A Map to Identify Problem Areas.
One of the prior speakers suggested using a map and format to identify locations with
heating, ventilation and any other problems.
4.7. Ventilation on the 11lh Floor Raised As A Concern.
A new speaker said that it seemed to her that part of the 11th floor was not adequately
ventilated, it was stuffy.
4.8. Dry Air Causing Problems, and The Use of Humidifiers.
Many of the participants complained of dry indoor air and the bad (skin, eye, throat)
effects it was having on them. One asked if she could use a humidifier in her office.
-------
5. Responses. And Additional and New Information.
All of the points raised were responded to by the writer as they were made. The
responses provided, and additional and new information are presented here.
5.1. Re: Issues of Lead in Drinking Water.
The responses made at the meeting, and additional and new information, are:
(A). The "less than 6 micrograms per liter of lead" term used was a direct quote
from the laboratory report. Also, the point was made that a periodic lead test had
been had been recommended in the Supplementary Report, dated January 29,
1991.
(B). A point of new information is that the chemist (who made the analysis and
reported the results using the term "less than 6 microgram/liter") was contacted
on 2/1/91 by the writer to discuss the matter of reporting. He said that:
• He used the updated Atomic Adsorption/Furnace method which is EPA-
approved (at 40 CFR parts 141 & 142).
• He follows the EPA's Environmental Monitoring and Service Laboratory's
(EMSL) guidance for the analysis.
• Reference standards are used to optimize accuracy and precision in the
analysis.
Writer's Notes:
• Reference standards are made up based on the need to use an
appropriate "Practical Quantification Limit" [PQL] to express the "lowest
concentration that can be reliably achieved by a well-operated laboratory",
as stated in the Federal Register Vol. 53, No. 160, page 31550, Aug 18,
1988. This Register also states - [the] " PQL is generally about 5-10
times the Method Detection Limit (MDL); — and (b) — [the] "MDL is 1
ug/l", relative to the AA/Furnace method for lead in drinking water.
t The use of the term "less than 6 ug/l" to express the lowest concentra-
tions evidently meets the referenced regulatory guideline for reliably
reporting low lead levels. It is less than the highest PQL (10 ug/l) which
could have been used in accordance with the EPA guidance.
• The reference standard concentration of 6 uq/l is 12% of the current
Maximum Contaminant Level (MCL): and, 40% of the proposed (15 ug/l)
MCL for lead (the writer thinks that the use of this standard concentration
to report on the new low lead level of interest is reliable).
-------
• If regulatory standards (MCLs) get more stringent in terms of concentra-
tion limits, one might expect to see a drive toward reduced Practical
Quantification Limits; however, it seems to the writer that only small (one
or two times the method detection limit) gains might be achieved in this
regard by laboratories in general.
• The above information explains, at least to the satisfaction of the writer,
the matter which was raised.
(C). The (sink) water sample (which was retained by the chemist) which was
reported - quoting - as "an unexplained anomaly" was retested in the week of
Febuary 3rd, following on requests from several individuals. The report of the
retest was "less than 6 microaram per liter."
(D). On the questioned use of lead solder in fountains: since 1986, there has
been a SDW-Act regulation banning the use of lead. Almost certainly, every
domestic equipment manufacturer and plumbing contractor knows and follows the
directive. Not to do so could be devastating to product sales, and would appear
to be an apparent willful violation of the SDWA regulation.
Also, the Engineering Manager of the Rubin Company was contacted by the
writer on 2/5/91 on the point. He said that their specifications were replete with
provisions covering the banned use of lead throughout the water supply system
and that they complied with the building code and so certified to the state in the
permit process.
In summary, the point made in the Supplementary Report is reiterated; the writer
believes that there is no evident problem of lead in the drinking water. And, a periodic
sampling for continuing assurance has been and is recommended. However, there
easily might be some relevant and important matter of which the writer is not aware.
If any specialist believes that an analytical problem or a health risk exists, the matter
should be formally communicated to the appropriate manager.
5.2. Re: Assertion of Formaldehyde Concentration Initially Being Excessive
It is not correct to interweave data from different dynamic situations and tests to reach
for an answer to what existed when the building was first occupied. Diffusion rate
limitation on emissions, the dynamic dilution effect, and the interaction of these two
effects dictate (i) the peak concentration at the initial furniture set-up/hvac-operation,
and, (ii) the subsequent time vs.concentration curve. This needs to be appreciated.
Also, one purpose of the the HMI-commissioned study was to evaluate the peak
formaldehyde level in a typical new office arrangement. HMI's evidence showed that no
excessive peak level arises; and our offices are (i) more spacious and (ii) more
ventilated than the case of the HMI-test. The writer believes that it is not likely that the
initial formaldehyde concentrations were excessive, but he does not preclude the
possibility since no specific tests were done when we first moved into the new offices;
-------
there did not appear to be any evident need. However, the point now is that at this
time there we know that formaldehyde is not a problem. The writer explained these
points in the meeting, and said that if anyone would like to discuss the diffusion and
tumover(ventilation) effect on concentration and concentration change rate we could do
this.
5.3. Re: Respiratory Hazard? Carpet Pile "Balling."
Jeffrey Davidson, EPA Indoor Air Quality Consultant, pointed out that the carpet pile
"balls" and fibers would not be respirable because of their size. The writer pointed out
that (i) fibers one sees are not ones to worry about. It is the 5 micron and somewhat
longer microscopic fibers that deposit to varying degrees in the compartments of the
respiratory system, and even then, the microscopic fibers are not necessarily toxic or
their inhalation hazardous; and (ii) he had microscopically examined two, good-sized
air samples for respirable dusts, and had found the air to be very clean. The fiber and
total paniculate loadings on the test filters were very little, and (iii) the there was no
evidence that carpet (nylon) fibers were present in the air to a degree which would
alarm an industrial hygienist in any way. And, apart from this, nylon fiber is classified
as "benign."
5.4. Re: On-Goino Construction At the Time Of Occupancy.
There are no air data for the time period. No testing took place. However, the materials
involved were common variety and are not considered to be toxic. No hazardous
situation is believed to have existed. As additional information, which was not said at
the meeting, the writer inspected the 11th floor work at the time and he did not see any
problem. He did see that plastic sheeting was being used extensively to control dust
spreading, and that the day-time cleaners were making sure that plaster-dust did not
track. The construction work in case was done very cleanly, in the opinion of the
writer.
5.5. Re: Perceived Problems of Area Ventilation (the 11lh floor).
The CO, testing showed a high degree of ventilation with respect to fresh air circulation
on both floors. Also, the VOCs concentration reported by the Lexington Laboratory for
the area in case was only a few parts per billion, in total. It is possible that imbalance
or reduced "throw" from a local diffuser in small office areas exists. This might cause
the perceived problem. The use of the surveys which we plan to conduct shortly
(please see sections 5.6 and 5.7) should be useful in identifying any localized
problems. This matter was referred to the Facilities Branch Chief by the writer on
2/4/91).
5.6. Re: The IAQ - Survey.
It was stated that this survey was ready to use (see copy attached), and it would be
sent to all EPA employees in the building. P. Meaney will be writing to all employees
on this matter. Also, only Dr. O'Campo will handle the responses to assure that
confidences are maintained.
-------
5.7. Re: Use of A Floor Plan To Identify Issues.
The proposal to use an annotated floor plan to identify perceived problem areas, to
help management in making any necessary changes, without disclosing identities was
instantly endorsed by everyone at the meeting. Useful, timely information could be
given directly to the facilities specialists.
