Indoor Air Quality Management Plan
for
US EPA Headquarters. Waterside Mall
Version of: April 13, 1990
Concurrence:
I approve of this Plan in terms of both its concept and its
specific contents. Further, I recommend it on the part of the
organization I represent to Mr. Charles L. Grizzle, Assistant
Administrator, Office of Administration and Resources Management,
for review and action.
date
Julius Jimeno, Chairman,
Labor/Management Health and Safety
Committee and
Director, Environmental Health and
EPA
for" ^/ // /Qatfe
Lores Murray, Membe]
Labor/Management Health and Safety
Committee and
President,
American Federation
of Government Employees,
Local #3331
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TABLE OF CONTENTS
ACKNOWLEDGEMENTS 2
A NOTE ON THE SCOPE AND DEVELOPMENT OF THIS PLAN 3
PART 1
BACKGROUND INFORMATION
SICK 'BUILDING" SYNDROME AND BUILDING RELATED ILLNESS 4
PART 2
INDOOR AIR QUALITY RISK MANAGEMENT AT EPA HEADQUARTERS
RISK IDENTIFICATION AND ASSESSMENT. . 10
RISK CONTROL 12
RISK COMMUNICATION 14
RISK FINANCING 15
PART 3
THE GOALS OF THIS PLAN
SHORT-TERM 16
MID-RANGE 18
LONG-TERM . . 19
PART 4
INDOOR AIR QUALITY IMPROVEMENT MEASURES
FACTUAL BASIS FOR SOME SPECIFIC IMPROVEMENT MEASURES 20
OTHER PREMISES FOR IMPROVEMENT MEASURES 25
SHORT-TERM IMPROVEMENT MEASURES 26
MID-RANGE AND LONG-TERM IMPROVEMENT MEASURES 31
PART 5
BIBLIOGRAPHY 36
APPENDICES beginning at. . .37
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ACKNOWLEDGEMENTS
This version of the Plan, dated April 13, 1990,
incorporates the most recent changes made by management in
response to union input. The first version of this Plan that was
jointly approved in concept and principle by both management and
labor was developed by the Indoor Air Quality Management Plan
Subcommittee, in January 1990, under the auspices of the Labor/
Management Health and Safety Committee, US EPA Headquarters.
The Subcommittee was composed of four regular voting members, two
of whom represented management and two others who represented the
certified unions - one from the AFGE and the other from the NFFE.
In addition, an ex-officio, non-voting member was appointed to
serve in an advisory capacity. The original official members of
the Subcommittee, and the organizations they represented, were:
Bob Axelrad, ex-officio representative
Indoor Air Division,
Office of Air and Radiation
Kirby Biggs, union representative
American Federation of Government Employees
Myra Cypser, union representative
National Federation of Federal Employees
Stan Fredericks, Chairman and management
representative
Facilities Management and Services Division,
Office of Administration
David Scott Smith, management representative
Environmental Health and Safety Division,
Office of Administration
Special contributions in Part 1 of this Plan, entitled
"Background Information," were made by:
Bob Axelrad
Office of Air and Radiation
Kevin Teichman
Office of Research and Development
David Weitzman
Office of Solid Waste and Emergency Response
Additionally, material is quoted from the Guidelines for
the Assessment of Bioaerosols in the Indoor Environment.
published by the American Conference of Governmental Industrial
Hygienists in November, 1989.
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A NOTE ON THE SCOPE AND DEVELOPMENT OF THIS PLAN
Although this Plan references the EPA's facilities at the
Waterside.Mall building complex, there is no intent to imply the
exclusion of other EPA facilities located in the Fairchild
building or at Crystal City. The Agency intends to ensure a high
level of indoor air quality for its employees at those locations,
too. Modification of'appropriate elements of this Plan to
accomodate the unique needs of EPA occupied areas of its other
Headquarters facilities shall be made as required. This Plan is
considered a "living document," and thus modifications may be~
made to it from time-to-time as significant additional
information about Indoor Air Quality matters becomes available.
The direct participation of the unions in the important and
continuing process of revising this Plan is considered to be
essential. However, in late March 1990, the NFFE's leadership
announced its withdrawal from participation on the parent
Labor/Management Health and Safety Committee. Their action ended
NFFE's participation on the parent Committee and its
Subcommittees at that time. However, this Plan shall continue to
evolve, as intended, from its first version that was initially
jointly developed and approved in concept and principle by
management and representatives of both unions in January 1990.
Both management and the AFGE union continue to maintain their
commitment to work together in a spirit of close cooperation to
further develop and oversee the implementation of this Plan.
Such efforts will further enhance the health, safety, and
wellness, and sense of well-being of all EPA Headquarters
employees.
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PART 1
BACKGROUND INFORMATION
SICK BUILDING SYNDROME AND BUILDING-RELATED ILLNESS
A new term - "sick building" - has come into use in recent
years. The term characterizes a building in which a substantial
percentage of its occupants complain of health and comfort
problems that can be related to working or being in the building.
Some problems suffered by occupants that are associated with sick
buildings have been termed "sick building syndrome" (SBS) and
"building related illness" (BRI). (These terms generally apply
to problems related to indoor air pollution; they are not used to
characterize buildings where complaints stem solely from
inadequate temperature or humidity control.)
Some experts consider a building to be sick whenever about
20% or more of its occupants complain of multiple symptoms that
are always or often expressed shortly after they enter the
building, and which most often resolve shortly after they leave
the building. Examples of such symptoms include: headache;
stuffy nose or sinus congestion; dry or itching skin; tearing
and/or burning sensation in eyes; dry, irritated throat; unusual
fatigue or tiredness; sleepiness or drowsiness; dizziness and/or
nausea; sensitivity to odors. From a medical perspective, other
abnormal physical signs and/or positive laboratory tests are not
associated with individuals experiencing SBS, who complain of
these symptoms.
A World Health Organization committee estimates that the
occupants of up to 30 percent of new and remodeled buildings may
have such problems. In fact, almost every building may at some
time experience indoor air-quality (IAQ) problems. Frequently,
the problems result from the building being used, operated, or
maintained in ways unforeseen by those who originally designed
it, or from poor judgment in the building design itself.
A building is said to manifest SBS when;
• A substantial number of building occupants complain of
multiple symptoms associated with acute discomfort,
which occur shortly after entering the building.
• The cause of the symptoms is not known.
• Most of the complainants report relief shortly after
leaving the building.
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Building-related illness (BRI) is?less common, but often
more serious than SBS. Building-related illnesses can be
clinically diagnosed and they are accompanied by abnormal medical
findings. These include abnormal physical signs and symptoms,
and abnormal laboratory test results. Examples of building-
related illnesses include: infections, such as "Legionnaire's
Disease," toxic syndromes associated with exposure to chemical or
physical agents, and hypersensitivity diseases (including
hypersensitivity pneumonitis, "humidifier fever," asthma, and
allergic rhinitis).
When occupant exposure to indoor air contaminants results in
cases of clinically defined illness, disease, or infirmity, the
building is said to manifest building-related illness, which is
characterized by;
• Complaints of symptoms such as cough; chest tightness;
fever; chills, and muscle aches which can be associated
with illness.
• The cause or causes of the symptoms are believed to be
exposure to indoor pollutants.
• Complainants may require prolonged recovery times after
leaving the building.
It is important to note that it is normal for some
percentage of a building's occupants to experience one or more of
such symptoms, and that occupant complaints may also result from
an illness contracted outside the building/ acute sensitivity of
certain individuals (such as allergy), job-related stress or
dissatisfaction, or other psychosocial factors. Nevertheless,
studies have shown that such symptoms may be caused or
exacerbated by indoor air contamination.
Indoor air problems that have been cited in the literature
as causes of, or contributing factors to, sick buildings include:
• inadequate ventilation;
• pollutants emitted inside the building;
• contamination from outside sources;
• biological contamination.
These causes are thought to act in combination, and often
supplement other occupant complaints such as inadequate
temperature, humidity, or lighting. However, even after a
building investigation, specific causes of SBS - by current
definition - remain undetermined.
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Prior to the 1973 oil embargo, most office building's
heating, ventilating, and air conditioning (HVAC) systems were
designed and operated to provide as much as 15 cubic feet per
minute (cfm) of treated outside air for each building occupant.
To save energy, conservation measures were later implemented
which reduced the standard amount of treated outdoor air provided
for ventilation in some office buildings to only 5 cfm per
occupant. Thus, the capabilities of HVAC systems to provide
ventilation can vary considerably, based on the particular design
criteria effective at a given time. Additionally, many
ventilation systems do not effectively distribute the treated air
to people in the building. The result is inadequate ventilation
which allows pollution levels from existing sources to increase.
This is thought by many IAQ experts to be a major contributing
factor to SBS.
Some indoor pollutants come from sources inside the
building. For example, adhesives, carpeting, vinyl or rubber
molding, manufactured wood products, copying machines,
pesticides, and cleaning agents may emit volatile organic
compounds (VOCs), including formaldehyde. Research shows that
some VOCs can cause acute and chronic health effects at various
concentrations. Tobacco smoke is also a source of indoor air
pollution, which can contribute to harmful levels of VOCs and
respirable particulate matter.
The indoor air can also be contaminated from sources outside
the building. This occurs primarily when pollutants from motor
vehicle exhausts, plumbing vents, and building exhausts (such as
those for toilets and kitchens) enter the building through
improperly located outside air intakes, windows, and other
openings. In addition, combustion products such as oxides of
carbon, nitrogen, and sulfur can enter a building from an
attached or underground garage, or a nearby industrial source.
These pollutants can cause both SBS symptoms and BRI.
Other causes of building-related health effects include some
biological agents. Among these are certain bacteria and fungi,
and their spores, pollen, and other living and non-living agents.
Biological contamination at levels sufficient to cause illness is
sometimes associated with HVAC systems. For example, disease
causing biological agents may breed in stagnant water that is
allowed to accumulate in humidifiers and cooling coil condensate
pans, or where,,water has collected on ceiling tiles, carpeting,
insulation or internally lined duct work. Physical symptoms
related to biological contamination may include cough, chest
tightness, fever, chills, muscle aches, and general allergic-
type responses such as mucous membrane irritation and upper
respiratory congestion.
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"Specific causes of SBS remain unknown. It.is
often assumed that SBS results from insufficient fresh
air (outdoor air) being brought into the enclosed
environment. However, little published evidence
supports this hypothesis and complaints are not always
correlated with ventilation rates. (Skov, 1987; Fanger,
1988; Robertson, et. al., 1985; Harrison, 1987).
