UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                         REGION I

       J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
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.
 Second Printing, With Public Summary Report of 3/15/91 Appended.
                    PRINTED ON RECYCLED PAPER
                                                          0 Tr- *

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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 1 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. Also,
summary data,  for the period of November 1990  to  February 1991, on formaldehyde, target volatile
organic compounds and illuminance are provided, as appendices.

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 specific 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, di/tri-
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 comer-wall locations on
both floors.  There  is no infiltration  of carbon monoxide from the garages below. Formaldehyde level is
consistently low. The levels 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.
      • 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 Of 12/21/90.
      • Notice Of Update Meeting.
      t 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 the Occupational Physician.
      • 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 (Spinier 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:

«     Evaluate target volatile organic  compounds (toluene, benzene,  di/tri-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.
      t 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  illumination, 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-morning
     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  valuative programs are identified. At some
     later date, management might want to have such programs defined
     and implemented by  outside  specialists.  To this  end, program
     information  is provided.  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 (C02) 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.

I.e. 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 paniculate  - 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 shin 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; PAST); and, in some
cases, by a respiratory air flow restriction, as measured by FEV, 0 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 al,  in  Denmark  has shown  that a  mixture  of
 hydrocarbons which are known to be common indoor air pollutants will cause eye,  nose
 and throat  irritation  in  healthy  adults,  which  is not adaptable,  at an exposure of:
 concentration of approximately one part per million  (measured as toluene; GC-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. Outgassing 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) CCyCO, and (2) Formaldehyde Tests.  Other Observations.

1. CO,.  CO Tests.

1.a.  Dr. Tom Spittler, BSD 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 levels is comparable to the outside level.

1 .c. The maximum CO concentration reported for an office space was 0.9 ppm.

1.d. The CO concentration  reported for the 10th floor smoking-room (when it was
occupied by five people who were smoking - about half-full, and when the two "smoke-
eaters"  were in operation, as observed by the writer) was 5 ppm.

2. Formaldehyde Tests

2.a. The 10th floor was  tested quantitatively for formaldehyde  in the first week of
November.
The writer's open-floor plan  office (10-319)  and a closed type  office (10-364)  were
tested using a passive dosimeter which was exposed for 160 hours, during a normal
work period which included a week-end period.  The MA state  DPH made the analyses
(which were kindly arranged for by Dr. Mary Beth Smuts, of the EPA Region 1, Air
Toxics and Pesticides Division).  The  MA-DPH  reported results, as simple average
values for the 160 hour sample time, as follows:


             OPEN OFFICE AREA (10-319): 0.018 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.3.a. are reported on the basis that at least
one EPA employee has made a relevant comment  to the safety manager.

4.b. Comments  have been made as a part of the complaints of headaches, eye  or
throat irritation, irritability, and  backache.

4.c. The  actual  or perceived  extent and  seriousness of complaints is not currently
known; the comments or complaints made to the safety manager have  been relatively
few, and only an informal survey has been made. An EPA  protocol to formally assess
concerns is available.

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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.

1.d. "Legionella"  is  not considered  to be a risk; the HVAC cooling-intake  does not
involve, and is not in  proximity to, pooled  or sprayed water.

2.  Formaldehyde.

2.a. The reported results  of (the November,  1990) tests for formaldehyde  and the
evident absence of its distinctive odor indicate that there is no problem of formaldehyde
in the  10th or 11th floor offices.

3.  Reason  for the Perceived Current Absence of General Chemical  Odors.

3.a. There is no discernible persistent odor of volatile organic  compounds of the type
which  characterize new furnishings  in any  of  the  open office spaces, and none is
expected  because: (i) no  urethane foam  backed partitions  nor any  organic solvent-
based  paints were used  in the installation; (ii)  carpet tiles which had  very little odor
when they were new  were used instead of carpet stock in  rolls which appear to hold
on to the distinctive smell of  new rolls of carpet; (iii) only  a  water-based poly vinyl
acetate (PVA) glue was used with the carpeting, and not all of the carpet tiles required
gluing  down (they  mechanically lock in-place in the lay-down); and (iv) the building was
aired out before occupancy occurred for at least three weeks, using the  HVAC system,
after the carpet tiles and the office furnishings were installed.

3.b. Notwithstanding the  absence of a persistent general chemical odor  of  the new
furnishing type, cleaning  chemical-odors (and  associated acute eye irritation) exist at
times in the Information Center,  as observed by the writer.

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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 shift in aural or visual acuity would occur. However,
certain  physical discomforts and  localized  interferences with  business privacy and
productivity exist locally and need resolving.

(iv) Minimal dust and minimal  noise in a large, carpeted  office are mutually exclusive;
a balance is needed, based on the facts,  recognizing that carpeting is needed for noise
control.

4.b.  Appropriate responses to specific matters and situations.

(i)  Volatile/semi-volatile Organic Compounds:  as mentioned previously, aldehydes,
alcohols,  substituted  cyclo-aliphatic compounds,  and  other classes  of  organic
compounds which  have  been associated with  some  known offending furnishing
materials  often  have odors which can be detected  by people at  sub-part per billion
levels.  When there  is no chemical odor or a significant  level  of complaints of eye  or
respiratory tract irritation  in the offices, and  when materials were selected with a view
to  not having volatile organic compounds released into the work place (as in this case),
it seems that conducting a broad total volatile organic analysis would not be necessary;
however,  spot checks in areas could be useful.

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  particulate 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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                                       14
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.