Floor plans, made by W. Holbrook, already exist which could be used for this purpose
after a few minor changes have been made. The writer said that he would make a
layout-and-format, which facilities personnel could use as a questionnaire. This
questionnaire, of course, would not have any sections addressing medical or personal
identification matters. This work is now complete (see copy attached). A facilities-
questionnaire is now ready for release. It could be distributed as the same time that
the lAQ-Survey is sent out.
5.8. Re: Dry Air and The Use Of Humidifiers.
Dry air in offices was widely recognized as a periodic, winter-time problem. It was
stated that no engineered solution was feasible. However, humidifiers might be useful,
and there was no current prohibition on their use, provided that the circuit was not
overloaded, and the humidifiers were kept clean.
As a point of new information, we can quickly test relative humidity and (dry bulb)
temperature before and after using a humidifier in a closed office to see if such use
is effective (please call N. Beddows, 565-3388 if you want this done).
N.A. Beddows
2/8/91.
Distribution:
W. Andrade/M.Dowling.
Branch Chiefs (building)
W. Chenoweth.
J. Davidson.
H. Davis.
Division Directors/Senior Staff.
EPA HQ OHSS Staff.
A. O'Campo. M.D. US.PHS.
Participants & Panel Members.
T. Spittler/P.Kahn.
B.White.
EPA Reception Areas,
Floors 10 & 11.
Attachments:
1. Overviews Used 1/31/91.
2. Occupational Medicine lAQ-Questionnaire.
3. Questionnaire For Use By Facilities Specialists.
-------
VIEW-GRAPHS FOR THE UPDATE MEETING OF 1/31/91.
-------
UPDATE -
INDOOR AIR QUALITY
EPA OCCUPIED SPACES,
ONE CONGRESS STREET
N.A. Beddows. 1/29/91
-------
-DECEMBER 21. 1990 MEETING-
MAJOR CONCERNS ADDRESSED AT THAT
TIME - -
CO GAS - INFILTRATION FROM
GARAGE
CO, GAS - MEASURE OF VENTILATION
FORMALDEHYDE - MEASURE OF
CONTAMINATION VIA
FURNITURE OUTGASSING
-------
- NEW QUESTIONS ON DEC. 21. 1990 -
HVAC SYSTEM TYPE &
FRESH AIR SUPPLY.
DUST COMPOSITION -MINERAL
FIBERS
« VOCs FROM THE HMI-FURNITURE
• IAQ SURVEY (NIOSH FORMAT)
-------
- SIX POINT PURPOSE -
1. PRESENT DATA GIVEN AT
12/21/90 MEETING
2. REPORT NEW INFORMATION & DATA
* FURNITURE MATERIALS &
OUTGASSING
* TARGET VOCs
* DUST SUSPENDED IN AIR
-------
3 DISSEMINATE PRIOR INFORMATION ON
LEAD IN THE DRINKING WATER
4. DESCRIBE/DISCUSS THE HVAC SYSTEM
& ACTUAL VENTILATION and
STANDARDS
5. IDENTIFY CURRENT PROBLEMS and
OPPORTUNITIES
6. SUMMATE KEY POINTS
-------
-CARBON MONOXIDE-
FOUND (TOM SPITTLER):
1.0 PPM (0.9) IN OFFICES
5 PPM IN SMOKING ROOM.
-------
CARBON MONOXIDE STANDARDS:
0 OSHA - INDUSTRIAL STD
= 50 PPM, TWA.
O EPA / NAAQS - 8HRS: 9 PPM
O WRITER'S "STD" -
OFFICES. NON SMOKING: 2 PPM.
SMOKING ROOM: <10 PPM (PEAK),
-------
-CARBON DIOXIDE-
FOUND (TOM SPITTLER)
360 PPM
STANDARDS:
OSHA - INDUSTRIAL STD.
= 5000 PPM !
(ASPHIXIATION RISK)
-------
OTHER CARBON DIOXIDE STANDARDS:
O INDUSTRIAL HYGIENE CONSENSUS
(IAQ) < 800 PPM, "ACCEPTABLE.1
ABOVE 1000 PPM -- PROBLEMS OF
AIR SUPPLY / OVERCROWDING,
-------
-FORMALDEHYDE-
FOUND IN NOVEMBER, 90
NAB / MA. STATE TESTS:
OPEN FLOOR/5 DAY SAMPLE:
18 PARTS PER BILLION (PPB)
CLOSED OFFICE/5 DAY SAMPLE:
23 PPB
-------
FORMALDEHYDE FOUND IN SECOND
SERIES OF TESTS - DEC. 90.
NAB / HPLC & 2,4 DNPH-DOSIMETRY:
• RANGE (n =11) = 10 - 18 PPB and
GEOMETRIC MEAN = 14 PPB &
GSD = 1.3.
STANDARD (IAQ - MA STATE)
ACTION LEVEL = 50 PPB.
-------
NOTE.
50 PPB IS THE ODOR LIMIT OF
DETECTION FOR MOST OF US.
-------
HERMAN MILLER INC.
COMMISSIONED STUDY:
FORMALDEHYDE & VOCS - MID 1990,
TYPICAL NEW SET UP. FULL SIZE
CHAMBER.
FORCE VENTILATION & 2.5 AIR
CHANGES PER HOUR
TEMP. (70°F) & HUMIDITY (R.H. 50%)
CONTROLLED
-------
HMI FURNITURE STUDY FINDINGS.
FORMALDEHYDE PEAK = 15 PPB &
40 DAY HALF-LIFE.
TVOCs PEAK =
250 UG/CUBIC METERS' &
5 DAY HALF-LIFE.
* USING O.M.P XYLENE AS A
"SURROGATE". THIS EQUALS 57 PPB.
-------
- VOCs BY PORTABLE GC/PID. -
FOUND IN JANUARY (SPITTLER& KAHN):
BENZENE. TOLUENE. TCE.
<5 PPB LEVEL FOR EACH
NO CHEMICAL ODORS
IN WORK PLACE
-------
STANDARDS for the
rnMMQN GARDEN VARIETY VOCs:
WASHINGTON STATE (1989) TVOC STD,
KNOWN VOCs; 500 UG/CUBIC METER'
* FOR SURROGATE: 0,111.0. XYLENE,
THIS = 115 PARTS PER BILLION.
-------
- DUSTS BY PLM. 400X -
DECEMBER 28, 1990.
FINDINGS - 1900 LITERS/200 FIELDS/NAB.
• NO MINERAL FIBERS
• NO XTALLINE ROUND PARTICLES
COMMON VEGETABLE, ANIMAL, &
SYNTH. FIBERS PRESENT, also
t» VEGETABLE 10 MICRON "ROUNDS" ?
-------
-CONFIRMATION, 12/28/90 FINDINGS-
CONFIRMED INDEPENDENTLY,
ON 1/8/91.
ALSO, MINOR AMOUNT OF POLLEN &
STARCH FOUND
H. DAVIS, EPA LEX. LAB.
-------
DRINKING WATER (FOUNTAINS)-
NOVEMBER, 1990 TESTS
FOUND (EPA LAB TESTS):
"BELOW 6 Mir.ROGRAMS/LlTER."
rvw^STANDARDS:
NOW = 50 MICROGRAMS/LITER
SOON = 15
-------
-VENTILATION & AIR CHANGE RATE-
NAB INSPECTION &
(CONSERVATIVE) CALCULATION
VENTILATION (OUTSIDE AIR)
= 25 CFM, PER PERSON
AIR CHANGE RATE = >4 PER HOUR,
VENTILATION IS RATED EXCELLENT
ASHREA STD C89) = 15-20 CFM/PER.