European studies suggest that SBS is associated with
ventilation systems that use humidification and
chillers (S. Burge, 1987; Finnegan, 1984; Skov, 1987;
Valbjorn, 1987; Fanger, 1988). Job category and gender
also affect the perception of work-related symptoms.
Occupant activities and furnishings can affect indoor
air quality and complaint rates. Specifically, the
surface area of 'fleecy' materials, exposed paper
materials, and the amount and allergenic portion of
floor dust have been related to complaint rates
(Gravesen, 1986). Different buildings may have
different sources of poor indoor air quality; sometimes
a contaminated ventilation system itself is a source."
"Bioaerosols have not been conclusively associated
with SBS. S.Burge (1987) and Finnegan (1984) suggest
that correlations between SBS and humidification and
cooling were due to microbial contamination. Fungal
amplification and unusual fungi associated with SBS
have been reported (Morey, 1984 and 1988). Endotoxins,
mycotoxins, and other microbial products are chief
candidates for future research into the relationship
between SBS and bioaerosols since their effects would,
theoretically, not be dependent on immunologic
sensitization, and their effects might be of short
enough duration to account for complaints that resolve
when occupants leave a building."
"In summary, a single cause for SBS is unlikely.
Rather, many hypotheses (sources/causes) must be
considered in determining the cause of complaints in
any particular building, including ventilation rates,
ventilation system maintenance and type, off-gassing of
building furnishings, and evolution of a multitude of
irritants from occupant activities, microbial
contamination, etc."
[These quotations were extracted from: Guidelines for the
Assessment of Bioaerosols in the Indoor Environment. American
Conference of Governmental Industrial Hygienists, November,
1989.]
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Solutions to indoor air problems usually include
combinations of the following prevention and control measures;
• Education. This is the most important control method.
If building occupants, management, building maintenance
personnel, and others understand the various sources
and effects of indoor pollutants, they can act together
to reduce indoor pollutant exposures.
• Pollutant source removal, modification, or
substitution. This is the most effective way to
resolve an indoor air quality problem when specific
sources causing the problem can be identified. This
approach reduces or eliminates the emissions from a
pollutant source, and may be used in combination with
increased ventilation to dilute the indoor pollutant
level. Examples of this method include cleaning or
replacing contaminated filters in the HVAC system,
removing water-stained ceiling tile and carpeting;
instituting a no smoking or restricted smoking policy;
exhausting combustion products to the outdoors; and
using and storing paints, adhesives, solvents, and
pesticides in well-ventilated areas. In fact,
resolution of problems in a building which manifests
BRI usually requires removal of the pollutant source.
• Increasing ventilation rates. This can often be a
cost-effective means of reducing indoor pollutant
levels. In a building with mechanical ventilation
systems, outdoor air quantities should be provided at
rates at least as high as those specified in
appropriate standards or codes. The American Society
of Heating, Refrigerating and Air Conditioning
Engineers (ASHRAE) 1989 ventilation standards (which
are being implemented at EPA Headquarters facilities)
specify a minimum of 20 cfm of outdoor air per person,
in general office areas. It is important to ensure that
ventilation systems are operated and maintained to
provide at least these rates. Also, when there are
strong pollutant sources, additional ventilation should
be provided to dilute and/or exhaust contaminated air.
Optimally, local exhaust systems should be employed to
remove indoor pollution from such sources as restrooms,
copying rooms, and printing facilities.
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Time of use adjustment of* a pollutant source. This is
another important IAQ control strategy. When feasible,
pollutant sources should be used when the least number
of people will be exposed, e.g., painting during
weekend or nonworking hours, and allowing building
materials in new or remodeled areas to off-gas
pollutants under high ventilation conditions before
occupancy.
Air filtration and purification. These processes can
be used in combination with source control and
ventilation where specific problems are identified and
practical air cleaning options exist. Particulate
filtration, for example, is a highly advanced
technology, but increasing performance in filtration
can translate to major increases in both capital and
operating expenses. Ordinary furnace filters do not
effectively capture pollen and other small particles.
Vapor and gas removal equipment is also available for
some specific types of pollutants, but these
technologies are usually not appropriate for general
use in ordinary office environments.
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PART 2
INDOOR AIR QUALITY RISK MANAGEMENT AT EPA HEADQUARTERS
RISK IDENTIFICATION AND RISK ASSESSMENT
Risks associated with IAQ problems at EPA's Headquarters
facilities include, but are not limited to:
1) adverse impacts on employee's safety, sense
of well-being, and comfort;
2) diminished health and wellness, including
increasing employee's psychological stresses
to unhealthy levels;
3) lessening of employee's morale;
4) reduction of employee's productivity;
5) impairment of the Agency's abilities to meet
its mission related goals;
6) diversion of human, financial, and other
resources to resolve related contingencies.
It is often difficult (or impossible) to quantitatively
assess and prioritize the wide range of risks to employees and to
organizations resulting from poor indoor air quality. Many of
the arts and sciences that use quantitative methods are still in
nascent stages of development; they are - at best - inexact.
Frequently, the actual causes of adverse health effects
among building occupants that are attributed to indoor air
quality are never identified. However, certain universally
applicable control measures have historically been shown to be
effective. They can eliminate, or significantly diminish, reports
of adverse health effects that are attributed by building
occupants to indoor air quality. Such measures can prove
effective even in instances where the causes of problems are not
positively identified.
For these reasons, and others, the difficulties of
developing and using meaningful, quantitative risk assessments
when constructing a comprehensive corrective plan are compounded.
Some broad qualitative assessments of the impacts of poor indoor
air quality are possible to determine and they can be useful, in
a strategic sense, to develop priorities for corrective
approaches. Options for specific remedial actions of a tactical
nature can then be explored. Quantitative methods can be a
useful adjunct to such tactical efforts. They are most
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effectively used-when dealing with a known causative agent, or
when a specific agent is highly suspected.
The risk identification and assessment methods used in
developing this Plan are premised upon those that are currently
recognized, established, and accepted among a wide community of
IAQ experts.
Actions to date at EPA's Headquarters facilities, include
both formal and informal steps to qualitatively and
quantitatively identify and assess IAQ related risks. These have
included, among others:
1) monitoring for, and assessment of, potential
stressors such as those of a chemical,
biological, particulate, ergonomic, or
physical nature in the work environment;
2) establishment of a medical surveillance
program for symptoms and illnesses attributed
by employees to IAQ;
3) assessments of labor/management relations;
4) identifying employee health, safety, comfort,
and wellness issues;
5) determining employee job satisfaction and
some causes of job related psychosocial
stresses; and
6) evaluations of various building systems,
including mechanical components of heating,
ventilating, and air conditioning (HVAC)
systems.
A major effort in these regards has been pursued through a
comprehensive study of indoor air quality and the work
environment, which was conducted under the coordination of Kevin
Teichman at EPA and Lawrence Fine at NIOSH. To date, Volume 1 of
three - the Employee Survey, and a Union supplement to Volume 1 -
have been published. Volume 2 - Results of Environmental
Monitoring -and Volume 3 - Multivariate Analysis - are now in
preparation. Volume 2 has been scheduled for release in late
April 1990. This comprehensive study is in addition to other
previous studies of a more targeted nature that were conducted
under the auspices of groups such as the Environmental Health and
Safety Division, the Indoor Air Branch, and the Office of
Technology Transfer and Regulatory Support. A variety of
additional risk identification and risk assessment efforts, in
addition to these studies, currently continue on an on-going
basis.
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RISK CONTROL
Previously, efforts to control employee and Agency risks
related to IAQ at Headquarters have included measures intended
to:
1) maintain a well functioning ventilation
system capable of providing an adequate
supply of air, in terms of quantity and
quality, to all employees;
2) maintain a program to control pollutants
generated or accumulated within the building,
including environmental monitoring as
necessary;
3) prepare and distribute a survey of employees'
perceptions about indoor air quality, working
conditions, comfort and well-being to enable
targeted corrective actions; and
4) conduct educational programs and maintain
open communications between employees and
management on matters pertaining to
occupational health, safety, and wellness
concerns.
Other risk control measures that have been, or are being
taken, are further characterized in a number of documents: the
EPA labor/management agreement of July 13, 1987 [Appendix 1],
several desk-to-desk memoranda such as that sent from Loree
Murray (President of AFGE), Robert Carton (President of NFFE) and
Charles L. Grizzle (AA for OARH) to all Headquarters employees on
November 17, 1989 [Appendix 2], and reports sent to the Honorable
Barbara A. Mikulski by Mr. Grizzle [Appendix 3].
Risk control measures specified in this Plan include:
- pollutant source removal, modification, or substitution;
- time of use adjustments of pollutant sources;
- increasing ventilation rates;
- additional air filtration and purification;
- educational programs and communications activities.
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These measures are intended to improve the quality and
quantity, of indoor air provided to EPA employees at its
Headquarters facilities. In doing so, the Agency hopes that it
will significantly enhance employee's safety, sense of well-
being, and comfort. Such measures are also expected to improve
employee's general health and wellness, while diminishing
psychological stresses related to IAQ. These steps should have a
major positive impact on morale and result in increased
productivity. Human, financial, and other resources can then be
redirected to activities that will further the Agency's abilities
to meet its nationally and globally directed mission related
goals.
As such risk control efforts are conducted, together with
additional efforts that will be implemented in the future, it is
essential that this IAQ Management Plan remain flexible in terms
of:
1) specific control related measures,
2) time frames for completion of individual
proj ects, and
3) allocations of resources.
This flexibility is necessary because information that may
be developed during the evolution of control measures could point
to the need for some project modifications, reprioritization of
projects, and development of other control measures. Maintaining
such flexibility will help to assure that this Plan is optimally
effective and efficient in addressing such additional issues as
they arise.
The control measures in this IAQ Plan are based upon
information that has been developed about the quality of air and
employee perceptions about their workplace since 1986. Because
Volumes 2 and 3 of the Indoor Air Quality and Work Environment
Study are still in preparation, this Plan may undergo subsequent
modifications when the remaining volumes are released, or upon
receipt of additional information from other sources
necessitating such changes.
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RISK COMMUNICATION
The proposed communications strategy includes both internal
and external entities as targeted audiences. Communications
conducted in the context of this strategy must be constructed and
implemented so as to reach a maximum number of identified
audiences. In instances where the members of an audience will be
expected to understand a decision that has been made on their
behalf, or where the members of an audience are expected to
participate in a decision making process, the communication of
risks must be understandable by the target audience in terms of
their personal and/or institutional risk management.
Members of each target audience must be able to make
informed risk management decisions. The significance of risks
should be conveyed in terms that are well known and understood by
the members of the target audience. In some instances a
meaningful appreciation for a particular risk can be established
by anecdote. The risk can be compared to, or contrasted with,
other risks that are commonly encountered by members of the
target audience. The costs of different options as they pertain
to the audience should also be made known. Information releases
of a purely advisory nature, such as those to external media, may
also be presented in such terms.