I.e. Arrange (i) relative positions, and (ii) lights  to prevent or minimize (a) reflected
glare from desk lights, and (b) direct glare from O/H lights with no open.small-gnds  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 o! View.    (ii) Direct Glare From
                                                   O/H Non-ditluse 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:

      • 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.

     • USE A BLACK DESK PAD FOR IMPROVED CONTRAST AND COMFORT IN
     READING.

     o WHEN USING A PC, TAKE FREQUENT BREAKS -- REST YOUR EYES;
     STRETCH YOUR BACK AND NECK MUSCLES, AND SHAKE YOUR WRISTS
     AND FINGERS TO RELAX THEM.

     • SUPPORT YOUR LOWER FOREARMS IN FRONT OF THE KEY BOARD (A
     20" x 6" x 3/4" FOAM PAD WILL BE USEFUL WHEN PLACED AT THE LEVEL
     OF, AND 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 C02 and  CO should  be made periodically, and
whenever the level of employee complaints suggests the need.

8.c.  Given that some percentage of the population at large appears to  be  especially
sensitive or susceptible to airborne chemicals  (for instance,  it appears that perhaps 20
% is 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.

c KEEP TELEPHONES ON "LO". AND KEEP CONVERSATIONS etc., AT
REASONABLE SOUND LEVELS. TALK CONFIDENTIALLY.

• 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.

t RESPECT OTHER PERSONS' NEEDS.

FOR CONTROL OF VISUAL AND ERGONOMIC STRESSES. Take these steps:

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.

o 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

-------
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                               UEOIOMI

           JF KENNEDY FEDERAL BUILOINQ. BOSTON, MASSACHUSETTS 0220H211
             rQ ON THE ACTUAL VENTILATION (DESIGN, OPERATION, CAPACITY,
             ITANSARDS) OF THE HVAC SYSTEM, and PERCEIVED COMFORT -
EPA OCCUPIED SPACE, ONE CONGRESS STREET, BOSTON, MA



                            N.A. Beddows

                               1/15/91









WRITER.


A. ACTUAL VENTILATION

 1. .NTERIOR VAR.ABLE AIR VOLUME (VAV) UNTO ,^^^fSJ^t^SS W


Ei
UNITS.
 2 FOR EACH VAV UNIT. OUTSIDE AIR FLOW RATE AN^ RECIRCUUTINC^AIR FLOW^ ^







              M w*w  IIMITC POMPRiqES THE INTERIOR AIR SUPPLY AND AIR HEATING
 3. A TOTAL OJ^^sYSJEM  AT ANY ONE: TIME IN A WORKDAY. MOST (90%) OF THE VAV

 UNITS OPERATE SIMULTANEOUSLY.
 225.000 SQUARE FEET.

  S. US,NG CONSERVAT.VE VALUES OF RELEVANT »™S*
 DAYTIME MINIMAL VALUE °F CURRENT WTSIDEAm SUPPLY              WRITER'S

 ^^EiF^c'uR^NT^E^HK R^ES!l«SllTH« 4 CHANGES PER HOUR-

 FOR THE ENTIRE FACILITY.
                            PRINTtD ON RECYCLED PA

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 6 THE 1989 ASHREA 'VENTILATION FOR ACCEPTABLE INDOOR AIR QUALITY" STANDARD #62-
1989. AT TABLE 2.2, '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.
                                         . FIXED SUPPLY AlE.
                                          PAW
                                    OF HEATHS (PACOLLEL H£6Ttv<;)

                                                            litfhi
                     FIGURE 1. BASIC VAV CONFIGURATION.
BASED ON THE ABOVE MATTERS OF ACTUAL VENTILATION. AND WITH DUE REGARD TO OTHER
STUDIES (i.e.. carbon dioxide, carbon monoxide, formaideyde) 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 HEK3HT 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 I 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.
                                                         saws
 WINTER MO, WELD WAlTO "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
 rOURSE THERE IS NO CHILL FACTOR INVOLVED WITH INSTRUMENTATION) AND THEY ARE
 pSSfc f'Al LE^ST  THREE FEE? HIGHER  THAN FOOT LEVEL. AND SINCE ^SIGNIFICANT
 TFMPFRATLJRE GRADIENTS EVIDENTLY EXIST BETWEEN DESK TOPS AND FOOT LEVELS. AT
 LEAS * f SOME OFFICE LOC^WS THERE IS AN EVIDENT NEED TO SET SOME WALL UNIT
 CONTRA 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.

 t ELEVATORS NEED HEATING.

 • THE 10th AND 11th 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 cfro/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 DJISIGN .
                                               Norm Beddows .
                                                      1/3/91.

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REPORT OF THE MEETING OF 12/21/90.

-------
     '.        UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
      |                            REGION I
     /         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 on furniture materials and VOC-outgassing;
dust in air; target VOCs in air; lead in drinking water; the design and operating
characteristics ojthe HVAC system; ventilation-the supplying ojfresh air-and air
exchange rate in  the building; luminance; relative humidity; employee (IAQ)
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
      inuolue a stgni/icant 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.

      9  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 floors is excellent, and
      exceeds all known relevant and applicable standards

      9 There is no problem of lead in the water from the drinking fountains

      9 Problems exist re: localized heating, drafLs, 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 modern 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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      0 Report on the HVAC System and Work Place Ventilation.

      • Discuss Ventilation and Relevant Standards.

      • Mention Some Current Problems, and Opportunities.

      t 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.

       a  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  paniculate (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 paniculate.