-------
SCHEMATIC OF A TYPICAL VAV - UNIT
(168 IN THE SYSTEM)
WWlSONliDOF
&
Fttffl
WMT
aw
-------
-CURRENT PROBLEM AREAS-
TEMPERATURE DISTRIBUTION,
HORIZONTAL & VERTICAL
DIRECT LIGHTING - TOO LITTLE &
TOO MUCH
INDIRECT LIGHTING
NOISE IN SOME AREAS
VERY DRY AIR PERIODICALLY.
-------
NOTE.
TEMPERATURE BALANCE IS
NEEDED IN SOME LOCATIONS
AT THIS TIME.
-------
- IN SUMMATION -
NO FORMALDEHYDE GAS OVER-
EXPOSURES.
NO CO, CO2, VOCs - PROBLEMS.
NO DUST (FIBERGLASS) PROBLEMS.
NO LEAD IN DRINKING WATER
VENTILATION IS EXCELLENT.
-------
• PROBLEMS ARE LOCALIZED re:
• DIRECT & INDIRECT LIGHTING
• TEMPERATURE CONTROL
• NOISE and SPEECH PRIVACY
AIR DRYNESS IS A GENERAL,
Winter - period PROBLEM
-------
• REPORTED/REFERRED COMPLAINTS,
FROM FIRST DAY TO DATE.
<1% OF ALL EPA EMPLOYEES IN
BUILDING.
NOT "OCCUPATIONAL ILLNESS",
under OSHA.
-------
LETTER OF REQUEST: QUESTIONNAIRES.
1. Medical Questionnaire.
2. Facilities Questionnaire.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONI
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-221 1
MEMORANDUM
DATE: February 15, 1991
SUBJ: Indoor Air Quality Assessment - Questionnaires
FROM: Patricia L. Meane,
for Planning and
TO: All EPA Employees - One Congress Street
We have been busy in the last few months in evaluating the indoor air and work
place qualities in the space which we occupy in this building. Norm Beddows
(Industrial Hygienist), Tom Spittler (Laboratory Director) and Peter Kahn (Chemist)
have provided reports on the chemical analyses, ventilation study, and exposure
assessments which they made. We have held two employee-briefings and provided
two comprehensive reports to you.
For the most part, the results have been encouraging. No significant levels of carbon
monoxide, formaldehyde or volatile organic compounds were found anywhere on our
floors. The carbon dioxide level was very low compared to the levels generally
measured in office spaces.
At this time, we have completed the physical-chemical evaluations, and are entering a
new phase which involves learning in detail what we can about individual work
places. To do this, we need the help of all of you -- those who have complaints or
concerns, and those of you who do not. We need you to take a few minutes to
answer each of the two questionnaires attached. One questionnaire deals with
occupational-medical matters, and the other, with facilities-type questions. We need
answers to both of these to be able to give you the best work places that we can, as
soon as we can. I will make certain that your answers are held in confidence, as
some of you have requested. Please help us to complete our study. I am looking
forward to receiving your opinions and thoughts. I promise to let you know about your
collective views.
Please send the completed facilities questionnaire to Bill Chenoweth (PFM), and the
occupational medical-IAQ questionnaire, to Dr. Alvero O'Campo, Medical Director
(DFEOH) Room, E-120 JFK Federal Building, Boston, MA 02203.
Thank you.
Attachments-(2).
cc: Norm Beddows. s,o
Bill Chenoweth.
Dr. A. O'Campo.
Laurel Seneca.
PRINTED ON RECYCLED PAPER
-------
WORK PLACE QUALITY/FACILTIES QUESTIONNAIRE:
FOR EPA EMPLOYEES, ONE CONGRESS STREET.
•We need your help to ensure that optimum work place quality is provided
to all EPA employees in One Congress Street. You can help by completing
this questionnaire and marking any problem area on the floor plan on the
reverse side. We need everyone's response, even if there is no particular
problem to report. You need not sign the return or indicate your identity in
any way. Thank You. Please send your response directly to:
Mr. W. Chenoweth, Facilities Branch Chief, Mail Code: PFM.
PLEASE REPLY BY FEBUARY 21, 1991. THANK YOU.
Do you have any complaints in your work place? Yes No .
If yes, check the appropriate place, and mark the area on the floor plan.
Temperature too cold too hot
Dust in air
Odors Noticed
Voice Transmission/Lack of Essential Business Privacy
Disturbing Noise/Voice Intrusion
Direct Lighting too low too high
Glare is a Problem
Other & Comments (explain)
When Do These Problems Occur? (e.g., AM/PM/ Specific Day or Period)
Please use the space below to make any additional remarks.
Date / / .
Form NAB(Q.1)1.10.91.
-------
TENTH FLOOR
\—i
^SHADED AREAS = $
SPACE OCCUPIED
4- I | OfTlCf Of RfC(OM*L_, am-r n* *rnrmt\. itnimm tuunjum
l_ ^4. I .r.' COUNSEL r—«4 —>. »o~*in»«to« 1=^
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AW. l»tSTICW>C» AMD TOXICS
ELEVENTH FLOOR
*, •~s* -/
HADE6 AREAS =
PACE OCCUPIED BY OTHER AGENCIE
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-------
OCCUPATIONAL, MEDICAL QUESTIONNAIRE for
Occupants of EPA Space, One Congress Street, Boston, Ma.
Please sent your response IN A SEALED ENVELOPE directly to:
Dr. A. O'CAMPO, MEDICAL DIRECTOR
PHS - DIV. OCC. EMPL. HEALTH,
JFK FEDERAL BUILDING, ROOM E 120
GOVERNMENT CENTER, BOSTON, MA. 02203
PLEASE REPLY BY FEBUARY 21, 1991. THANK YOU.
1. Do you have any complaints re: your work place environmental
quality or related effects? Yes No . If yes, please check:
temperature too cold
temperature too hot
lack of air circulation (stuffy feeling)
noticeable odors
dust In the air
disturbing noises
other (specify)
2. When do these problems occur?
morning daily
afternoon specific day(s) of the week
all day which day(s)
no noticeable trend
3. Health Problems or Symptoms
Describe in three words or less each symptom or adverse health
effect you experience more than two times per week. Example:
runny nose.
Symptom #l .
Symptom #2
Symptom #3 .
Symptom #4
Symptom #5 ___ '.
Symptom #6
-------
Do you have any health problems or allergies which might account
for any of the above symptoms? Yes No . If yes, please
describe.
Do any of the following apply to you?
wear contact lenses
operate video display terminals at least 10% of the work day
operate photocopier machine at least 10% of the work day
use or operate special office machines or equipment (specify)
5. Do you smoke? Yes No
6. What is your job title or position? (optional)
7. Briefly describe your primary job tasks.
8. Your office phone number is? (optional)
9. Your name is? (optional)
10. Date of this report? / /
IS YOUR REPLY TO BE KEPT CONFIDENTIAL? YES NO
Form (Q.2)1.10.91
-------
LETTER TO THE OCCUPATIONAL PHYSICIAN.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGIONI
J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
DATE: February 14, 1991.
TO: A. O'Campo. MD.
Director of FEOH Division,
US. PHS, J.F. Kennedy Building,
Boston, MA.
FROM: N.A. Beddows.
SUBJECT: Distribution of Medical Questionnaire.
Program Information & Requested Feedback.
Today, the medical questionnaire (a facsimile of the NIOSH-EPA Indoor Air Medical
Questionnaire) was sent to all the EPA's employees at One Congress Street, with a
request that they send their responses directly to you so that we can assure that
they are held in confidence and competently evaluated, as you so kindly agreed to
undertake.