The strategy also includes recommendations for
communications intended for all employees, line supervisors and
managers, members of the senior management team, internal and
external media, and various oversight bodies - such as the US
Senate and House of Representatives, General Accounting Office,
and others. Active involvement by the EPA's Office of Executive
Support, Executive and Congressional Communications, and the
Office of Human Resources Management, Employee Participation and
Communications Division - as well as other information
dissemination groups (including labor organizations) - is
considered essential.
This Plan, prior to its transmittal to the AA for OARM
by the Labor/Management Health and Safety Committee, may be
forwarded to such information dissemination groups for their
review and further development of the comprehensive
communications strategy. These groups may then engage in advance
planning for the implementation of components of the IAQ
communications strategy relative to their areas of
responsibility.
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RISK FINANCING
While some of the IAQ risk identification, risk
assessment, risk control, and risk communication measures can be
priced - even if on an approximate basis - others are not
possible to calculate at this time. Therefore, only rough
estimates of budgetary allocations are currently possible, and
major adjustments may be required over time.
A preliminary determination was made by the Environmental
Health and Safety Division of costs for IAQ related projects
initiated by Headquarters from 1986 through August of 1988. It
reflected that the Agency had spent in excess of $1.7 M, at that
time. Direct costs incurred since that time, to support similar
activities, are currently greater than $1 M. No known attempts
have been made to calculate other costs incurred by the Agency -
such as those related to diminished employee productivity, human
resources administration and employee turnover, lost workdays,
alternative work space, and others.
Listed in Part 4 of this Plan, entitled "IAQ IMPROVEMENT
MEASURES," are the specific control measures that are to be
implemented. At the present time it is not feasible to
accurately estimate the amount or level of internal staff effort
required to support all of these activities. Neither is it
feasible to accurately estimate the costs for services and
products that must be acquired in order to implement all of the
control measures. However, such estimates will be prepared later
as the additional data required to develop such estimates is
received.
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PART 3
THE GOALS OF THIS PLAN
[Note: scientifically valid measurement techniques shall be used
when appropriate to periodically assess progress made towards
achieving the goals described in this sectioni Actions to
achieve these goals may be taken and evaluated, however, based on
other than scientific methods.]
Short-term:
1) to have the IAQ Management Plan approved by the
Labor/Management Health & Safety Committee and
transmitted to the AA for OARM by not later than
4/12/90;
2) to have the IAQ Management Plan approved for
implementation by the AA for OARM, and other
appropriate entities, by not later than 4/30/90;
3) to continue on-going efforts, and to immediately .take
additional steps, to improve the quality and quantity
of indoor air provided to EPA employees at its WSM
facilities; to continue and to enhance established risk
management activities related to indoor air quality at
EPA Headquarters. These activities include risk
identification, assessment, control, financing, and
communications efforts currently underway within the
Office of Administration, Environmental Health and
Safety Division, Facilities Management and Services
Division, and other collaborating Offices and
Divisions. Emphasis is to be placed on employing
proven measures that have been historically
demonstrated to eliminate, or significantly reduce,
reports by building occupants of adverse health effects
attributed to the building;
4) to immediately initiate new communications activities
intended to inform all EPA Headquarters employees, and
others, about this comprehensive IAQ Management Plan.
This includes its goals and the risk management
activities to be conducted short-ten, mid-te'rm, and
long-range. [All reasonable steps must be taken to
insure that IAQ Management Plan related communications
with employees, and others, do not create, or
exacerbate, employee's psychological stress.] Such
communications should employ methods suggested in
various risk communication guidance documents, such as
the EPA's publication entitled: Risk Communication for
Air Toxics.
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Developing employee's understanding of this Plan's
goals, and training and educating employees about the
vital and active roles they must play-to insure its
effective implementation, is critical to success.
Effective communications and employee driven control
methods are essential in these regards.
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Mid-range;
1) to reduce the levels of specific employee health,
safety, and well-being risks - of significance - and
which are associated with IAQ, to levels acceptable to
labor and management, by not later than June 30, 1991;
2) the IAQ Plan Subcommittee will ensure the elaboration of
specific, objective measures for determining
improvements in IAQ. Examples include measurably lower
levels of significant indoor air pollutants,.as.well as
increases in the quantity and quality of treated
outdoor air provided to employees in meeting the goal
of 20% minimum outside air, per 1989 ASHRAE standards;
3) to reduce the percentage of employees at WSM who
indicate that they often or always have symptoms
frequently associated with indoor air quality [exhibit
ES-2 within Volume 1*] from an average of 13.4% to less
than 6%, by not later than June 30, 1991;
4) to reduce the percentage of employees at WSM who
associate one or more symptoms with their work building
[as cited in exhibit 5-10 (see also 5-3) within Volume
1 of the Indoor Air Quality and Work Environment
Survey*! from 62% to less than 30%, by not later than
June 30, 1991;
5) to reduce the percentage of employees at WSM who
indicate that their building associated symptoms
reduced their ability to work at least some of the time
[exhibit 5-9 within Volume 1*] from 29% to less than
15%, by not later than June 30, 1991;
6) to reduce the percentage of employees at WSM who
indicate that the frequency and duration of their
infections had increased since they began work in the
WSM building [exhibit 5-12 within Volume 1*] from 39%
to less than 19%, by not later than June 30, 1991.
* See Appendix 4
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Long-term;
1) to achieve and fulfill all programmatic elements and
goals of this IAQ Management Plan, in a manner
acceptable to labor and management;
2) to establish a model of excellence - recognized as
outstanding in both the private and public sectors -
for the planning, developing, implementing, and on-
going management of a comprehensive IAQ Management
Plan.
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PART 4
INDOOR AIR QUALITY IMPROVEMENT MEASURES
FACTUAL BASIS FOR SOME SPECIFIC IMPROVEMENT MEASURES
1. An average of 13.4% of respondents to the Indoor Air
Quality and Work Environment Survey conducted among EPA
Headquarters personnel at Waterside Mall have reported
that they often or always experienced indoor air
quality related symptoms during 1988 which got better
upon leaving work. Those symptoms included:
a. headache
b. stuffy nose/sinus congestion
c. dry, itching, or tearing eyes
d. burning eyes
e. dry throat
f. unusual fatigue or tiredness
g. sleepiness or drowsiness;
2. according to the Indoor Air Quality and Work
Environment Study. Volume 1. there were a significant
number of complaints made by EPA Headquarters personnel
about a variety of symptoms that they perceived to be
associated with the workplace in 1988, although not all
such symptoms were related to indoor air quality. For
example, 62% of Waterside Mall employees reported
associating one or more of their symptoms - ranging
from headaches, runny noses and coughs, to backaches
and wrist pain - with the 401 M Street facilities;
3. at Waterside Mall, employees ranked fumes from new
carpeting, paint, and tobacco smoke as the leading
causes of eye, nose, throat, and respiratory
irritation;
4. 24% of employees have reported that they want to adjust
physical conditions relating to odors in winter months;
30% in summer;
5. the highest ranking odors noticed at workstations last
year at Waterside Mall were "other food smells,"
"cosmetics," and "new carpet odors";
20
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the.results -of environmental monitoring conducted by
hygienists as a part of the Indoor-Air Quality and Work
Environment Study. Volume 2. had not been received at
the time this Plan was prepared. Other industrial
hygiene studies at Waterside Mall have previously been
performed, with the following general results:
a. biological agents; no viable microbes or
their spores - that are pathogenic to humans
- have been found in concentrations that are
deemed clinically significant to the general
population, in any air sampling conducted to
date at WSM;
b. chemicals; No specific chemicals found in the
workplace have been positively identified by
the EPA as a causative agent of employees'
general, on-going, health complaints at W5H -
that they attribute to the building;
However, 4-phenylcyclohexene (4-PC) - at low
parts-per-billion concentrations - has been
attributed by the National Federation of
Federal Employees union, local #2050, as the
cause of some EPA employee's adverse health
effects. (This chemical is present in about
95% of the carpeting currently produced in
the US.) In this regard, seventy-six
employees' complaints attributed to 4-PC were
first associated, in both temporal and
spacial terms, with the odor of certain
carpeting installed in areas of Headquarters
facilities beginning in October 1987.
According to the local NFFE union, at least
20 of these employees have reported that they
acquired "multiple chemical sensitivity"
during the time in 1987 when odors from the
newly installed carpet were the strongest. At
the present time, it is not possible to
firmly conclude with a degree of scientific
or medical certainty that the correlation of
4-PC with employee's health complaints is
valid. [See Van Ert letter, dated February
1990 (Appendix 5).] 4-PC is the subject of
various on-going EPA and other studies to
further characterize its toxicity, determine
its concentrations in carpet and other
materials, and in the workplace air;
21
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c. participates: respirable particulates have
been sampled, and there have only been
findings of "...interest..." related to
11... carbonaceous soot..." and other
particles stated to be "...sulfur
condensates...". These particulates were
found in concentrations consistent with what
would normally be expected in a metropolitan
environment such as Washington, D.C., and in
a building configured and HVAC-eguipped as
WSM.
Some of these particulates can be attributed
to the proximity of the Headquarters
buildings to several coal-fired power and
steam generation plants. Amounts of
respirable particulates measured have
averaged less than 20 micrograms/cubic meter
of indoor air, as compared to the EPA's
standard of 150 micrograms average/cubic
meter. Assessments of the allergenic
potential of some of these particulates has
been made.
[Note: the preceding is a general summary
intended to characterise only those results
of the specific tests, and expert
professional interpretations thereof, for the
environmental monitoring performed at EPA
Headquarters from 1986 to date.]
[Note: some individual employees with
specific medically diagnosed allergies to
various commonly encountered substances have
been identified. Measures have been/are
being taken to provide appropriate
aeeommoCations to such employees for their
medical conditions, in accordance with
recommendations from their physicians.]
comments about dusty, dirty working conditions were
recorded in the Employee Survey, with "...lack of
vacuuming...contributing to the problem, and
"...vermin..." reported. Remarks on the presence of
mice and roaches were more common at Waterside.