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
paniculate. 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.

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 10th 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 10"1 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 4.4.3).

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 (C8H10. 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.

      a 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 10th and 11th 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 21s1 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.

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                                      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.

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                                       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.

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                                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  bv 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.

• There is no  problem of lead in the drinking water from the drinking fountains.

a  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.

       • 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.

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                                        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-depth  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 Ian 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.

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Appendix

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MASSACHUSETTS
          COUNCIL, INC.
                  oanu«am
  Occupational Asthma Alert  /
  People who develop  asthma as
  adults and  have more symptoms
  during  the  work  week than on
  weekends may  be suffering from
  occupational asthma.
  The  disease  b 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 (TOI).
   Asthma symptoms include  wheez-
   ing, tightness  in the chest and
   difficulty  breathing. When the dis-
   ease  is   diagnosed  early  and
   patients  avoid the  irritating  sub-
   stance, they are able to  recover
   complete  lung   function.   Longer
   exposure  may  result  in more
   severe hearth  problems such  as
    pneumonia.
    Employers are advised to be aware
    of asthma symptoms among their
    workers and improve working con-
    ditions when necessary.
_—-•' 'nht "" VP™ ' •?*£
office  lighting   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. Hatf the offices were equip-
 ped with conventional  overhead
 fluorescent lighting  or downlight-
 hg. The  other  hart had indirect
 fluorescent  lighting  that directs
 light  toward  the ceiling,   called
 uplighting.
  Nearly a lounh  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  only  1  percent  of  workers in
  offices  with  indirect lighting  In
  addition, loss of productive work
  time  caused  by tiredness or leth-
   argy  was tour times greater In the
   group with conventional computer
   area down lighting.
   A lollow-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.

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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^ wnb
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 pub ie affairs. All of Ult
*< nnn Pacific Bell employees who use VDTs are to receive economic training

•bVFole>eisdaiQfi1h9a?onSeoffice"in  Concord. Calif., which employs  101 operators
had already been retrofitted prior to the announcement that the firm's.program
was being «i»rr»H-"P- Operators in the retrofitted office can «d.u« the height
nf  their  chairs and  deiks so they can sit or stand while
                         so they can ,., or stan   wie wor
              straight-wrist position. Walls in the working area and
               have been coated with fabric to cm flown on noise ie
 fit workstations ns^'c pccn coaicu_^»mi iawnv *^ »*»* ^.w... —.. .	—_^_j_
 ™ According to roley. a survey is now under way to determine wU.n depart.
 ments should be considered first for retrofitting and training. The resuUs should
 be in and the retrofitting and training started by the first quarter of 1991. she

 ""rife  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 Superiors-
   The San Francisco Chamber of Commerce is draftmg guidelines for its own
 set of voluntary VDT-use standards as a proposed alternate to the ordinance
 under consideration. The chamber's voluntary  guidelmes «e 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 Rector  said.
   However. Joan Moore, secretary for the Communicat.ons 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 union's  Northern
  California and Nevada Council.                                      "•

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                                                                   •uurnNS.17740
HERE'S
       fsbw
Modular Sound-Absorptive
Panels Foil Powerhouse
          -	    -  . 1. •  .  - •
Noise Problem