I expect that there will be some respondents, and that some of these may have had
field-assignments with EPA Region 1. If this is so, they will most likely have
participated in the Regional medical monitoring program, for which I am the project
officer. You may wish to have access to a medical record which we might have
under this program so that you may better gain an understanding of any reported
disorder or aggravation of a disorder. If this is the case, we would require a simple
written permission from the respondent, addressed to myself (contractually, such
releases from the contract physician are required to be handled in this manner).
Once this is in hand, I will arrange for any record to be made available.
We are sending you under separate cover, a consolidated report of the evaluations
and transactions relating to the indoor air quality assessments made here in recent
months.
I am confident that the responses will be thoroughly reviewed and concisely reported
upon. For our purpose, to assure that we are providing optimum work place safety, I
would need to know how many returns are delivered to you, and what types, and
how many of each type, of disorders or aggravations of pre-existing disorders there
are reported in the total number of returns. No disclosure of identities would arise
in any way in this context. Of course, any and all additional information which you
can provide to us while assuring that confidences are maintained will be most
welcome. Also, employees can make requests for information or consideration
directly to the management.
If you need further information, please advise. My telephone number is 565-3388.
Thank you.
cc. Barbara White. Laurel Seneca. «6T°
Julius Jimeno. Patricia Meaney. William Chenoweth.
PRINTED ON RECYCLED PAPER
-------
CURRENT INFORMATION FROM
THE QUESTIONNAIRES.
-------
SUMMARY OF REPLIES TO QUESTIONNAIRES.
700 copies of both the facilities and medical questionnaires were made available to all employees at One
Congress Street, by direct mailing to all (EPA'/EPA-contractor's) employees in the building, and
distribution at the reception areas. There are approximately 600 potential respondents. The single or
multiple complaints, either about the conditions or symptoms, are summarily stated below. The
summaries are based on (i) the reports sent to the Facilities Branch, and (ii) the oral summary report
provided by the physician on 2/25/91 to the writer.
1. REPLIES TO THE FACILITIES-QUESTIONNAIRE.
LOCATION
COMPLAINT
TEMP. TOO COLD.
TEMP. TOO HOT.
DUSTY.
TOO NOISY.
ODORS PRESENT.
TOO MUCH LIGHT.
TOO LITTLE LIGHT.
TOO MUCH GLARE.
AIR DRYNESS.
STUFFY AIR.
OTHER.
SUM OF COMPLAINTS:
WRITE-IN COMPLAINTS:
10TH
18
08
00
16
06
00
04
06
01
02
00
61.
11TH
03
02
00
07
00
00
02
00
01
01
00
16
(FLOOR) AFFECTED AREAfS)/DIVISION(s)
£1 Corner Offices,
10 10 and 11 floors
23 Central Aisle (10)
ORC office/Cafetaria
•
General
11 floor, WMD.
COMPLAINTS RECEIVED. AS OF 2/25/91:
61.
Please See Attachment re: typical comments.
MAJOR AREAS WITH PROBLEMS, AS IDENTIFIED BY RESPONDENTS.
TENTH FLOOR
OCCUPIED BY OTHER AGENCIES.11.-
ODORS NOTICED ' - -^
^
-------
REPRESENTATIVE WRITE-IN COMPLAINTS
(NOT ALL INCLUSIVE)
10th fl. P&M Div. FAR CORNER WALL Also 11 th fl. WMD. Wall Area:
"temperature too cold, all day...when cold outside" (multiple same comments).
11th fl. WMDiv. "noise is incredibly disruptive—biggest factor on productivity,
overrides all the other factors."
Both floors/Open Offices: "managers should go tell noisy people to keep it quiet.
"Info branch should get covers for all the noisy, chartpaper printers on the open
floor offices. People should use them"
10th fl. AIR Div. Int. Space: "lighting too low all day"
11th fl. AIR Div. Central Area: "this area is noisy all day—it's noisy everywhere."
10th fl. ORC: "no lighting above my work area."
Special Notes Re: Air Movement on part of the 11th Floor
1. Because of the total number of the "write-in" and verbally made comments
on the point of perceived stuffiness on the 11th floor, WMD, central area,
the writer discussed the matter with the building engineer on 2/21/91. He
provided the following information:
"The motor to the VAV in this area is burned out. [He is] waiting for a
replacement motor. The area [in point] was not completed by the HVAC-
contractor." (who went bankrupt). "Two diffussers and associated ducts are
missing. Arrangements have been made to correct the problem. A
contractor [was] in the building today."
2. Based on the above information, the complaint of stuffiness (no air
movement) in the affected area is probably valid. Actual ventilation of the
floor area, however, is judged to be satisfactory by the writer based on
(1) the fact that the floor area is generally open, and (2) the carbon
dioxide tests in December and the VOC(s) tests in January showed a
consistent level of (good quality) ventilation, and a low contamination
situation.
NAB.
-------
2. Information From The Occupational Physician.
Dr O'Campo, Medical Director, Division of Federal Employees Occupational Health,
provided the writer with a comment that about 100 responses to the medical
questionnaire have been received, and that he has sent the responses for analyses to
a colleague. Dr O'Campo said that he would try to provide a summary for distribution
to our employees in the near future. At this time the writer has no data on the
resonses made to the medical questionnaire. Dr O'Campo will provide a written
report later.
NAB. 2/26/91.
-------
III. GENERAL DISCUSSION.
Back-ground information is provided in the summary report dated 12/21/90, and in the
supplemental report dated 1/27/91. Some of this information and new points are
discussed herein.
1. Volatile Compounds Found Indoors. Target Compounds. And On-Site Analysis.
The presence of many hundreds of volatile and semi-volatile compounds, very small
concentrations, could be found in office buildings if ultra-sensitive detection (GC-MS)
were employed (Characterization of VOCs in Public Access Buildings. Sheldon, LS.
1987).
The volatile organic compounds that would be likely to be found in new office buildings
are common compounds which are members of the following chemical classes:
o Aliphatic Hydrocarbons (e.g., n-decane, undecane, cerene, limonene).
Painted sheetrock, glued carpet, and office furnishing are common sources.
o Aromatic Hydrocarbons (e.g., toluene, benzene, styrene, ethyl benzene,
trimethyl benzene). Glued carpet and wall covering are common sources.
o Halogenated Hydrocarbons (e.g., tetrachloroethylene, 1,1,1-trichloroethane,
trichloroethylene, dichlorobenzene, chloroform). Cleaning agents and insecticides
are common sources.
o Aldehydes (e.g., formaldehyde). Furnishing is the major source.
Other classes (e.g., organic acids, alcohols) may also exist in some situations.
The concentrations of the compounds actually present will depend largely on the types
and quantities of furnishing, the age of the installation (with time, concentrations
decrease), and the ventilation rate.
Many of the common, room-temperature volatile compounds of these four major classes
can be analyzed and quantified on-site, at the parts per billion level, using a portable
gas chromatograph with a photoionizing detector. Essentially, the compound of interest
need have an ionization potential equal or less than the energy of the detector
(nominally, 10.2 ev.) and be relatively responsive to the ionization detector. Hydrogen
cyanide (IP, 12.8 ev.) and carbon dioxide (IP, 14.1 ev.) are not detected by PID.
Benzene and toluene which are ubiquitous can be identified and quantified using a GC-
PID instrument and carefully prepared, and validated "head-space" reference standards*
at about half a part per billion (the outside city air could contain one part per billion v/v
of each of these compounds; meta and para xylenes, at about one part per billion; and
tetrachloroethylene, at about one part per billion.