Specific concerns were expressed about the ventilation
system, with Waterside-based employees referring to
"...dirt filled air blowing around, sooty, powdery
dust, black particles falling from ventilators, and
other strange material coming from the ventilation
system...";
22
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8. there are several food service operations, a large
supermarket, and a smaller grocery store located in the
WSM complex. Such operations are generally known to
attract vermin, such as insects and rodents. Health and
sanitation laws require special vermin control measures
to be implemented by such types of businesses; the
degree and manner of compliance with such regulations
by those businesses located in the WSM complex is not
currently known by EHSD staff. There is no coordinated
vermin control program practiced by all WSM building .
complex tenants at this time;
9. the current condition of components of the AHU/HVAC
systems is not known to EPA personnel; the supply air
ductwork is thought to have fiberglass insulation
lining portions of the interior - there are no EPA
records reflecting recent comprehensive ductwork
inspections to determine its condition; interior air is
returned to AHU's throughout the system through above-
the-ceiling plenums, and a large percentage (up -to 90%)
may be recirculated; there are no EPA records
reflecting that the plenum spaces have been cleaned;.
the AHU's are equipped with intake air filters stated
by various parties to have efficiencies of between
"
0 • • ,
10. the smoking of tobacco products is currently permitted
in certain designated areas of the building, under the
provisions of a written smoking policy; these
provisions were in effect at the time of the employee
survey; problems with enforcement have been reported
anecdotally to EHSD staff in recent months;
11. painting of the building's interior is presently
accomplished using water based latex paints; interior
painting is done during other than regular business
hours with special ventilation methods employed;
managers and supervisors are now being informed in
advance when such work is scheduled, so that
appropriate notification of staff can be accomplished
and necessary arrangements for minimizing staff
exposure to paint odors made; these provisions were not
in effect at the time of the employee survey;
12. there are written provisions for dealing with the use
of fragrances and/or cosmetics by employees; these
provisions were in effect at the time of the employee
survey; anecdotal reports of enforcement problems have
been made to EHSD staff in recent months;
23
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13. according to various reports, certain ventilation
exhaust stacks, including some of those serving WSM
complex restaurant operations, are net designed,
constructed, or located so as to minimize the re-entry
of stack effluents back into the building through
supply air intakes and other openings; FMSD recently
arranged for the relocation of an intake near the -
Safeway loading dock, to minimize capture of odors and
delivery vehicle exhaust emissions.
24
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OTHER PREMISES FOR IMPROVEMENT MEASURES
1. There are several reasons for EPA employees' complaints
about adverse health effects related to indoor air
quality at Headquarters facilities:
- there are some adverse health effects being
experienced by employees that are related to indoor
air quality;
— some on-going health problems being experienced by
employees are not related to the workplace, although
they are attributed by the affected employees, and
others, to it;
- some complaints are psychosocial in origin and may be
based upon misperceptions and unfounded fears about
the building and the quality of indoor air at the
workplace.
2. The most rational approach to resolving employee
complaints about indoor air quality involves taking
immediate steps to improve air quality using methods
and materials that have, historically, been proven to
be effective in significantly reducing or eliminating
such complaints in other settings. It is also
important to address employee's perceptions about the
causes of symptoms that they relate to the building.
The first steps proposed are intended to isolate,
reduce, or remove conditions generally recognized as
potential causes of sick building syndrome complaints
and building related illnesses. Additional steps are
intended to assure employees that management recognizes
and is being responsive to their concerns, by
addressing symptoms that employees associate with their
workplace. Further steps are intended to ensure that
IAQ Management Plan related communications with
employees do not exacerbate stress related symptoms,
which are currently expressed by some employees.
25
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SHORT-TERM IMPROVEMENT MEASURES
1. Engage in a three part cleaning of the building:
a. encourage all employees to participate in
"Operation Cleanup" - a general cleaning and
dusting campaign for each organizational
element's spaces, by building, beginning
April 22 1990; make arrangements to have
extra housekeeping staff and carts available
to haul away unwanted general office
detritus; have salvage crews available to
haul away unwanted equipment; have trucks
available to haul away bulk waste, salvaged
equipment, and records for appropriate
disposition;
b. have the USSI housekeeping contractor engage
in a thorough cleaning (vacuuming, mopping,
dusting, and sanitizing) of each building or
building zone following the employee's
"clean-up" within that building or zone;
c. inspect, photograph, and document the
condition of the HVAC systems servicing EPA
occupied spaces at Waterside Mall facilities
- within 30 days.
Within 90 days (and only after parts "A" and
"B" are completed) have a contract let to
have all interior components of all AHUs
serving EPA occupied areas at WSM cleaned
[See Appendix 6 - the WORK STATEMENT for
cleaning the HVAC systems, dated March 26,
1990.] All fiberglass insulation is to be
removed from within AHUs and related ductwork
and replaced with sound insulating material
acceptable to EHSD; all HVAC system ductwork
is to be vacuumed and wiped clean, all
diffusers to be cleaned, all above-the-
ceiling plenum spaces to be cleaned and
ceiling tile cleaned and vacuumed on its
upper surface (such work to be performed
after regular business hours); damaged,
stained, and/or moldy ceiling tiles to be
replaced; USSI (or other housekeeping staff)
shall vacuum and dust all office areas in
which ductwork has been cleaned prior to
employee occupancy, during the same night/
morning that such ductwork cleaning is
performed;
26
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Continue to conduct briefings of senior management,
line managers and supervisors, staff, and others - as
necessary - to address concerns about indoor air
quality; disseminate information through appropriate
sources about the positive steps that Administration,
EHSD, FMSD, and the Unions, working hand-in-hand with
other groups, have taken/are taking to identify and to
resolve significant indoor air quality problems,
employee complaints about building related symptoms,
employee diseases that may be related to the building,
and other employee concerns about health, safety and
well-being; in addition, and at the specific request, of
the Director, Office of Administration, monthly
progress reports related to implementation of various
elements of the Plan, problems encountered, and other
matters requiring resolution by senior-level management
will be prepared under the auspices of the IAQ
Management Plan Subcommittee. These progress reports
will be sent to the Labor/Management Health & Safety
Committee for its information and necessary action,
with a copy to the Director, OA by not later than the
fifth (5th) day of each month. In addition, three
copies of the monthly progress reports will also be
sent to the OA Director's designee, for transmittal to
House and Senate Committees;
Invite additional individuals to serve as non-voting,
ex-officio members of the IAQ Management Plan
Subcommittee, as necessary. Such individuals may
include a representative of Town Center Management,
such as the supervisor of building engineering, a
physician representative of the Headquarters EPA Health
Unit, a senior-level representative of the Indoor Air
Division, a senior-level representative of the Office
of Technology Transfer and Regulatory Support, a
senior-level representative of the Employee
Participation and Communications Division, and an
independent Mechanical Engineer, employed as a
registered Professional Engineer with a local
engineering design firm having extensive experience in
renovating HVAC systems in response to IAQ
considerations; others who the Subcommittee members
feel may make significant scientific, technical, or
managerial contributions to the Subcommittee's
activities; the Subcommittee shall continue to develop
the IAQ Management Plan modifying it as conditions may
necessitate, and shall monitor and report on its
implementation, with the goal of resolving currently
identified problems of significance - within 2 years'
time;
27
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Reach an agreement with TCM mandating the continued use
of only (water-based) latex paints for indoor painting
jobs within EPA occupied space at WSM; verify that all
indoor painting is conducted after hours and with the
use of special ventilation methods to reduce odors to
the maximum extent feasible; assure that a mechanism is
established to enable informing line supervisors as far
in advance as possible of planned interior painting
jobs - so that necessary arrangements can be made to
inform the staff in the affected areas, and to assure
that paint-sensitive employees have an opportunity to
make contingency arrangements with their supervisors;
have an indoor painting safety protocol (related to
indoor air quality) for EPA Headquarters facilities
developed under the auspices of the Subcommittee -
within 90 days;
Appoint a SMOKING POLICY TASK FORCE, which shall report
to the Subcommittee, and charge the group with
developing a phased plan - within 90 days - that has- as
its ultimate goal the development of a plan to
eliminate violations of the current smoking policy at
EPA Headquarters facilities;
[The AA for OARH has proposed a total smoking ban,
Agency-wide, which is now in the "Green Border" review
process. Negotiations on this proposal, as it relates
to Headquarters, are expected to begin in the near
future.]
The Headquarters' WELLNESS PROGRAM will continue to
provide smoking cessation classes and related health
education programs;
Review the current procedures for resolving complaints
made by employees in which adverse health effects are
attributed to cosmetic or fragrance use by others.
Make revisions to the procedures, with the goal of
minimizing adverse health effects; review and revisions
of the procedures to be conducted within 90 days;
Review the current environmental services
(housekeeping) contracts between TCM and contractors,
as they pertain to EPA Headquarters facilities - begin
within 30 days; closely monitor and document the
performance of work under these contracts, and make
whatever changes are necessary to insure that the EPA
WSM Headquarters facilities are properly cleaned and
maintained; conduct scheduled, zone-based inspection
walk-throughs with representatives of TCM, USSI, EHSD,
28
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FMSD, and area managers/supervisors to document"all
findings and to insure corrective actions are
implemented (place special emphasis on vacuuming,
dusting, and sanitary cleaning procedures); work with
area managers to assure that spaces within their
geographic sphere of control are made accessible to
housekeeping crews; schedule walk-throughs so that each
EPA occupied space is subject to inspection at least
once per year;
8. Review current vermin control procedures at EPA
Headquarters facilities - within 30 days; attempt to
reach an agreement for the initiation of coordinated
vermin control monitoring and vermin control procedures
in accordance with the provisions of the Integrated
Pest Management Plan and existing collective bargaining
agreements with Town Center Management and the other
building leasees, within 90 days - if possible;
9. Attempt to reach an agreement to require prior EHSD
approval, in consultation with the Unions, for the use
of all cleaning agents and disinfecting agents- -and
procedures used by TCM and USSI in Headquarters-
facilities, as well as all vermin control agents -
within 90 days;
10. Attempt to reach an agreement with TCM to have
restaurant associated exhaust ventilation stacks at
Waterside Mall redesigned and reconfigured to minimize
the ingress of effluents back into the building through
fresh air intakes and other building openings - within
90 days;
11. Immediately initiate efforts to identify and inspect
all AHUs in the Waterside Mall complex servicing EPA
occupied space - within 30 days; obtain the
specifications for all such equipment and obtain the
most complete and accurate set of as-built drawings
available - within 90 days; have the contractor update
all such drawings, to include associated main supply
and exhaust ductwork, controllers, thermostats, and
other related equipment; have the contractor supply the
requested utility related information in a hard-copy
format as well as on an IBM-PC driven database (using
off-the-shelf, purchased software) sh-jwing HVAC system
components by building, zone, and room/area for all
headquarters facilities - within 180 days - and keep
all information current in the future; [Notes refer to
Booz, Allen, & Hamilton Inc. report dated September 28,
1989, by Kenneth R. McLauchlan, PE, entitled: "Results
of Inspection and Analysis of HVAC Systems at Waterside
Mall..." Available for review by appointment at EHSD.]