Ceiling-hung Noise-Foil III panels are fully perforated (or maximum sound absorption and are available in pre
finished materials—steel and aluminum. Acoustical performance of these panels (as well as the others in the
Noise-Foil family) were confirmed by testing In facilities of the IAC Aero-Acoustic Laboratory.
Amid the scenic Blue Ridge Mountains in northeast
Georgia, not far irom the Tennessee state line. Carters
Lake glistens in the sunlight. The sparkling waterbody
with 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-capacity hydrogenerators.
and discharges into a  reregulation reservoir below the
           powerhouse. Water is pumped back into the ma!n lake
           when demand for power is low, usually during the nigh;
           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 o' the
           reregulation pool to vary as much as 10 feet (3m) wahm a
           6-hour period, to rise up to 22 (eet (67m) from Monday to
           Friday, and to drop as much as 22 feet (67m! over a
           weekend  Pump-back results m weekend fluctuations in
           Carters Lake of up to 4  feet (1 2m) The powerhouse-
           engineering staff credits reuse of the water with sucstan-
           tially increasing capacity of 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-in
(1981mm) long containing verminproo' 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 •» Men from the top of the
dam »it e.
  Complementing the ceiling installation are 1,250 wall
 mounted Noise-Foil II pre-finished. white, aluminum 2-
 inch-thick 61mm) 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  dm 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 c^:
 noise levels through sound absorption Each Noise-Fo'
 System is characterized by a Noise Reduction Coeff ider,:
 (NRC) of O.SO. meaning that 90% of the sound energv
 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 best 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 pomts do not exceed the
 OSHA exposure limit of 85 dBA dunng the normal eig1-.-
 hour working day The modular acoustical treatment 
-------
Study:  Environmental  illness  a  mental  disorder
  CHICAGO (AP) - People who think the mo
dem. chemical-saturated environment Is mak-
ing them skk may simply be suffering mrnl;i1
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 Ret sick after
exposure to everyday items like processed foods,
newsprint, gasoline and clothing.
  Relief in the condition, also  called multiple-
chemical sensitivity, varies In the medJcal com-
munity, with some doctors  doubting Its exis-
tence altogether.
  "It's my  belief that  people diagnosed as hav-
ing environmental illnesses  in most cases do
have something wrong: a  garden variety emo-
tional disorder." said Dr. Donald W. Black, who
headed  a  study at the university's medical
school  published today In the Journal of the
American Medicine Association.
  Beginning In June 1968, Black's research team
studied 23 people diagnosed as suffering from
environmental illnesses. Fifteen, or 65 percent,
showed symptoms of past or  present mental
disorders like depression, anxiety or obsessive
oompusive behavior, the study said.
  In a 4&member control group of henlthy )»*>•
pie. 1.1. or 28 percent, shown! symptoms of
mcnt.il disorders, the study said.
  The research was naively poiicf-ived ami ptnir-
ly sol up. said Dr. l>eo Calluud. .1 Now York
internist wlio trmts pi-ople dkitfiosed with en-
vironmental illness.
  CnmiKiring the menial conditions of environ-
mental illness pntients against healthy pii^le.
rather than (he mental states of pmpk: sufli-ring
medically accepted chronic ailments, was a criti-
cal flaw. Galland said.
  "Being sick tends to make people depressed."
he said. "I don't think there's ever own a study
done comparing healthy community mcmln-rs
with a group of patients wlio suffer from a
chronic illness that hasn't found more psycho-
pathology among the patient group."
  Comparing DM* mental conditions of environ-
mental illness subjects with those of pi-npli; with
asthma,  for example, might have proved  hln
claim, he said.
  A group of medical practitioners railed rllnl-
cnl ecologists believe that conimnn clxinlcnls In
the air and physical cnvironn«-nt can ti|is<4 the
hmly's Immune system, lending to imusiii. respi-
ratory |in»til«ins. lieadarlies mid citlH-r ;iilnwiits.
(In- sltifly said.
  Some intlvnts have reported hyperscnslMvlty
In nigs, paneling, deodorant, bedding and other
everyday midstiinces.  Some sulferers have
sought out "toxic free environments" by giving
up tlwlr urban jobs and moving to the desert or
mountains.
  A luck of an acceptable definition for environ-
menial illness, as well as a lack of an established
lest for the disease, has led much of the medical
community to dismiss the concept, the research-
ers wrote.
  Another critic saM even If the Iowa team's
conclusions  were valid,  luxiin In the environ-
ment couM have contributed  to the  mental
disorders,
  "I dim't think any pgychlaufal  can teO me
what causes mental Illnesses like depression
and neurosis," said Dr. Max Costa, professor of
environmental medicine and pharmacology at
New York University MedJcal School.

  Mark's research team also crlUcted the use
of tww ptnvon treatments on people diagnosed
with imvlrunmontal Illness. Those treatments
Indude stjrctal dirts, wearing filter masks  and
iislnc doiM:lns or enemas of spring water, coffee

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NOTICE OF UPDATE MEETING OF 1/31/91.

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  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
gaseous  evolutions;  measured  lead in (fountain)  drinking water,
stardards, and sampling plan; ventilation system type, and outside
air supply and 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.

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REPORT OF UPDATE MEETING OF 1/31/91.

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          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 10'h and the 11* 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.

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      (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 ppb. 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  11th 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-survey. 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 11"1 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.

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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.

      •     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 uq/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).

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      •     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 microqram 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  particulate  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-Going 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 11th floor).

 The CO2 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.

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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.

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VIEW-GRAPHS FOR THE UPDATE MEETING OF 1/31/91.

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UPDATE -
  INDOOR AIR QUALITY



  EPA OCCUPIED SPACES,



  ONE CONGRESS STREET
          N.A. Beddows. 1/29/91

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    -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

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- 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)

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      - 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

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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

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      -CARBON MONOXIDE-
FOUND (TOM SPITTLER):
       1.0 PPM (0.9) IN OFFICES



       5 PPM IN SMOKING ROOM,

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CARBON MONOXIDE STANDARDS:

 • OSHA - INDUSTRIAL STD
       = 50 PPM, TWA.

 • EPA / NAAQS - 8HRS: 9 PPM

 • WRITER'S "STD" -

    OFFICES. NON SMOKING: 2 PPM.

    SMOKINGROOM: <10 PPM (PEAK),

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       -CARBON DIOXIDE-
FOUND (TOM SPITTLER)

  •  360 PPM
STANDARDS:
      OSHA - INDUSTRIAL STD.
           =  5000 PPM !
          (ASPHIXIATION RISK)

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  HARBON DIOXIDE STANDARDS:
INDUSTRIAL HYGIENE CONSENSUS
(IAQ) < 800 PPM, "ACCEPTABLE.

ABOVE 1000 PPM -- PROBLEMS OF
    AIR SUPPLY / OVERCROWDING

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       -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

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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.

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NOTE.
  50 PPB IS THE ODOR LIMIT OF
  DETECTION FOR MOST OF US.

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      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

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   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.

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    - VOCs BY PORTABLE GC/PID. -
FOUND IN JANUARY (SPITTLER& KAHN)

  • BENZENE. TOLUENE. TCE.

  •<5 PPB LEVEL FOR EACH

    NO CHEMICAL ODORS
    IN WORK PLACE

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      STANDARDS for the
         GARDEN VARIETY VOCs:
WASHINGTON STATE (1989) tVOC STD,


KNOWNVOCs; 500 UG/CUBIC METER*
  FOR SURROGATE: o^nyp, XYLENE.
   THIS = 115 PARTS PER BILLION.

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     - 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

    VEGETABLE 10 MICRON "ROUNDS" ?

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-CONFIRMATION. 12/28/90 FINDINGS-
   CONFIRMED INDEPENDENTLY,
       ON 1/8/91.