* H an accurately known, very dilute solution of a sparingly soluble volatile organic compound in water (TC, wt/vol.
unit) completely fills a capped vial, and the a fraction (F) of the solution is withdrawn and discarded. The volatile
compound partitions itself between the air and the water so that an air concentration (A, wt/vol.) is established at
the prevailing equilibrium conditions. The relationship is: TC/A = 1/K + (F/1-F). "H" is Henry's constant, which is
temperature dependant. In practice prepared solutions (fully filled vial) are kept in ice until needed, and a micro
syringe is used to sample the head space and inject the sample into the GC column. The GC has a control for
selecting an appropriate scale.
-------
In a well-ventilated, well-regulated office, one might expect to encounter toluene
concentrations of less than ten parts per billion; and benzene, at less than five parts
per billion. However, in a smoking room, the concentrations of these compounds (and
carbon monoxide) could be at least an order of magnitude greater than the respective
non-smoking office levels.
Employing benzene, toluene, o,m, p xylenes, trichloroethylene, chlorobenzene and other
several other common volatile compounds (which have ionization potentials at or below
10.2 e.v) as target compounds for evaluating indoor air quality using a portable GC-
PID unit is both appropriate and convenient. In this way, one can quickly evaluate
both the (air) quality of a space, and the consistency of quality of a large space, and
determine if an facility or operation (for instance, a cafeteria, a smoking room or a
printing room) is causing or contributing to a localized air quality problem.
Formaldehyde is a common contaminant of interest. It can be quantified (with a
practical limit of a few parts per billion) quickly and inexpensively using a one-day
exposure dosimeter and high performance liquid chromatography (for more information,
please see the supplementary report dated 1/29/91).
Carbon dioxide (an index of effective ventilation) and carbon monoxide (an indicator of
a problem of infiltration from a garage operation, or ineffective ventilation of a smoking
room) can be quickly and inexpensively quantified, with adequate sensitivity for these
purposes, using a portable infra-red (Miran) analyzer, for more information, please see
the summary report dated 12/21/90.
2. Office Characteristics. New Office Treatment.
When it comes to indoor air and work place environmental quality matters, we know
that forced ventilation and freedom from respirable paniculate and organic compounds
are essential. Also, direct and indirect lighting, relative humidity, temperature, and air
velocity are major factors. Work place noise can be important. For the most part, these
factors are easily quantified, and can be related to occupants' perceptions of their well-
being. We are also aware of the role that microbiological agents can have in work
place safety. What is much less evident, is the relationship of sub-clinical effects to
repeated daily exposures to the hundreds of volatile organic compounds which may be
identified in indoor air at fractional parts per billion or parts per billion concentrations
when at sophisticated analytical methods are employed. What effects exposuress to
a low total concentration of a mixture of aliphatic, aromatic and chlorinated hydrocar-
bons (the dominant classes of volatile compounds which could be found in office air)
and alcohols, acids, ketones, aldehydes and esters (which may also be present in office
air) at sub-parts or a few parts per billion levels) may have on occupants appears to
be essentially unknown, despite the fact that such exposures have been implicated in
sick building syndrome scenarios.
-------
New buildings are expected to have greater initial concentrations of volatile compounds
in the air than they would have several months later. Some researchers (Pellizzari,
1984- Wallace et al, 1987) have demonstrated that several orders of magnitude
differences between the initial concentrations and the concentrations several months
later, of some simple aromatic and aliphatic hydrocarbons, can occur. Also, correspond-
ingly, half-lives of several weeks to several months can occur.
Each situation is matter of dynamic mixing of emitted vapors and fresh air supply. The
types and extent of furnishing used and the turn-over time for the building-ventilation
dictate what will be the initial concentrations and concentration decay rates in each
case So it seems prudent to maximally air out any new building before occupancy,
and to continue airing out even after occupancy. There is obviously a limit to doing this;
its an economic limit, essentially, and one which should be carefully thought about by
the building owners and others.
3. Noise In The Work Place.
Noise is an evident problem in some spaces. Engineered solutions may be available
in some instances, sound absorptive panels and other devices. A correct approach to
noise control calls for the services of an acoustic engineer. However, some solutions
are self evident. The provision of computer-printer, acoustic covers, and proper persona
behavior, including properly using the telephones for business communications will
improve the work place quality for many of the occupants.
4. Economic Considerations of Indoor Air Quality Evaluation.
It is abundantly clear that evaluating indoor air quality is potentially very expensive. It
is interesting to briefly look at potential costs. The consultant certified industnal hygienist
rate is $100 - $120 per hour; the consultant analyst rate is $60 to $80 per hour,
depending on the services rendered; and other needed ancillary services are, typically,
$30 to $35 per hour. An lAQ-evaluation, encompassing the minimal scope of the
evaluations reported herein, requires, as a minimum, the following levels of services:
200 hours, industrial hygiene time; 60 hours, analysts' time; and 40 hours, support
services Thus, one could expect consultants' charges to be about $30,000 for a
preliminary but reasonably comprehensive study of a commercial facility comprising
several large floors. The economy of using in-house expert services when they exist
in conducting an evaluation is evident.
-------
V. SUMMARY OF CONCLUSIONS.
With Respect To Contaminants.
Carbon monoxide, formaldehyde, benzene, toluene, and trichloroethylene have been
found in indoor air at One Congress at only trace concentrations. In some cases, the
indoor air concentrations were similar to the concentrations found in the street air
immediately outside the building (the street air test was: benzene, 1 ppb; toluene, 1.5
ppb, on January 8, the day that the indoor tests were made by T. Spittler and P.
Kahn).
The reported sum total of the important target volatile organic compounds which were
evaluated, excluding formaldehyde, found in the office air, at any location excluding the
designated smoking room on the tenth floor, was less than 7 parts per billion, by
volume. The dominant constituent was toluene, at 4 ppb; and, the second dominant
compound was benzene, at 1.5 ppb (as a maximum).
Formaldehyde was found in the indoor air. Based on the best chemistry available, using
a battery of eleven tests including one control, made in late December 1990, we found
the geometric mean concentration was 14 ppb, with a geometric standard deviation of
1.3 (the transition point for a log normal distribution).
The smoking room was found to have elevated levels of carbon monoxide (5 ppm),
benzene (30 ppb), toluene (64 ppb), and o,m,p xylenes (12 ppb). These levels are what
one would expect for this type of room (with no dedicated forced ventilation).
Carbon dioxide level in the building was less than 400 parts per million. This fact, and
the spot checks which the writer made on representative variable air volume (VAV)
units, with respect to the minimal fresh air intake rate, and the conservative evaluation
by the writer of the total ventilation rate from simultaneously operational VAV-units,
indicate that the degree of gross forced ventilation on both floors is excellent.
Dust in air has been shown to be free of inorganic fibers and silica. Dust loading is
very light. In one area grains of pollen were found, together with a very light level of
paper and organic fibers somewhat larger than respirable size, using an exhaustive
microscopic evaluation. The finding of pollen indoors is to be expected, under such an
examination. The pollen (the writer's "rounds", in the evaluation of 1/8/91) load level
(<100 count) was negligible based on the number of microscopic fields (200, at about
0.006 mm. sq.) examined and the high volume (1900 liters) of air sampled and filtered
(using a 35mm dia., 0.8 urn pore-size, MCE-filter).
Sub-standard office direct lighting exists in some locations. Localized glare, noise
transmission, and temperature swings are evident problems. Ventilation of the smoking
room is sub-standard. These problems are being worked on by the facilities branch
personnel and the building management. An engineered solution exists for each of the
illumination and ventilation problems, and may exist for the other types of problem.