29
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12. *MSD to have contracts let for the performance of one-
half of this work in FY90, the balance to be performed
in FY91: physically separate from contiguous areas of
the building (using slab-to-slab construction, self^
closing corridor doors, negative air pressure
balancing, and ducted return air discharging directly
to the building's exterior), the following types of
areas within EPA facilities:
restrooms;
- locker rooms;
- shower/bathing rooms
- laboratories where toxic chemicals are routinely
used (there are none currently at WSM);
- photographic development facilities;
- janitor's closets and rooms dedicated to storage of
cleaning and/or sanitizing agents;
- core rooms dedicated to reproduction and/or copying
machines;
- carpentry, woodworking, metalworking, or similar.
shops (there are none currently at WSM);
- print shop facilities.
30
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MID-RANGE AMD LONG-TERM IMPROVEMENT MEASURES
1. Ventilation study and HVAC modification implementation;
obtain recommendations for enhancements of WSM HVAC
systems required to meet requirements negotiated in the
Agency's "Clean Air Agreement" [Appendix 1]; have
recommendations made by the Engineering Design Group
independently evaluated by another HVAC mechanical
engineering design firm; have specifications and
drawings prepared for required upgrades to the WSM HVAC
systems (make available results of previous engineering
analyses, and facilitate communications between
knowledgeable parties); award construction contracts,
with the first areas targeted for renovations to be
those identified from historical data as "hotspots" for
employee complaints. Have all work monitored for
compliance with engineering specifications, drawings,
and good practice and workmanship by an independent air
balancing company having current membership in the
Associated Air Balance Council; set goal of having all
HVAC systems modifications completed within 18 months,
with one-third to be completed in 1990 and the balance
of two-thirds to be completed in 1991.
[All provisions of the Clean Air Agreement shall be
followed. Ventilation system design specifications for
air exchanges and temperature shall conform to the
ASHRAE standards effective in 1989. Engineering design
goals should be based on premised conditions of 75
degrees under peak cooling load and 72 degrees under
peak heat load - at 20 cfm outside air/person.
Filtration specified shall have an efficiency of not
less than 65% based on ASHRAE 52-76, using extended
bag-type filters. Prefilters shall be installed to
enhance the life of the final filters. Filter beds
shall be equipped with instrumentation to measure
pressure drops to aid in the determination of the
condition of filters and maintenance. No provisions
shall be made for the humidification of indoor air.
Equip all cooling towers with drift eliminators.]
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Attempt to revise leases with TCM to reflect such
modifications, and include revisions relative to
acceptable temperature ranges and ventilation rates,
working with GSA officials as necessary. Continue
extended hours of HVAC system operation to assure an
acceptable level of occupant comfort - start systems
during early morning hours, by 5:00 am on weekdays
(except 4:00 am on Monday or the first day of the work
week) and run to 7:00 pm, M - F; run systems as
necessary on weekends.
Take necessary steps to assure that installations of
new HVAC systems meet the 20% outside air goal, per
ASHRAE standards. Agency designated personnel, who may
be accompanied by union representatives, shall randomly
monitor the dampers on 5 AHUs, through unannounced
inspections with TCM personnel, monthly; concurrently
inspections shall be made for leaks, stagnant water,
and evidence of unacceptable biological growth. Desk-
dropped flyers shall be issued whenever the HVAC system
is being balanced. Quarterly air monitoring for carbon
dioxide levels shall be performed in "hot spots." • See
the attachment entitled "Rationale for the Evaluation
of Ventilation System Efficiency."
2. Continue to remove damaged or troublesome carpet on an
accelerated basis from areas where employees and
managers agree that it is desirable to do so.
Develop revised procedures for acquiring, installing,
maintaining, and removing floor coverings.
Acquisitions of floor coverings should take into
consideration: 1) vendor certification of the off-
gassing rates of organic chemicals, conforming with EPA
criteria, or 2) airing-out procedures to minimize
indoor air pollutants. Revised procedures are to be in
place by July 1, 1990.
3. Space acquisition and occupancy control.
Take steps to reduce the occupant load of the WSM
facility to an average density of no more than 1
employee per 135 square feet gross floor area, in
accordance with GSA stipulations.
A. First, focus on "hotspots", giving priority
for relocation to those employees determined
by EPA's physician(s) to be candidates for
alternative work space or work assignments.
32
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B. Within 30 days, review the memorandum from
Mr. Charles L. Grizzle dated July 10, 1989
[Appendix 7], to determine if changes in
procedures may be needed to improve the
process.
C. Within 30 days, conduct mandatory meetings
with all supervisory personnel to fully
explain their role and responsibility in
evaluating employee health concerns and
making accommodations when a supervisor
believes that an employee's health may be
adversely affected by his/her working
conditions. [A guidance document is being
prepared by the Labor/Management Health and
Safety Committee explaining options for
resolution of work-related health issues
identified by employees.]
D. Reduce occupancy loading through relocation
of organizationally related, functional
areas, by "AA-ship."
Currently Scheduled Space Acquisitions;
Crystal City #1 50,000 sq. ft.
Northeast Mall 16,000 " "
(subbasement)
Crystal City #2 50,000 " "
Additional space working with GSA
4. Control of indoor pollutants and employee exposures to
chemicals.
Mechanisms shall be maintained in place to insure that
employees will not be exposed to chemicals at levels
known to be toxic or acutely irritating to eyes, nose,
or throat, or cause other physical ills to employees.
[This includes measures to limit employee's exposures
to VOCs, including 4-PC, and other chemicals which may
off-gas from newly installed floor covering materials.]
Construction work in occupied areas of the building
which results in the release of irritating or toxic
dusts, aerosols, or vapors will be performed in
occupied areas only during non-work hours. Clean-up
must be completed before employees return to work.
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EHSD shall keep a listing of toxic chemicals present in
the building as required by the OSHA Hazard
Communication Rule.
(See the Clean Air Agreement for additional details
concerning specific programs for PCB's, radon,
solvents, and asbestos.) The mechanisms established
under short-term action item #9, herein, shall be
maintained as a permanent program by EHSD. In .
addition, the services of the Indoor Air Branch (MD-
54) shall be employed to initiate a pilot program by
10/31/90 on the evaluation and testing of selected
indoor materials. The proposed testing procedures may
be reviewed by the IAQ Management Plan Subcommittee.
[Appendix 8 - memorandum from W. Gene Tucker to Julius
Jimeno dated 12/18/89.] Determine the feasibility of an
Agency-wide program by 10/31/92.
Current operating procedures for investigation of
indoor air quality complaints at WSM, and emergency
procedures shall be maintained in force, and expanded
to include appropriate provisions for all EPA
facilities by October 1992.
5. Continue, and enhance, the established IAQ medical
surveillance program for Headquarters employees
Appoint a "Blue-ribbon EPA Health Task Force" composed
of independent, nationally recognized occupational
medicine physicians, allied-health professionals, and
other health-care professionals. These individuals,
together with other professional and technical
consultants (such as medical statisticians and
epidemiologists) will make recommendations for
enhancing the medical surveillance program, and provide
on-going oversight and monitoring of the program. The
Task Force may recommend other projects - such as
epidemiologic studies - involving WSM employees,
including those who have reported multiple chemical
sensitivities. Empanel such a Task Force by September
1, 1990. Expand the scope of the Task Force's charge to
include all EPA activities, nationally, by June 30,
1991.
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Establish an "All EPA Task Force" to develop and
implement an Agency-wide IAQ plan.
Appoint a Task Force by October 31, 1990, to develop
and oversee the implementation of a comprehensive IAQ
Plan for all EPA facilities. Publish information,
periodically, about the group's process and outcomes.
The active participation of EPA program offices and
other federal agencies in this activity, including GSA,
NIOSH, OSHA, and the Public Health- Service - among
others - will be sought. The EPA plan will be designed
as a model for the public sector and serve as a guide
for Federal Indoor Air Quality management plans.
35
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BIBLIOGRAPHY
Surge, H.A.; Feeley, J.C.; Kreiss, K.; et al: Guidelines for the
Assessment of Bioaerosols in the Indoor Environment. American
Conference of Governmental Industrial Hygienists. Ohio (1989).
Surge, S.; Hedge, A.; Wilson, S.; et al.: Sick Building Syndrome:
A Study of 4373 Office Workers. Ann. Occup. Hyg. 31(4A):493-504
(1987)
Fanger, P.O.; Lauridsen, J.; Bluyssen, P.; Clausen, G.: Air
Pollution Sources in Offices and Assembly Halls, Quantified by
the Olf Unit. Energy Build. 12:7-19 (1988).
Finnegan, M.J.; Pickering, C.A.C.; Burge, P.S.; The Sick Building
Syndrome: Prevalence Studies. Br. Med. J. 289:1573-1575 (1984)
Gravesen, S,; Larsen, L.; Gyntelberg, F.; Skov, P.: Demonstration
of Microorganisms and Dust in Schools and Offices. Allergy
41:520-525 (1986).
Harrison, J.; Pickering, A.C.; Finnegan, M.J.; et al.: The Sick
Building Syndrome - Further Prevalence Studies and Investigation
of Possible Causes. In: Indoor Air '87. Proceedings of the 4th
International Conference on Indoor Air Quality and Climate, pp.
487-491. B. Seifert, H. Esdorn, M. Fischer, et al., Eds.:
Institute for Water, Soil, and Air Hygiene. Berlin (1987).
Morey, P.R.: Microorganisms in Buildings and HVAC Systems: A
Summary of 21 Environmental Studies. In: Proceedings of IAQ '88,
Engineering Solutions to Indoor Air Problems. American Society
for Heating, Refrigeration, and Air-Conditioning Engineers, Inc.
Atlanta, GA (1988)
Morey, P.R.; Hodgson, M.J.; Sorenson, W.G.; et al.: Environmental
Studies in Moldy Office Buildings: Biological Agents, Sources and
Preventive Measures. Ann. Am. Conf. Govt. Ind. Hyg. 10:21-35
(1984)
Robertson, A.S.; Burge, P.S.; Building Sickness. The
Practitioner. 229:531-534 (1985).
Skov, P.; Valbjorn, O.; Danish Indoor Climate Study Group: The
"Sick" Building Syndrome in the Office Environment: The Danish
Town Hall Study. Environ. Intl. 13:139-349 (1987).
Vaibjorn, O.; Skov, P.: Danish Indoor Climate Study Group.
Influence of Indoor Climate on Sick Building Syndrome Prevalence.