   ALSO, MINOR AMOUNT OF POLLEN &
   STARCH FOUND
             H. DAVIS, EPA LEX. LAB.

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-LEAD IN DRINKING WATER (FOUNTAINS)-

      NOVEMBER, 1990 TESTS.
FOUND (EPA LAB TESTS):

"BELOW 6 MinRQGRAMS/UTER."

n W. STANDARDS:

NOW  = 50 MICROGRAMS/LITER
SOON  =15
ti

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-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 f'89) = 15-20 CFM/PER.

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 SCHEMATIC OF A TYPICAL VAV - UNIT
     (168 IN THE SYSTEM)
         Film
           SUPPLY
WHITS CW
   &
QUffPHT

-------
 -CURRENT PROBLEM AREAS-
TEMPERATURE DISTRIBUTION,
HORIZONTAL & VERTICAL

DIRECT LIGHTING - TOO LITTLE &
TOO MUCH

INDIRECT LIGHTING

NOISE IN SOME AREAS

VERY DRY AIR PERIODICALLY.

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NOTE.
   TEMPERATURE BALANCE IS
   NEEDED IN SOME LOCATIONS
   AT THIS TIME.

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     - IN SUMMATION -
NO FORMALDEHYDE GAS OVER-
EXPOSURES.
NO CO, CO2, VOCs - PROBLEMS.
NO DUST (FIBERGLASS)  PROBLEMS.
NO LEAD IN DRINKING WATER
VENTILATION IS EXCELLENT.

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PROBLEMS ARE LOCALIZED re:

0 DIRECT & INDIRECT LIGHTING

• TEMPERATURE CONTROL

• NOISE and SPEECH PRIVACY

AIR DRYNESS IS A GENERAL,
Winter - period PROBLEM

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REPORTED/REFERRED COMPLAINTS,
FROM FIRST DAY TO DATE.
  <1% OF ALL EPA EMPLOYEES IN
  BUILDING.

  NOT "OCCUPATIONAL ILLNESS",
  under OSHA.

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LETTER OF REQUEST: QUESTIONNAIRES.

      1.  Medical Questionnaire.
      2.  Facilities Questionnaire.

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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                                         REGION I

                    J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211
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.
          Bill Chenoweth.
          Dr. A. O'Campo.
          Laurel  Seneca.
                                     PRINTED ON RECYCLED PAPER

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   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(0.1)1.10.91.

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                                TENTH FLOOR

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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 (0.2)1.10.91

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LETTER TO THE OCCUPATIONAL PHYSICIAN.

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f  A
UK
            UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
  \
  |                                 REGION I
  r           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.
         Julius Jimeno. Patricia Meaney. William Chenoweth.
                                     PRINTED ON RECYCLED PAPER

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CURRENT INFORMATION FROM
   THE QUESTIONNAIRES.

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                      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 (EPAVEPA-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
oo
16
06
00
04
06
01
02
00
61.

11TH
03
02
00
07
00
00
02
00
01
01
00
16
„
fFLOOR)
21
Ifl

23







COMPLAINTS

AFFECTED AREAfSl/DIVISIONfS*
Corner Offices,
10 and 11 floors

Central Aisle (10)

ORC office/Cafetaria

General
11 floor, WMD.


RECEIVED. AS OF 2/25/91 :












61.

                    Please  See Attachment re: typical comments.
           MAJOR AREAS WITH PROBLEMS, AS IDENTIFIED BY RESPONDENTS.
             TENTH FLOOR
                      ABEAS    .
                OCCUPIED BY OTHER AGENCIES..
                      SPACE OCCUPIED BY OTHER AGENCIES.
•Tf.LjS*  t2?

WATER MGMT. DIV.

            _,.-\>	TOO COLO

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               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.

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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.

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                          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, L.S.
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.

* If 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.

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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 a'r 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 personal
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 industrial 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.

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                    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 um 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.

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                          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.).

-------
     SYSTEMS,
     INC.
                                 DECEMBER £6.  1990
U. S.  EPA
JFK  FEDERAL. BLDG
BOSTON,  MA   ©££
ATTENTION:  NORMAN &EDDOWS

ENCLOSED PLEASE  FIN;) M COPY OF  THE RESULTS  FRO* THE
FORMALDEHYDE. BADGES YOU SUBMITTED FOf? ANALYSIS.
IF YOU HAVZ ANV  FURTHER QUESTIONS REGARDING  THESE RESULTS.
^•!_ElA£i5. CONTACT GflD.

                                 &EST REGARDS.
                                 LINDA COYNE
                                 GMD LAB & RESEARCH MANAGER
ENCLOSURES:  FORMALDEHYDE ANALYSIS REPORTS
RKM
    Old Roue 519  Hendersonville. PA 15339 USA (412) 746-3600 FAX: (412) 746-1359
                      A RACHARACH Affiliate

-------
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-------
            IHDOOR VOC AIR SCREEMBC SURVEY RESULTS

                  EPA REGIOK  I OFFICE BOILDIBO

          ORE CORGRESS STREET - BOSTON, MASSACHUSETTS



                          JANUARY  1991
A description of the sampling locations used in this survey are
described below.
FloprlO
    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 was collected
    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    .  .    .
     approximately 5  feet  above floor level  at  1253 hours  adjacent
     to the reception desk.