Periodic, general low level relative humidity is an evident problem. This is not amenable
to an engineered control. Personal practices and local humidification may ameliorate
the problem when it arises.
-------
Microbiologic evaluation was not undertaken in the studies to date. There was and is
no indication from any EPA experience that this ought to be done. The Department of
Labor did conduct such an examination, in December 1990, in an enclosed office on
the eleventh floor as part of an evaluation of a work place in response an apparent
case of acute urticaria of an unresolved etiology. A report of the evaluation was
provided to the writer by the DOL Regional Administrator. The report concludes that
there is no microbiological contamination to be concerned about (the remainder of this
(DOL) evaluation was consistent with the findings of the EPA studies reported herein).
With Respect To Complaints.
The total sum of currently known (as of 2/28/91) formal complaints involving both
claimed occupational exposures is low. The affirmative responses to the occupational
medical questionnaire-survey, which might relate to an occupational office exposure is
being evaluated by the physician, who will report separately on this matter.
Final Comment.
Based on the preliminary quantitative studies made to date and the respective norms,
the writer believes that there are no current recognizable hazards which could be
associated in any way with any current level of indoor contamination of any kind. The
degree of gross ventilation appears to be excellent. Localized problems in illumination,
noise and possibly diffused air flow appear to exist, and air dryness is a general but
periodic problem. It is possible that a small number of our work-force is extraordinarily
sensitive to either trace levels of contaminants and/or physical conditions in the work
place. However, the writer knows of no evidence to date which indicate that
occupational (health) hazards exist indoors at One Congress Street.
-------
VI. RECOMMENDATIONS.
On The Point Of Addressing Complaints.
In regard to past complaints asserting only that some aspect of the new work place
seemed to cause some minor irritation or level of discomfort, one might accept them
at face value. We do not have any period data on relatively low concentrations of
potentially irritating substances (formaldehyde, volatile organic compounds or dust) or
any physical agent to base a concurrence or dissention. Any past complaint asserting
any serious adverse effect casually related to the work place is invidious, knowing what
we do know about the facility and its furbishing, and the extensive period of ventilation
(airing out) which was employed prior to occupancy. An current complaint from any
source ought to be considered fully in terms of any specific and local condition which
exists. There evidently are problems in direct lighting, indirect lighting, drafts and
temperature drops, and work place noise which may be disconcerting but are not
recognizably hazardous. A complaint made to the occupational physician, via the
medical questionnaire-survey, ought to be formally responded to, after a competent
industrial hygiene assessment has been made.
On Corrective Action.
Issues of lighting, noise, temperature and drafts ought to be systematically corrected.
Ongoing facilities-programs appear to be now in place for this purpose.
In regard to work place noise, the use of sound covers for printers is evidently needed
in some areas, especially the areas near the atrium and the adjacent offices. Also,
administrative efforts appear to be needed to persuade some employees to be less
noisy; to use the office telephone for business only; or to hold meetings in conference
rooms rather than in open offices or aisles. This could very well be as effective as
undertaking an engineered solution to a localized noise problem.
The use of humidifiers in closed offices might be beneficial at times. Care would have
to be taken to use a bacteriastat in the water. Also, one would need to make sure that
the circuit was not overloaded.
Consideration of force-ventilating the 10th floor photocopy room is recommended.
On Requiring Additional Quantitative Evaluations.
Every employee-complaint should be responded to individually; this may require making
a local evaluation. However, absent a significant level of complaints which could be
reasonably related to a questionable occupational indoor exposure, further in-depth
analyses of volatile organic chemicals including formaldehyde is not justifiable. Further
evaluation would require making extraordinary and costly efforts; and even then, the
likelihood would be low, in the judgment of the writer, that a meaningful outcome would
ensue from the analyses of volatile organic contaminants which might be present a
mere trace concentrations. On this point, one simply does not know the toxicological
relevance of an observed plethora of common garden variety organic compounds
measured at fractional part per billion levels.
-------
APPENDIX TO CONSOLIDATED REPORT
Appendix
1. December, 1990 Formaldehyde Data (Beddows et al).
2. December, 1990 Target VOC Data (Spittler et al).
3. Febuary, 1991 Illuminance Data (Wade, R.).
-------
GMD
I SYSTEMS,
INC.
DECEMBER £6. 1990
U. S. EPA
JFK FEDERAL &LDG
BOSTON, rtft Ci££'t23
ATTENTION: NOftrcAN &EDDOWS
ENCLOSED PLEASE FINJ M COPY OF THE RESULTS FRO* THE
FORMALDEHYDE BADGES YOU SUBMITTED FOR ANALYSIS.
IF YOU HAV-Z ANY FURTHER QUESTIONS REGARDING THESE RESULTS,
~"_t;AiiE. CONTACT GMD.
&EST REGARDS,
LINDA COYNE
GMD LAB & RESEARCH MANAGER
ENCLOSURES: FORMAuDEHYDE ANALYSIS RtPORTS
RKM
Old Roiite 519 Hendersonville, PA 15339 USA (412) 746-3600 FAX: (412) 746-1359
A BACHARACX Affiliate
-------
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-------
INDOOR VOC AIR SCREENIRC SORVET RESULTS
EPA REGIOR I OFFICE BOILDIHO
OHE CONGRESS STREET - BOSTOH, MASSACHUSETTS
JANUARY 1991
A description of the sampling locations used in this survey «re
described below.
Floor 10
Cafeteria - One grab sample was collected approximately 5
feet above floor level at 1307 hours in the hall way adjacent
to the cafeteria entrance.
L B Area - One grab sample was collected approximately 5
feet above floor level at 1310 hours adjacent to the work
station occupied by employee L.B.
Paul Keough's Office - One grab sample w« , Paul
approximately 5 feet above floor level at 1330 hours in Paul
Keough's Office.
B C. Area - One grab sample was collected approximately 5
feet above floor level at 1335 hours adjacent to the work
station occupied by employee B.C.
Smoking Room - Two grab samples were collected approximately
5 feet above floor level at 1350 hours in the smoking room.
At the time samples were collected, the room was occupied
by three individuals, 2 were smoking cigarettes and 1 a pipe.
Floor 11
L W. Area - One grab sample was collected approximately 5
feet above floor level at 1230 hours adjacent to the work
station occupied by employee L.W.
R M. Area - One grab sample was collected approximately 5
feet above floor level at 1235 hours adjacent to the work
station occupied by employee R.M.
Library - One grab sample was collected approximately 5 feet
above floor level at 1250 hours adjacent to the circulation
desk.
EPA Reception Desk - One grab sample was collected
"p'ro'imate™ 5 feet above floor level at 1253 hours adjacent
to the reception desk.
-------
FLOOR 10 - ram ooooa1* OFFICE
noon u - t.».
Compound
Detection Background Seaple I 21
Limit*
<»Pb W/Tl
Compound
BeCICne
Tri ehl oroetby 1 «ne
Toluene
Tetrecbleroetbylene
Chlorob*niene
Etbylbeniene
• . f lylene
o-Xylene
0.2
0.2
0.6
o.»