In: Indoor Air '87. Proceedings of the 4th International
Conference on Indoor Air Quality and Climate, pp. 593-597.
B. Seifert, H. Esdom, M. Fischer, et al., Eds.: Institute for
Water, Soil, and Air Hygiene. Berlin (1987).
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APPENDICES
#1 EPA Headquarters' Labor Management Committee
Clean Air Policy for Headquarters, dated July 13, 1987
#2 Headquarters' Labor Management Joint Letter to All Employees
Concerning Health and Safety Concerns at Waterside Mall,
dated November 17, 1989
#3 Letters from Mr-. Charles L. Grizzle, Assistant
Administrator, Office of Administration and Resources
Management to the Honorable Barbara A. Mikulski Concerning
Efforts to Provide Quality Work Environment, dated 12/12/89;
01/26/90; 02/27/90.
#4 Exhibits ES-2, 5-3, 5-9, 5-10, 5-12 from "Indoor Air Quality
and Work Environment Study, EPA Headquarters' Buildings,
Volume 1, Employee Survey," November 1989 [Publication #19K-
1003]
#5 Letter from Mark Van Ert, Ph.D., Director, Occupational
Safety and Health Program, School of Health' Related
Professions, The University of Arizona to Jeff Davidson,
Ph.D., Section Chief, Existing Chemical Assistance Group,
Office of Toxic Substances, EPA, Concerning EPA Employees'
Complaints of Illness and Indoor Air Pollution dated,
February 02, 1990
#6 Work Statement for the Cleaning of Heating, Ventilating, and
Air Conditioning Systems at Waterside Mall, dated March 26,
1990
#7 Letter from Mr. Charles L. Grizzle, AA for OARM, EPA, to All
Headquarters Managers and Supervisors Concerning Guidance
Regarding Employee Requests for Alternative Workspace or
Work Assignments, dated July 10, 1989
#8 Letter from W. Gene Tucker, Ph.D., Chief, Indoor Air Branch
(MD-54), EPA to Mr. Julius Jimeno, Acting Director,
Environmental Health and Safety Division, EPA, Concerning
Testing Indoor Materials, dated December 18, 1989
37
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APPBJOJX 4.
EPA LA30R MAX*3E>EJT CCMMirnZ
(Established Pursuant to Collective Bargairj.ng Pqrecncnt
Between SITE, Local 2050, AF3E. Local 3331 and the Agency)
PURPOSE; To establish a clean air policy for EPA Headquarters buildincs
(Waterside, Crystal City, Fairchild) which ensures that the level of air-
borne pollutants in these buildings is kept suf ficisntly low to provide a
healthful work environment.
BACKGROUND; Section 19 of the Occupational Safety and Health Act of 1970
seeks to ensure safe and healthful working conditions to all employees.
The Environmental Protection Agency, regarded nationally as being in the
forefront of establishing good environmental health policies, has identi-
fied indoor air pollution as a source of health risks and is therefore,
striving to provide its employees with a work environment free frcm signi-
ficant health risks associated with exposure to chemcal, physical, and
biological agents, fenagsnent is ccntnitted to maintaining a program
capable of attaining this goal and the following principles are adopted:
• Maintain a well functioning ventilation system capable
of distributing an adequate air supply to all employees;
• Maintain a program to control pollutants generated or
accunulated within the building including monitoring as
necessary;
* Institute, analyze and distribute the results of an employee
occupational health survey at Headquarters buildings to
detect possible indoor air related illness;
* Maintain an open f orun for communications between employees and
management on occupational health related concerns.
PROGRAM
1. Ventilation Systems
The Agency will take reasonable actions to overcome the constraints
of the leases and other factors that Management does not fully control
and that are impediments to achieving the following objectives:
The ventilation systems in buildings occupied by EPA employees at
Headquarters will be well functioning as defined by recognized engineering
standards and Federal and local codes. The amount of fresh air taken
ir.to these buildings will be equal to or greater than the latest American
Society of Keating, Refrigerating, and Air Conditioning Engineers (ASHP-AE)
guidelines (code 362) . The rate of fresh air changes will be equal to
or greater than the current ASHFAE guidelines fcr buildings that permit
tracking (20 cSn/person) .
-------
At no tune will outside air
-------
2. Control of PoUutAnts
E\3llutant3 brought jLnto the buildings or created in the buildings
shall be controlled in order that unacceptable levels are not reached
where erployees are working (includes copy center and print shop}.
The Occupational Health and Safety Staff shall keep a listing of
toxic' chanicals present in each building as required by the OSHA Hazard
ODmtunication Rule (29 CFR 1910.1200). This list nust be kept up to
date, tfetenal Safety Data Sheets (MSDS) shall be made available to the
Union, the Facility Advisory Qxincil and to any requesting employee for
all chanicals used in Headquarters buildings occupied by the Agency,
contractor or owner personnel, Management will request that MSDS's are
provided by contractors for all the chemicals being used in the building.
The integrated Pest Management program shall be used to control
insects and vermin within the buildings so that pesticide use will be
'kept as low as possible.
a. Sicking
Btployeea are ethically responsible for naking sure that their
colleagues are not adversely affected by pollutants brought into their
-buildings for their personal use (e.g., hair sprays, cosnatics, etc.) QZ
created within the building by personal habits (e.g., smoking, stared
food, etc.)
The Agency understands that a smoking policy will increase stress to
certain employees. However, the goal of the Headquarters smoking policy
is to minimize exposure of nonsncking EPA Headquarters employees to second
hand smoke. This goal will be achieved by Uniting all sucking to areas
where the air 'is exhausted outside the building and not returned into the
general building ventilation systems. At this tine the only locations
meeting this requirement are res treats.
To reduce the inconvenience to both smokers and nonsmokers, rest-rears
on approximately every third floor, starting with the second floor, will be
designated as smoking restrccns if this is permitted by the building owners.
Smoking will not be permitted in the restrccns that are not designated.
This rule will take effect 15 days after signing. During the first 6
months, penalties for non compliance with the smoking policy will be limtec
to warnings through reprimands. After 6 months the parties will convene to
resolve any problems that have arisen. This delayed enforcement will perm1
smokers time to adjust to the change and atterpt to quit smoking. Also, al
designated smoking restroons will be checked to insure that their exhaust
systems are functioning to a level which will insure that smcke generated i
the restroom is exhausted and does not enter the general work place. Rest-
rooms exhaust rates will be checked prior to the mplementation of the
smoking policy using velometers to measure the exhaust rate. Stoke tubes
will be used to determine that a negative pressure exists in the restrccr.
with respect to the general building air pressure. Ventilation in the
-3-
-------
designated snxxirrj res-.ruJTs *il^ .>2 checked -w-jally. !
-------
Only persons adequately trained and wearuic protective equipment
should be allowed in the area during, immediately following, the fire.
Since decontamination may be necessary, wipe sanples will be taken
and analyzed- by CHSS. PCB contaminated items will be decontaminated or
discarded so they will pose no hazard to employees.
The Occupational Health and Safety Staff will institute a radon
monitoring program in each of the buildings occupied by EPA Headquarters
employees sufficient in scope to assess whether there is any health risk
to employees associated with radon exposure during the work day. The
results of 'such surveys and the assessment will be nade available to the
Union and the Facilities Advisory Council.
d. Solvents
• Bnployees will not be exposed to chemicals at levels known to be
toxic or acutely irritating to the eyes, nose or throat or cause other
physical ills to employees. construction work in the buildings which
results in the release of irritating or toxic dusts, aerosols or vapors
will be conducted during atployee non work hours whenever warranted. If
construction, work which would result in such releases must be conducted
during work hours, EPA employees will be assigned to other work space
not affected by the activity. •
New carpeting shall be shaqpcoed before the space is occupied unless
it has been properly aired out or has been shown to not emit chemicals
which cause health reactions to occupants. If vapors frcn carpeting or
furniture result in a health reaction, the affected employees should be
allowed to work at a temporary location until the problen is solved.
tenagenent will provide safe and healthful working conditions. If con-
ditions at a work station are found to endanger the health of an employee,
management will take reasonable actions to protect the employee.
e. Asbestos
The Asbestos Operations and Maintenance program is currently undei
revision and will be added in as soon as it is ccrpleted.
3. Occupational Health Survey
The Agency shall perform an occupational health survey cf Headquarters
orployees to obtain baseline information on employees health and indoor
air pollution. Results of the study will be surTiarized and nade available
tp the Union and Facilities Advisory Council. Subsequent surveys will
be initiated in response to specific problems.
-5-
-------
4. Dae of Technical Expertise
Managenent will request the support cf the Agency's o*n scientific
and technical experts to help resolve Headquarters employee health
related issues.
5'. OamTurucation
The Agency will establish and maintain a forur. for the sharing
of information between enplcyees and upper management concerning health -,
and safety issues at the Headquarters buildings. This forun (called the
Facilities Advisory Oauncil) will consist of management officials an.*
interested employees.
FAC will meet on a regular basis every 4-6 weeks. The agenda will
be posted in all Headquarters facilities in advance and management will
review topics for discussion fron all employees.
By their signatures, the duly authorized representatives of the ft. can
Federation of Government Employees, Local 3331, the National Federation
of Federal Employees, local 2050 and .the Headquarters, Bwironnental
Protection Agency attest that they have agreed to and executed this
collective bargaining agreement.
For ATCE, Local 3331
r NFFS, Local 2050
g^^
fery Qjaato
President''
CATE
President
For the Agency
tvD^l
W. Hu.rzy
resident Elect
LATE
Ceralil A. 'Bryan Y
-------
/ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
«
NOV | 7 '989
FILE
MEMORANDUM TO ALL HEADQUARTERS EMPLOYEES
SUBJECT: Health and Safety Concerns at Waterside Mall
In a recent memorandum to all employees, Bill Reilly expressed
his concerns about the working conditions in the .Waterside Mall
facility and his commitment to seeing that these conditions are
improved significantly. The unions and other concerned employees
have also devoted much time and energy in identifying issues
associated with the Headquarters facility. Consequently, the
Office of Administration and Resources Management (OARM) staff and
union officials have met several times to address these concerns.
Our goal is to work together to improve the indoor air quality at
Waterside Mall and to take whatever steps are necessary to provide
EPA employees with a safe and healthful work environment. As
promised in Bill's memorandum, we will be communicating with you
on a continuing basis as to the specific actions that we are taking
to address health and safety needs. This memorandum is the first
of these communications. Listed below are the actions that are
being taken.