-------
                  rtoo* 10 - run. OOOOB'B cm a
                                                                                      neat 11 - L.I.
 Compound
 Detection  Background   leaple t 21
   Limit*
                         (KB I/t)
                                                                 Compound
Boniene 0.2
Tricbloroetbrlene . 0.2
Toluene 0.6
TatraebloroatbTlene O.I
Chlorobentene 2
•tbrlbaniana 1
•, p Erlene 1
o-l7lene 4
1
HD
l.S
HD
HD
HD
HC
HD
1.2
HD
4.2
HD
HD
HD
HD
HD
 •D • nondetecteble   Level* were not detected above
      BMtbed'a detection Unit.

                       FLOO* 10 - B.C. BJtll
Compound
Detection  Background  Senple I  2J
  Limits

Bentene
Tricbleroethjleoe
Toluene
Tetrecbloroetbrlenc
Cblorobentene
Btbylbeniene
n, t Ijlaae
o-Xrlece
(pub v/vl
0.2
0.2
O.C
o.e
:
i
i
4
(cob V/Y) 	
1
n
1.5
ID '
RD
• D
•D
n
(cob »/»)
1.3
R>
3.t
•D
»D
ICC
RD
RD
 Compound
    FLOOR 10 - L.8.  IMA


 Detection  Bickground  S»mp!t I 18
    Limit*
                          (cab v/v>
Benteoe 0.2
Tricbloroethjlene 0.2
Toluene O.t
Tetrtcbloroethrlene 0.8
Cblorobeniene 2
Cthrlbentene 1
«, p Iy 1 ene 1
o-Xjltnt «
1
RD
1.5
RD
RD
RD
RD
RD
i.:
RC
J.6
RD
RC
RD
RC
RD
Detection  Background  Beaple t t
  Limit*  ,
Bentene
Tricbloroetbrleae
Toluene
Tetracbloroetbflene
Cblorobeniene
Ithjlbeo*en*
•. a Ijlen*
o-Iyl en*
0.2
0.2
O.f
O.I
2
1
1
4
1
•D
l.S
•D
n
n
n
•D
i
•D
4
•D
BT>
n
•D
•»
                                             •D • aondetecttble   teveli were net detected above
                                                  awtbod't detection limit.
                                                                   Compound
                                                                         11 - LIBUKT
 Detection  Background  Baaple I 1«
   Liedte
Bentene
Tricbloroetbjlene
Toluene
Tetrachloroetbrlene
Cblorobentene
Ctbjlbentene
•, p Xylane
o-Xylene
0.2
0.2
O.t
O.I
2
1
1
4
1
•D
1.5
RD
• D
•D
RD
RD
1.2
RT>
1
1.4
RD
HD
RD
RC
                                                                   Compound
                                                                                              11  -  l.M.  AREA
 Detection  Background   Sample  I  10
   Limit*
                          (cob v/v)
Bentent 0.2
Tricbloroethjlene O.J
Toluene 0.6
T«tr»chloro«thjl»ne 0.6
Cblorobeniene 2
Ethrlbenien* 1
m, p Xrltnt 1
o-Xyleoe *
1
RD
l.S
BD
RD
HD
RD
RD
l.S
RD
4
KD
RD
KD
KC
DC
                                                                                       FLOOR 11 • RECEPT10B DESK
   Compound
   Detection   Background   Sample I 1?
     Liffuti
                           fppb v/v)
                                                                   Compound
tentcce 0.2
Tricbloroetbjleo* 0.2
Tolu*n< 0.6
Tetr*ch!oroethrlen« 0.8
Chlorobeniene 2
Etbjlbeniene 1
n. p Xylene 1
o-Xylene 4
1
RD
l.S
RD
«D
RD
RD
•D
l.S
1.2
1.6
RD
RD
RD
RD
RC
  Dttection  Background  E«r,r'. • I IS
    LlTT.lt>
  (t.Eb V/V)  (CDb V/0	(PP^ V/Y)
                                                                   Benienc                0.)         1

                                                                   Trichloroetbylene      O.J         RD

                                                                   Toluene                0.6        l.S

                                                                   Tetrechloroethylene    0.6         RD

                                                                   Chlorober.iene           5          BD

                                                                   Ethylbentene            1          *D

                                                                   n, p  Xjlene            1          "D

                                                                   o-Xjlene                «          "D
                                                                                                                  1.2
                                                                                               RD

                                                                                               RD

                                                                                               RD

                                                                                               RC

                                                                                               HD
                        0.8.  EMV1ROXMZKTAL  FROTECT10R ACERCT. XE010R I, EHV1ROHMEHTAL SERVICES DIV1S10R

-------
                     riOOIl 10 - BMOKIBC ROOM
Compound            Detection  Background  Simple I  29
                      Limit*
                    (ppb v/vl  (ppb vtvt	(ppb v/vl
Benieoe
Tricbloroetbylene
Toluene
Tetr*chloro«tb;lene
Cblorobentene
Ethyl beniene
m. p lylene
o-Irlen*
0.2
0.2
0.6
o.e
2
1
1
4
1
HO
1.5
HD
HD
HD
HD
•0
30
RD
(4
RD
•D
RD
7
S
ND • nondetectible   Level* were not detected above
     netbod'i detection limit.