2
1
1
4
1
TO
1.5
•D
TO
n
n
•D
1.2
n
4.2
n
•D
n
n
n
TO • non* *
1
•D
l.S
"D
•D
TO
TO
TO
1.2
TO
3.6
TO
TO
•D
TO
TO
Compound
Detection Background Sample I 11
Limit*
v/vl
Btntene 0.2
Tricbloroetbylene 0.2
Toluene 0.6
Tetrccbloroethjlene 0.8
Chlorobenten* 2
Etbjlbeniene 1
•. p Xylene 1
o-Zylene 4
1
TO
l.S
TO
•D
TO
TO
TO
1.5
1.2
3.6
RD
KD
TO
•D
n
Detection Background Sejepl* I •
Limit*
Bensene
Tricbloroetbyleoe
Toluene
Totrecbloroetbrlene
Cnlorobentea*
Etbylbeniene
•, p Ijlene
o-iyiene
O.I
0.2
o.«
O.I
2
1
1
4
1
«°
1.5
n
n
n
n
m
i
n
4
n
n
TO
TO
n>
•D • oondeteeteble Iff tit were net detected abev*
Mtbod's dtt«etion
pux» 11 -
B«ek«rouDd Bupl* I 14
w/v) tcpb T/T) - (BPb T/T)
Triehloro»thyl«n«
T«tr«ehloro«thjl«n«
Chlorob«nt«n«
ttbrlb«oi«n*
•, p Ijl«a»
0-Ijl*B«
0.2
0.2
C.»
O.I
2
1
1
4
1
•D
l.S
TO
•D
TO
n
•D
1.2
n
i
1.4
•D
TO
TO
TO
FLOOR 11 - l.N.
Compound
D«t«ction
Limit*
Background Sunpl* I 10
Bentene 0.2
Trichloroethjlene 0.2
Toluene 0.6
Tetrichloroethylene 0.8
Cblorobeniene 2
Etbrlbeniene 1
m. p Ijlene 1
o-Xrlene 4
1
• D
1.5
TO
TO
•D
TO
•D
l.S
TO
4
TO
•D
•D
•D
TO
Compound
FLOOR 11 - UCZPTIO* DESK
Detection Background Simple I 15
Limit*
v/vl (ccb v/vl (pPb
Benten* 0.2 1
Trichloroetbylene 0.2 TO
Toluene 0.6 l.S
TetrBCbloroethylen* 0.8 TO
Cblorobenten* 2 TO
Ethylbeniene 1 ">
». p Xjlene 1 "»
o-Xylene 4 «
1.2
TO
3
TO
TO
TO
n>
TO
0.8. EHVIROKXZHTAL MOTECTIOH kCEDCT. U01OR 1. ENVIRONMENTAL SERVICES DIVJIIO*
-------
noo* 10 - BIOKIBC ROOM
Compound Detection Background Bunple I )9
Limits
v/v) (ppb T/Y) (ppb T/V)
Bensene 0.2
TricbloroithylcQ* 0.2
Tolu«n« 0.6
T«tr«chloro«th7l«D« O.I
CblorobtntcD* 2
Cth7lb«ni«n« 1
m. p Zjlu>* 1
o-Xjl«n« 4
1
•0
l.S
•D
RD
WO
•D
•D
90
•D
«4
n
•D
•D
7
S
ND « nondet«ctibl• Lcvtlt wert not detected tbovt
method's detection limit.
-------
FOOTCANDLE READINGS
DIV FLR W/S
ORC 10
U
U
U
U
U
U
U
U
U
U
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
PR I
f/c
30
28
46
36
43
36
22
20
28
40
45
42
55
15
34
45
48
32
42
40
44
48
24
30
48
30
46
42
65
20
14
34
46
30
22
46
40
30
30
30
30
40
48
44
40
60
60
6O
60
60
*
34
SEC
f/c
36
38
30
28
26
30
*
*
42
42
40
45
50
24
34
45
45
38
42
32
60
70
28
44
60
45
44
*
55
48
40
60
36
30
48
36
30
32
30
30
30
46
40
42
40
44
58
6O
60
50
*
50
PRIVATE OFFICES AT DESK LEVEL
OFFICE* f/c
A106
A107
A1O8
A109
A110
Alll
A112
A113
A114
A115
A116
A117
A118
A119
A120
A121
A122A
A122B
A123
A124
A125
A126
A127
A128
A129
A130
A131
A132
A133
A134
A135
A136
A137
A138
A139
A140
A141
A142
A143
A144
A145
A146
A147
A148
A149
A150
A151
A152
A153
A154
A155
A156
* SEO CHGE
A173
65
34
70
45
**
»*
80
60
24 ***
80
30
60
55
55
35 **«
70
50
NA
**
80
80
70
44
60
50
s*
90
70
42
.80
65
40
60
70
**
55
60
40
70
36
NA
60
NA
**
**
NA
**
**
50
**
NA
40
na
-------
FOOTCANDLE READINGS
RA'S 10 A
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
AMD 1O
A 78
79
80
81
A 82
A 83
84
85
86
87 THRU
92
93
94
95
A 96
A 97
24
14
44
32
14
14
14
32
22
50
40
22
30
22
22
48
46
44
36
28
14
44
48
50
34
28
*
*
*
36
38
38
42
10
91 PMD
*
• *
*
*
30
42
22
24
48
44
18
18
14
18
40
50
46
20
40
40
4O
40
42
38
48
34
12
60
36
46
32
48
*
*
*
50
50
36
44
20
*
*
*
*
50
50
M
W
U
U
U
U
U
U
U
U
U
A174
A175
A176
A177
A178
A179
A180
A181
A182A
A182B
A182C
A183
A157
A158
A159
A16O
A161
A162
A163A
A164
A165
A166
A167
A 168 A
A168B
A168C
A169
A170
A171
A172
A302
A303
A304
A305
A306
A307
A308
A309
A310
A311
A312
A313
A314
A315
A316
A317
**
**
65 NEED 2FT
70
70
90
80
40
44
48
80
52
50
44
40
NA
48
50
70
46
60
NA
X*
70
70
70
90
90
NA
90
44
46
46
60
55
38
NA
48
NA
60
24
**
NA
NA
56
NA
-------
12-Feb-91
FOOTCANDLE READINGS
A 98
A 99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141 A
141 B
141 C
142
143
144
145
146
147
148
149
149 A
150
150 A
151
14
36
30
36
.30
36
36
50
50
24
35
48
50
46
50
12
48
14
12
28
44
30
24
32
20
26
24
28
36
20
24
36
36
24
36
42
34
26
36
34
22
36
48
38
24
40
28
50
40
22
30
20
24
48
40
28
30
24
38
50
34
30
32
30
24
50
48
46
46
50
50
26
48
48
16
16
28
36
28
34
30
44
42
38
42
38
46
36
34
42
48
28
44
34
42
36
40
40
22
44
44
36
40
*
26
50
49
26
40
30
20
42
60
44
60
36
A318 20
A319 20
A320 NA
A321 18
A322 20
*SEQ CHG
U A328 55
U A329 60
A332 LAB
-------
TO. page 3
FOOTCANDLE READINGS
152
153
154
W 155
W 156
157
158
W 159
U 160
161
162
W 163
W 164
165
166
U 167
W 168
169
170
U 171
W 172
173
174
U 175
U 176
PMD 1O
A 87
A 88
A 89
A 90
A 91
*SEO
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
W 199
W 200
38
46
18
42
42
60
30
46
48
40
12
26
48
42
12
22
42
44
30
40
40
42
42
36
46
70
70
50
55
70
CHG
26
20
30
34
40
30
44
30
60
38
5O
26
20
*
*
30
42
42
42
24
26
28
38
18
36
60
42
48
60
60
55
50
55
36
28
38
50
42
40
42
40
48
50
50
50
50
60
60
48
60
75
50
50
50
50
40
40
60
38
44
48
24
60
50
48
20
18
*
*
46
36
46
46
34
34
36
26
20
A323
A324
U A325
A326
*SEQ CHG
U A334
W A335