Creation of a Labor-Management Health and Safety Committee
To assure that we are receiving1 adequate input from employees,
we are establishing a Health and Safety Committee to be comprised
of an equal number of representatives from the unions and
management. The purpose of this group is to develop strategies,
identify problems, and set priorities for corrective actions. We
have already met several times to discuss the formation of this
committee. The unions will continue working closely with their
bargaining unit members on a range of issues affecting the health
and safety of Agency personnel. The unions will conduct a meeting
for all interested employees on December 7, from 12:00 to 1:00p.m.
in the EPA Auditorium.
Ventilation Enhancements
Many employees have complained of poor office air quality in
the mornings, particularly on Mondays. To correct this, we are
pleased to announce that Facilities will operate the ventilation
system on an extended basis, effective November 17. Specifically,
Facilities will run the system on Sunday and start the system
earlier on weekday mornings.
-------
-2-
OARM has'ihired a ventilation engineer to design corrective
actions and "-to provide immediate recommendations to meet the new
American Society of Heating, Refrigeration, and Air-Conditioning
Engineers (ASHRAE) standard for the introduction of cuts-do dir
into the workspace of 20 cubic feet per minute per employee. This
action will help attain the goals set forth in the Indoor Air
Quality Collective Bargaining Agreement of July 1937. OARM will
also obtain the services of a construction engineer to assure that
corrective actions are completed as designed.
New Space
As requested, GSA is about to sign a lease for 50,000 square
feet of additional space in Crystal City. While this space was
requested to accommodate new employees hired as a result of the
FIFRA Amendments, it will allow the Agency to ease some of the
overcrowding. Another request for space is being prepared to
further relieve the overcrowding.
Carpet Removal
The first 2,000 square feet of carpet was removed from room
2827 of the mall over the weekend of September 23 and 24. As
result of recent flooding, Facilities has also removed carpet fro
portions of the East and West Towers. We- are now compiling a list
of other areas from which we will remove carpet. One of the
initial tasks to be addressed by the 'Health and Safety Committee
will be to set priorities of rooms for carpet removal. Together
with program managers we will inform all affected employees in a
systematic and timely fashion to minimize disruption. The
committee will also review the advisability of replacing the old
carpet with new carpet or tile. At this point in time, carpet that
is removed is being replaced with tile.
Elevators
We recognize that the elevators were not designed to handle
the inordinate number of passengers and amount of freight traffic
on a sustained basis. Accordingly, Facilities has started the
complete overhaul of all the elevators, beginning with the East
Tower. This will ensure their safe and efficient use. As a part
of this project, Facilities will upgrade the cabs to meet current
standards for handicapped accessibility and computerize the
operating system to make it run more effectively.
-------
-3-
Comrauni cations
To provide a more effective method of promptly identifying
problem areas, the Facilities Management and Services Division is
restructuring its operations office so that each AA~ will have a
single contact point for these types of issues. Each
Assistant/Associate Administrator (AA) will be asked to designate
a liaison within his/her organization to act as the facilities
ombudsman to interact with. Facilities and the Health and Safety
Committee.
We are acutely aware of the challenges presented by this
building. Nonetheless, we are committed to carrying out Bill
Reilly's pledge to you to provide a safe and healthful work
environment. With your help and understanding, we will accomplish
this task.
Loree Murrayfl Charles L. Grizzle ££/ Robert Carton
President Assistant Administrator President
AFGE OARM • NFFE
-------
APPENDIX 3
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
OFFICE of
INISTRATIO
O RESOURCE
MANAGEMEN"
Honorable Barbara A. Mikulski
Chair, VA, HUD and Independent
Agencies Subcommittee
Committee on Appropriations
United States Senate
Washington, D. C. 20510
Dear Madam Chair:
This is the first in a series of reports you will be receiving
which highlight our efforts to provide our employees with a quality
working environment.
Attached is the Environmental Protection Agency's (EPA) plan
of action to remedy the concerns associated with the Waterside Mall
(WSM) complex. As you will note, the plan contains key milestones
which represent realistic time frames for completing major building
enhancements and modifications. We have been conservative in
estimating our start and completion dates, since we do not wish .to
create expectations which cannot be fulfilled. Also, we have taken
into consideration factors which could delay implementation.
Some of the problems associated with EPA's occupancy in WSM
are caused by overcrowding. We have been working with the General
Services Administration on this matter, and have been assured that
our space needs will be met. As a result of these meetings, we are
seeking to procure an additional 150,000 square feet of office
space in the Washington Metropolitan area. This space will be used
to house both new hires as well as to alleviate current
overcrowding.
Additionally, we have been working with the unions to gain
their input concerning building deficiencies and to share with then
our proposals for addressing these concerns. The enclosed plan
represents a joint venture between EPA management and the unions
to ensure that our Headquarters facility meets the highest building
standard.
-------
-2-
Your concern for the quality of Federal work space is
appreciated. I am sure that all of us working together can
ensure that EPA employees will be housed in a safe and healthy
facility. Your continued interest and support is welcomed.
Sincerely,
Charles L.'GrizzJo&y
Assistant Administrator
-------
U.S. ENVKKQ*
SCHEDULE OF
RL P1RDTECTION AGBO
^ IMPROVEMENT ACTIVITIES
ACTIVITY
START
DATE
OJMPLETION
DATE
COST
REMARKS
A. Voitilation Study
Contract with Engineering 11/01/89
Design Group for recommen-
dations to make HVAC systems
more effective
01/12/90
$60,000
2. Implement Study Recommen-
dations
01/15/90 unknown
unknown
Initial HV7C iro^stigation
completed
Cost and completion
date will not be known until
study is complete. We plan
to approach the project
in stages, improving
the worst areas first.
B. HVAC Modifications
1. Ex tend hours of HVAC 11/17/89
operation to start earlier
in the am and run longer
on Sunday
NA
$473,000
2. New Air Handling Unit
for rooms 3219 & 3404
3. New Air Handling Unit
for rooms 3009, 3242,
& parts of 3238
11/20/89 12/22/89
$50,000
12/11/89 01/16/90
$40,000
Increase in annual utilities
costs
Will add 2,500 cubic feet
per minute (CFM) of air
to the SW corner of the
3rd floor of the Mall
»
Will add 2,500 CFM of air
to the NW corner of the
3rd floor of the Mall
-------
-2-
ACTIVITY
START
DATE
COMPLETION
DATE
COST
REMARKS
B. HVAC Modifications (Cont.)
4. New Air Handling Unit
for rooms 3002, 3006,
3519, and part of 3020
5. Vent Copy Rooms at WSM,
Fairchild, and Crystal
directly outside
C. Remove Carpet and Tile Hotspots
1. Room 2003
2. Rooms 2821
3. Room 2809, 2811, & 2815
4. Room 2817
5. Rooms 2102 & S205
6. Room SE205
7. Schedule other rooms
and continue
02/01/90 02/28/90
03/01/90 until
completed
$45,000
$240,000(est)
12/09/89
12/15/89
01/05/90
01/12/90
01/19/90
01/26/90
02/03/90
12/10/89
12/18/89
01/08/90
01/15/90
01/22/90
01/29/90
ongoing
$7,000
$4,200
$10,800
$9,000
$2,200
$7,200
$330,000
Will add 2,500 CFM of air
to the NW corner of the
3rd floor of the Mall
24 copy centers at
$10,000 each
IMSD space, 1,500 sq ft
OSW space, 1,093 sq ft
OSW space, 2,662 sq ft
OSW space, 1,994 sq ft
OSW space, 600 sq ft
OSW space, 1,900 sq ft
approx. $4/ sq ft
-------
-3-
ACTIVITY
D. Elevator Overhaul
1. Replace door closure
mechanisms
2. Upgrade panels to meet
requirements for
handicapped employees
3. Computerize elevator
control mechanisms
E. Space Acquisition
1. Crystal City #1
2. Northeast Mall
Sub-basement
3. Crystal City #2
4. Additional space
F. Indoor Air Management Plan
1. Prepare Comprehensive
Indoor Air Management
Plan
START
DATE
01/02/90
01/02/90
12/07/90
02/01/90
COMPLETION
DATE
03/31/90
03/31/90
COST
RUWKKS
05/01/90 09/30/90
Request
Sent
01/01/89
08/26/88
Rent*
Begins
03/01/90
01/01/90
09/30/90
02/01/91
01/31/90
$90,000
$140,000
$600,000
Rent
$758,331 (FY90)
$1,300,000 (FY91)
$264,000 (FY90)
$352,000 (FY91)
$217,000 (FY90)
$1,300,000 (FY91)
East and West Tower
elevators
All elevators
East and West Tower
elevator banks. Requires
the awarding of a new
contract
50,000 sq ft for FIFRA
employees
16,000 sq ft for
Contractors RMD, NICT,
etc.
50,000 sq ft for
1990 growth
$933,000 (FY91) We've been working with
$1,400,000 (FY92) GSA to get additional space
to reduce overcrowding
$20,000
Currently meeting with
unions and preparing plan
* Occupancy gene tally occurs one month after rent begins to allow for Agency build-out,
-------
V*.
UNITED STATES ENVIRONMENTAL PR01LCTION AGENCY
WASHINGTON. D C. 20460
'f
,WN 2 6 1990
OFFICE OF
ADMINISTRATION
AND RESOURCES
Honorable Barbara A. Mikulski MANAGEMENT
Chair, VA, HUD, and Independent
Agencies Subcommittee
Committee on Appropriations
United States Senate
Washington, D. C. 20510
Dear Madam Chair:
Last month, I promised to provide you with regular reports
which highlight our efforts to provide EPA employees with a quality
work environment. This is the second of these reports.
During the last month, we completed the installation of the
first of the new air handling units and are nearing completion on
the second. Work to rebalance the air distribution in the larger
zone where the first unit was installed is ongoing. The carpet
removal, elevator upgrades, and the space acquisitions detailed in
our last report are on schedule and we have added additional rooms
for carpet removal to this month's schedule. We are also working
to award a large carpet removal and tile installation contract
which will allow us to accelerate this portion of the work. The
indoor air management plan will be completed as scheduled. Our
only disappointment was with the draft report on the ventilation
study. We have directed the engineering firm to perform additional
analyses and provide a more detailed report by the end of this
month.
We have been working with the unions on these issues and will
continue to meet and negotiate with them. As you might expect, we
are not always in total agreement. However, I believe we have the
same goals, and as we continue to talk and understand each other's
concerns the intensity of the situation will subside.
-If you have any questions regarding the enclosed schedule,
please call me on 382-4600 or have your staff call Rich Lemley,
Acting Director, Facilities Management and Services Division on
382-2030.
Sincerely,
Charles L. Grizzle
Assistant Administrator
Enclosure
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
SCHEDULE OF BUILDING IMPROVEMENT ACTIVITIES
ACTIVITY
A. Ventilation Study.
1. Contract with Engineer-
ing Design Group for
recommendations to make
HVAC systems more effec-
tive
Remarks:
Project delayed. Draft
report not acceptable.