-------
              FOOTCANDLE READINGS
ORC  10
*

u










w
w






u
u
w
w
u























u
u


u
w/s

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
PRI
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
3O
46
42
65
20
14
34
46
30
22
46
4O
30
30
30
30
40
48
44
40
60
60
60
6O
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
60
60
50
*
50
                                      PRIVATE OFFICES AT DESK LEVEL
                                      OFFICE*    f/c
A106
A107
A108
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
* SEQ CHGE
A173
65
34
70
45
**
**
80
60
24 ***
80
30
60
55
55
35 ***
70
50
NA
**
80
80
70
44
60
50
xx
90
70
42
80
65
40
60
70
xx
55
60
40
70
36
NA
60
NA
xx
XX
NA
XX
XX
50
XX
NA
40

na

-------
12-Feb-91
Page 1
              FOOTCANOLE 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 10
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
40
40
42
38
48
34
12
60
36
46
32

48
*
*
*
50
50
36
44
20

*
*
*
*
50
50
A174
A175
W A176
U A177
W A178
U A179
A180
A181
A182A
A182B
A182C
A183
A157
A158
A159
A16O
A161
A162
A163A
A164
A165
A166
A167
W A168A
U A168B
U A168C
W A169
UJ A170
U A171
W 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
7O
46
60
NA
**
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                                                        Page 2


              FOOTCANDLE READINGS
                                      A318        20
                                      A319        20
                                      A320        NA
                                      A321        18
                                      A322        20
                                      *SEQ CHG
                                    U A328        55
                                    U A329        60
                                      A332       LAB
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

-------
12-Feb-91                                                        Page






              FOOTCANDLE READINGS
152
153
154
U 155
W 156
157
158
U 159
U 160
161
162
U 163
14 164
165
166
W 167
W 168
169
170
U 171
W 172
173
174
U 175
U 176
PMD 10
ft 87
A 88
A 89
A 90
A 91
*SEQ CHG
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
192
193
194
195
196
197
198
W 199
U 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

26
20
30
34
40
30
44
30
60
38
50
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
W A325
A326
*SEO CHG
U A334
W A335
W A336
W 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
5O
46

-------
12-Feb-91                                                        Page
              FOOTCANDLE READINGS
                                      A359        55
                                      A360        NA
                                      A361        NA
                                      A362        40
                                      A363        NA
                                      A364        40
W 201
W 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
Ul 227
W 228
U 229
W 230
231
232
W 233
W 234
235
236
W 237
U 238
U 239
U 240
241
242
W 243
W 244
W 245
246
247
U 248
W 249
W 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
60
50
16
48
48

-------
12-Feb-91                                                        Page 5






              FOOTCANDLE READINGS
259
260
261
262
263
264
W 265
Ul 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
W 287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
315
316
50
48
30
60
.30
42
26
40
36
36
30
14









32
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12-Feb-91                                                        Page 6






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12-Feb-91                                                        Page  7


              FOOTCANDLE READINGS
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12-Feb-91                                                        Page  8






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12-Feb-91                                                       page 9






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12-Feb-91
                                                                 Page 1C
              FOOTCANDLE READINGS
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     "A"  PRECEEDING U/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

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       POST  SCRIPT:  Summary  of Conclusions  and Recommendations.
       3/5/91 Report For Distribution  To All Employees.
           UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                   REGION I
^           J.F. KENNEDY FEDERAL BUILDING, BOSTON, MASSACHUSETTS 02203-2211


  DATE: 3/5/91.
  TO: DISTRIBUTION.
  FROM: N.A. BEDDOWS.

  SUBJECT-  CONCLUSIONS AND  RECOMMENDATIONS  re: EPA REGION  1
              INDOOR  AIR  QUALITY  STUDY,  ONE  CONGRESS  STREET &
              PROVISION OF A CONSOLIDATED REPORT.

  It is appropriate at  this time to provide a  consolidated  report, and to present my
  conclusions and  recommendations re: the  above captioned  study. The report (attached
  or otherwise available from the library) will serve as a repository of available data, and
  it may be useful as a guideline for others who may need to  conduct a similar evaluation
  elsewhere.

  We have characterized this  facility using a series of chemical and physical tests, and an
  appraisal of a representative number of responses  to  a  facilities  questionnaire (61
  "affirmative complaints",  and 3 "no complaint"  responses , with 700 questionnaires having
  been broadly distributed throughout the two EPA-floors), as of 2/25/91.

  We have identified opportunities for improving the quality of some work  places by
  implementing administrative and/or engineered  controls.

  A medical  questionnaire was distributed to all our employees in February. The results
  of  a planned appraisal by the occupational physician (Dr.  O'Campo) are not currently
  available. However,  this is not  a limitation on classifying the facility or identifying
  opportunities for improvement, because the medical questionnaire differs from the facility
   questionnaire only in that it additionally requires the reporting of symptoms -- which later
   might be related to a current or past exposure inside or outside the  work place.

   CONCLUSIONS.

   A summary of my conclusions to date is offered below.

   With Respect To Contaminants:

   Carbon  monoxide, formaldehyde, benzene, toluene, and trichloroethylene exist in  the
   indoor air  at One Congress at mere trace concentrations.  The  concentrations of target
   VOC-contaminants measured  indoors were similar to the  concentrations found in  the
   street air immediately outside the building.  The reported  sum total  of  the ubiquitous,
   target volatile organic compounds indoors  was very low - in the tens of parts per billion
   range.  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  at low concentrations  which were well below the relevant  (corrective) action
   level (50 ppb). We found the (geometric) mean concentration of formaldehyde indoors
   in  December was 14  ppb (GSD = 1.3). These data were  obtained  using the '--"
   available chemistry and a battery of eleven tests, including one control.
                               PRINTED ON RECYCLED PAPER

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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. This  (25'x20'xlO') room has since been force-ventilated at a high rate
(calculated design rate  3000  cfm). It is now  fully acceptable to  the smokers, based on
their comments to me.