U A336
U A337
A338
A339
A340
A341
A342
A343
A344
A345
A346
A347
A348
A349
A350
A351
U A352
A353
U A354
A355
A356
A357
A358
60
NA
22
44
32
60
48 ***
60
NA
NA
NA
NA
NA
NA
NA
NA
55
46
55
NA
NA
NA
60
50
42
NA
26
50
46
-------
12-Feb-91 Page 4
FOOTCANDLE READINGS
A359 55
A360 NA
A361 NA
A362 40
A363 NA
A364 40
W 201
U 202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
U 224
W 225
U 226
W 227
W 228
U 229
U 230
231
232
W 233
U 234
235
236
W 237
U 238
W 239
U 240
241
242
W 243
U 244
W 245
246
247
U 248
U 249
U 250
U 251
252
253
254
255
256
257
258
14
12
48
50
42
40
18
38
48
*
*
32
38
30
40
28
22
36
36
34
44
38
50
26
16
46
24
18
26
14
20
48
44
40
34
55
50
30
34
32
48
32
34
22
18
60
50
50
36
60
60
48
65
35
46
22
48
30
16
16
46
42
44
42
48
38
46
*
*
46
36
38
50
50
28
24
14
12
38
48
60
16
16
30
30
24
16
12
42
40
26
28
40
46
30
26
40
36
60
60
16
40
30
60
55
50
36
*
*
48
60
6O
50
16
48
48
-------
Hage 5
FOOTCANDLE READINGS
259
260
261
262
263
264
W 265
U 266
U 267
U 268
269
270
271
272
273
274
275
276
277
278
279
U 280
U 281
U 282
U 283
284
285
U 286
U 287
288
289
29O
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
31O
311
312
313
314
315
316
50
48
30
60
.30
42
26
40
36
36
30
14
32
36
38
38
*
55
36
34
34
38
5O
34
40
85
60
38
32
38
50
46
44
48
38
38
48
40
25
50
18
42
46
48
28
20
25
22
50
60
50
50
50
42
48
50
38
55
46
-10
-10
32
44
30
42
*
46
50
30
50
60
5O
50
45
50
60
42
46
42
50
34
40
38
48
44
36
48
48
60
28
42
46
28
22
24
18
28
50
-------
12-Feb-91
FOOTCANOLE READINGS
A
A
A
A
A
A
A
A
A
A
A
A
A
WHO 11
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
45
18
50
18
55
34
40
32
44
28
28
70
70
80
70
34
34
60
50
60
3O
60
75
30
60
50
50
70
75
65
65
80
40
46
40
24
26
52
30
30
70
24
26
50
60
70
7O
30
28
46
30
60
55
55
20
40
28
42
28
46
34
*
48
65
44
46
75
70
80
60
70
6O
48
60
70
46
70
75
34
6O
5O
50
70
75
65
65
80
*
*
60
60
7O
70
50
50
50
60
60
60
65
65
80
80
80
80
55
50
60
34
65
*
eioi
B102
B103
B104
8105
U B106
B107
B108
B109
U B11O
U Bill
U B112
U B113
U B114
6115
B116
B117
B118
B119
B12O
B121
B122
B123
B124
NA
60
44
50
50
38
NA
NA
NA
42
40
60
40
80
50
40
65
50
20
NA
NA
NA
NA
40
-------
Page 7
FOOTCANDLE READINGS
B125 42
8126 50
B127 -10
U B128 50
U B129 42
UJ B130 38
U B131 48
B132 NA
B133 50
6134 28
U
U
U
U
U
A
372
373
374
375
376
377
378
379
380
380 A
381
382
383
384
385
386
387
388
389
390
391
392
393
394
395
396
397 A
397 8
397 C
398
399
400
401
402
403
404
405
406
407
408
409
410
411
412
413
414
415
416
417
418
419
420
421
422
423
424
425
426
55
36
4O
30
20
20
50
55
28
90
60
32
34
44
24
40
44
50
60
60
36
28
32
42
26
50
12
14
16
48
50
28
44
44
30
48
48
30
44
42
28
46
48
30
42
42
30
46
48
32
44
44
30
44
32
46
70
70
70
20
26
26
16
14
50
48
40
80
60
60
50
38
50
50
46
50
60
50
50
42
38
38
38
60
*
*
*
5O
60
44
42
46
46
*
*
44
46
30
40
*
*
42
44
44
30
60
60
46
46
44
42
48
l
42
44
65
50
-------
FOOTCANOLE READINGS
w
u
w
u
w
u
w
u
w
u
u
u
u
u
w
u
w
u
w
u
14
427
428
429
430
431
432
433
434
435
436
437
438
439
440
441
442
443
444
445
446
447
448
449
450
451
452
453
454
455
456
457
458
459
460
461
462
463
464
465
466
467
468
469
470
471
472
473
474
475
476
477
478
479
480
481
482
483
484
34
48
44
48
42
34
34
40
36
36
48
48
42
42
60
44
50
34
55
44
36
38
46
28
34
48
38
42
34
36
65
34
44
50
30
48
36
36
50
34
44
30
30
48
44
48
42
38
10
12
12
30
36
36
32
34
38
40
50
50
70
65
60
55
60
70
6O
48
60
60
55
60
46
50
44
50
32
60
5O
70
70
55
50
60
50
48
60
7O
50
55
55
70
60
50
50
46
70
55
60
44
28
30
44
48
36
30
24
26
24
38
*
44
46
42
42
*
-------
Page
FOOTCANDLE READINGS
485
486
487
488
489
490
491
492
493
494
495
496
497
498
499
500
501
502
503
5O4
504
506
507
508
509
510
511
512
513
514
515
DIG 11
W 516
U 517
W 518
U 519
W 520
U 521
522
523
524
525
526
527
528
529
530
531
532
533
534
535
536
537
30
20
40
22
32
24
24
40
40
34
42
28
22
50
25
38
22
24
38
46
50
26
46
38
26
32
22
48
32
34
34
60
44
46
44
40
34
48
30
34
48
46
38
42
55
55
32
36
65
36
10
65
55
*
34
42
28
32
40
34
36
32
44
44
40
4O
42
*
38
40
42
40
*
*
*
44
38
28
28
30
38
38
46
20
40
*
60
44
48
50
50
38
60
38
48
44
22
46
48
40
50
50
34
26
65
55
W B135
B136
B137
B138
B139
B140
B141
B142
B143
B144
B145
B146
6147
U B148
B149
B150
B151
B152
55
42
3O
44
NA
75
NA
NA
65
30
NA
44
NA
65
60
44
70
NA
-------
FOOTCANDLE READINGS
NEIC 11
TI
LIB
W W10
W Wll
U12
U13
W14
Ml 5
U16
W17
W18
11 SPECIAL
538
539
540
541
542
A 543
A 544
A 545
48
48
44
44
44
42
42
42
50
PURPOSE
40
20
24
28
24
42
50
45
48
48
44
44
44
46
42
42
48
AREAS
32
*
*
*
*
40
70
50
W B153
B154
B155
B156
W B156A
W B157
B158
A B162
60
NA
NA
NA
NA
NA
NA
60
"A" PRECEEDING W/S OR OFFICE DESIGNATES IN ATRIUM
•W PRECEEDINGW/S OR OFFICE DESIGNATES ON A WINDOW
* DESIGNATES NO WORKSURFACES OR NOT REQUIRED
** W/S OR OFFICE NOT ON PLANS
*** BULBS REMOVED TO CUT BACK LIGHT
------- |