With Respect To Ventilation/Cleanliness:

I believe  that the fresh air  supply  to each floor  is excellent.  Carbon dioxide levels
throughout the building were  less than  400 parts per million. This fact together with the
results of  the quantitative fresh air supply  checks on the HVAC system which  I made in
December support this judgment. Thermal  imbalance and point (supplied  air) distribution
problems  exist in certain sectors. There is evidently  a ventilation  equipment/duct set-up
(stuffy  air) problem in the Water Division  (central  area). This is  being worked  on,
according  to the building owner.

Dust level is generally very low. Also, what little amount of airborne dust was found in
two center-area  samples was seen microscopically  to  be free of inorganic fibers and
silica. On  the eleventh floor,  airborne pollen  was found, together with a very  light level
of paper and organic fibers somewhat larger than respirable size.  Finding some airborne
pollen  indoors is to be expected, with such a volume of sample and  PL-microscopic
(x400)  examination. The pollen count was negligible.  This is based on  the (more than
adequate) sample volumes collected and the fields counted in the PLM examinations, as
described  in the 1/8/91 report.

With Respect To Comfort/Ergonomic  Factors:

Sub-standard office direct lighting and excessive glare exist in some locations. Also, noise
generation (from some  people/printers)  and  transmission,   lack  of  privacy,  and
temperature swings are evident and reported problems in some (now identified) locations.
Engineered solutions  exist  for some of these problems,  and we  can  help ourselves in
many cases. The problems are being worked on by the EPA Facilities  Branch  personnel
and the building management.

Low level  relative humidity indoors is an evident winter-time problem.  Paradoxically, the
better  is the ventilation, the worse might be  this periodic problem.  It is not  amenable
to an engineered control. However, local  humidification of enclosed offices may help.

A microbiologic  evaluation  was not undertaken in our study. In my judgment,  there was
and is  no indication from  any EPA experience that  this ought  to be done.  Also,  the
Department of  Labor  did conduct  such  an examination,  in December  1990, in an
enclosed office on the eleventh floor. This was made 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 me by the DOL Regional Administrator. The report
concludes  that there is  no  microbiological contamination to be  concerned about.  The
remainder of this evaluation  was  consistent with our findings.

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With Respect To Complaints.

The sum of formal complaints involving both claimed or reported occupational exposures
is  low.  The responses to the  occupational medical questionnaire-survey,  which might
relate to an occupational office exposure, is being evaluated by the PHS physician, who
will report separately on this matter.

SUMMARY CONCLUSIONS.

1.     I believe that there are no current recognizable health hazards in the work places,
      but  localized, comfort and productivity-type problems exist. This  is based on the
      quantitative studies which we have made to date,

2.     I think that  some (a small  number) of our employees  either are extraordinarily
      sensitive to trace levels of a host  of contaminants (haptens), or believe that they
      are chemically sensitive to trace concentrations of substances present either in their
      work places, their houses, or the  environment.
Notes:
      (a) The issue of chemical sensitivity is controversial.
      (b) A claimed  effect without supporting  objective scientific evidence is  not proof
          that an occupational health hazard exists.

RECOMMENDATIONS.

In regard to these points, the following  recommendations are offered:

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. Any past complaint asserting any serious adverse effect casually related to the
work  place ought to  be regarded  as  unfounded.  We do know a good  deal about  the
facility and its furbishing, and the  extensive period of ventilation  (airing  out) which was
employed  prior   to occupancy.   A 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  brought to  our attention  by the  PHS  physician, based on  the medical
questionnaire-survey,  ought  to be addressed  with   a  competent   industrial  hygiene
assessment, and  a formal response made by the  assessor.

On Corrective Action. & Specific  Complaints.

Issues of lighting, noise,  temperature and drafts ought  to be systematically corrected.
Ongoing facilities-programs appear to be in place or in  development 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 bacteriostat
in the water. Also, one would need  to make sure that  the circuit was not overloaded.

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 remote, in my judgment,  that a meaningful outcome would ensue
from the analyses of volatile  and semi-volatile organic contaminants which  might be
present only at trace (fractional or low parts per billion) concentrations.

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. Ed Conley
facilitated the chemical assessments being made. 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. Ms. Janis Carreiro, US. DOL made available the results of the Department
of Labor air quality evaluation. Mrs.  Barbara White  and  Ms. Pat Meaney helped  in
preparing for and arranging the employee-meetings and the surveys. Mr. Bill Chenoweth
and  Ms.  Laurel  Seneca  provided valuable comments  on conducting  the  surveys. Dr.
Alvero O'Campo  kindly  agreed to confidentially appraise the  returned medical  quest-
ionnaires. I gratefully acknowledge the truly excellent cooperation afforded me by these
colleagues and others too numerous to name who  participated in the meetings .
DISTRIBUTION:

With Report Attached (For Redistribution, As Appropriate):
EPA Region 1 Senior Staff.
EPA HQ. OHSS Director and Industrial Hygiene Staff.
Branch Chiefs - Human Resource & Facilities Branches.
Technical Contributors.
Jeffrey Davidson.
Alvero O'Campo.
Barbara White.
Janis Carreiro, Regional Administrator, U.S. DOL. Region 1.
U.S. EPA Library One Congress Street.
U.S. EPA Lexington Laboratory Library.

Sans Report:
EPA Branch and Section Chiefs, One Congress Street.

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