Contractor directed to
perform additional analyses.
Next draft expected 1/26/90.
2. Implement Study Recommen-
dations.
Remarks:
Cost and completion date
will not be known until
study is complete. We
plan to approach the pro-
ject in stages, improving
the worst areas first.
New start date will be
1/29/90.
START
DATE
11/01/89
COMPLETION
DATE
01/12/90
COST
$60,000
01/15/90
Unknown
Unknown
-------
ACTIVITY
START
DATE
COMPLETION
DATE
COST
B. HVAC Modifications
1. Extend hours of HVAC 1/17/89
operation to start earlier
in the a.m. and run longer
on Sunday
Remarks:
Cost is annual increase in
utilities costs.
2. New Air Handling Unit 11/20/89
for Rooms 3219 & 3404
Remarks:
Completed
3. New Air Handling Unit 12/11/89
for Rooms 3009, 3242,
and parts of 3248
Remarks:
Project delayed. New
completion date is 1/30/80.
4. New Air Handling Unit 02/01/90
for rooms 3002, 3006,
3519, and part of 3020
Remarks:
Will add 2,500 CFM of air
in the NW corner of the third
floor of the Mall
5. Vent Copy Rooms at WSM, 03/01/90
Fairchild, and Crystal
directly outside
Remarks:
24 copy centers at $10,000
each. Cost proposal for
N.E. Mall received 1/17/90.
N/A
12/22/89
01/16/90
02/28/90
Until
Completed
$473,000
$ 50,000
$ 40,000
$ 45,000
$240,000
(Estimate)
-------
ACTIVITY
B. HVAC Modifications (Continued)
6. Relocate outside air
intake- to avoid exhaust
fumes-..
Remarks:
Completed. Building owner
corrected initial installa-
tion deficiency at no cost.
C. Remove Carpet and Tile Hotspots
1. Room 2003
2. Room 2821
3. Rooms 2809, 2811, & 2815
4. Room 2817
5. Room 2102
6. -Room SE205 and part, of 2101
7. Rooms 3225 & 3410
8. Room SE225
9. Room SE226
10. Room SE273
11. Room SE 274
12. Room 3006
13. Schedule other rooms
Remarks•
Items 1-5 completed.
6. OSW space, 1,900 sq. ft.
7. OCEM space 1,700 sq. ft.
8. OERR space 1,200 sq. ft.
II II f\f\ft fmrf
9.
10.
11.
n
n
it
n
n
it
900 sq,
1,000 sq.
600 sq.
800 sq.
ft,
ft.
ft,
12. OPPE space 800 sq. ft
13. Approximate $4 sq. foot
START
DATE
01/02/90
12/09/89
12/15/89
01/05/90
01/12/90
01/19/90
02/02/90
02/09/90
02/16/90
02/23/90
03/02/90
03/09/90
03/16/90
COMPLETION
DATE
01/16/90
12/10/89
12/18/89
01/08/90
01/15/90
01/22/90
02/05/90
02/12/90
02/19/90
02/26/90
03/05/90
03/12/90
03/19/90
ongoing
COST
None
$ 7,000
$ 4,200
$ 10,800
$ 9,000
2,200
7,200
r
$
$
$
$ o
$ 3,oOO
4,000
2,400
$ 3,200
$300,000
$
$
-------
ACTIVITY
Elevator Overhaul
1
E.
Replace door closure
mechanisms- East and
West Towers
Upgrade panels to meet
requirements for handi-
capped employees - All
elevators
Computerize elevator
control mechanisms -
East and West Towers
START
DATE
01/02/90
01/02/90
05/01/90
Remarks:
1.
Two elevator cabs in
the West Tower and one
in-the East Tower have
been completed.
Start date delayed but
completion still expected
for 3/31/90.
Requires the awarding
of a new contract.
Space Acquisition
1. Crystal City #1
2. Northeast Mall
Sub-basement
3. Crystal City #2
4. Additional Space
Remarks:
1. 65,000 sq. ft,
available starting
4/1/90
2. 16,000 sq. ft.
available 2/1/90
Request
Sent
01/01/89
08/26/88
12/07/90
02/01/90
COMPLETION
DATE
03/31/90
03/31/90
09/30/90
Rent*
Begins
03/01/90
01/01/90
09/30/90
02/01/91
COST
$ 90,000
$140,000
$600,000
Rent
$ 758,331-
$1,300,000-
$ 264,000-
$ 352,000-
$ 217,000-
$1,400,000-
$ 933,000-
$1,400,000-
FY90
FY91
FY90
FY91
FY90
FY91
FY91
FY92
-------
START COMPLETION
ACTIVITY DATE DATE COST
E. Space Acquisition (Continued)
Remarks:
3. 50,000 sq. ft. for
199'0 growth
4. Space request to GSA
to reduce overcrowding
* Rent usually begins one month before occupancy.
F. Indoor Air Management Plan
1. Prepare Comprehensive 01/31/90 $ 20,000
Indoor Air Management
Plan
Remarks s
Meeting with Unions to
discuss draft.
-------
UNITRD STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON. D.C. 20460
FEB 27 1990
OFFICE OF
ADMINISTRATION
AND RESOURCES
MANAGEMENT
Honorable Barbara A. Mikulski
Chair, VA, HUD, and Independent
Agencies Subcommittee
Committee on Appropriations
United States Senate
Washington, D.C. 20510
Dear Madam Chair:
Enclosed is our February report on efforts to provide EPA
employees with a quality work environment.
During the last month, we completed the Indoor Air Management
Plan and received the report from our contract engineers containing
recommendations for enhancing indoor air quality at Waterside Mall,
Both of these items are discussed further below. The installation
of the second of the new air handling units was completed and
although initiation of the installation of the third unit was
delayed, the work is now progressing nicely. We are actually a
little ahead of our schedule for carpet removal, having removed
over 25,000 square feet of carpet and replaced it with vinyl tile
from November through last weekend. As can be seen on the attached
schedule, we are also on track on the elevator upgrades and space
acquisition.
As we indicated last month, we have been meeting regularly
with both our unions on the development of our Indoor Air
Management Plan. The National Federation of Federal Employees,
declined to approve the plan because it did not state that we would
remove all carpet from our headquarters buildings. Previously,
they had only requested removal of the carpet which was installed
in the fall of 1987 and spring of 1988. However, even while these
discussions continue, we are proceeding to implement the plan. We
will keep you advised of the status of our discussions with the
unions.
-------
As stated above, we now have the ventilation study report.
The findings and recommendations contained in it do not point to
a single, cause or cure for our problems. However, upon discussions
with several indoor air experts, we understand that this is most
often the case. The problems in our buildings did not crop up
overnight from a single cause—and they will not be solved with a
single fix. The solutions to our situation lie in the completion
of the tasks listed in our schedule, as well as the implementation
of the recommendations in the report and the methods and procedures
in our Indoor Air Management Plan. We are proceeding accordingly.
As tasks and dates become firm, these will be added to our
schedule.
If you have any questions, or if you would like to see a copy
of our Indoor Air Management Plan, please do not hesitate to call
me.
Sincerely,
/ /-
/"^Charles L. Grizzle
/ /^Assistant Administrator
Enclosure
-------
U.S. ENVIRONMENTAL PROTECTION AGENCY
SCHEDULE OF BUILDING IMPROVEMENT ACTIVITIES
ACTIVITY
A. Ventilation Study
1. Contract with Engineer-
ing Design Group for
recommendations to make
HVAC systems more effec-
tive
Remarks: Draft report
received. -Recommendations
include increasing minimum
outside air mix to 20%,
cleaning of ducts, direct
exhausting of copy
centers, and enhancing
filtration.
START
DATE
11/01/89
COMPLETION
DATE
01/26/90
COST
$60,000
2. Implement Study Recommen-
dations.
Remarks: We have begun dis-
cussions with our contracts
office to determine the
quickest strategy for imple-
mentation. _As dates and costs
are established, they will be
reflected. Copy center
exhausting work has begun and
is reflected under a new sub-
heading G.
01/29/90
Unknown
Unknown
-------
ACTIVITY
START
DATE
COMPLETION
DATE
COST
B. HVAC Modifications
1. Extend hours of HVAC 1/17/89
operation to start earlier
in the a.m. and run longer
on Sunday
Remarks: Cost is annual
increase in utilities costs.
2. New Air Handling Unit 11/20/89
for Rooms 3219 & 3404
Remarks: Completed
N/A
12/22/89
$473,000
$ 50,000
3. New Air Handling Unit
for Rooms 3009, 3242,
and parts of 3248
Remarks: Completed
4. New Air Handling Unit
for rooms 3002, 3006,
3519, and part of 3020
Remarks: Project delayed
while new mechanical room
to house air handling unit
is constructed. New sched-
uled completion date is
03/30/90.
5. Relocate outside air
intake to avoid exhaust
fumes.
12/11/89
01/30/90
02/01/90
02/28/90
$ 40,000
$ 45,000
01/02/90
01/16/90
None
Remarks: Completed. Building
owner corrected initial installa-
tion deficiency at no cost.
-------
ACTIVITY
START
DATE
COMPLETION
DATE
COST
C. Remove Carpet and Tile Hotspots
1. Room 2003 12/09/89
2. Room 2821 12/15/89
3. Rooms 2809, 2811, & 2815 01/05/90
4. Room 2817 01/12/90
5. Room 2102 01/19/90
6. Room SE205 and part of 2101 02/02/90
7. Rooms 3225 & 3410 02/09/90
8. Room SE225 02/16/90
9. Room SE226 02/16/90
10. Room SE273 02/23/90
11. Room SE274 02/23/90
12. Room 3241 03/02/90
13. Rooms SE256 and 264E 03/09/90
14. Room 3103-13 03/16/90
15. Room 3006 03/23/90
16. Schedule other rooms
12/10/89
12/18/89
01/08/90
01/15/90
01/22/90
02/05/90
02/12/90
02/19/90
02/19/90
02/26/90
02/26/90
03/05/90
03/12/90
03/19/90
03/26/90
Ongoing
$
$
7,000
4,200
$ 10,800
$ 9,000
2,200
7,200
6,800
4,800
3,600
4,000
2,400
$ 3,200
$300/000
Remarks:
Items 1-11 completed.
Removed approximately 25,000
square feet to date.
-------
ACTIVITY
START
DATE
01/02/90
03/01/90
Elevator Overhaul
1., Replace door closure
mechanisms
2. Upgrade panels to.meet
requirements for handi-
capped, employees - All
elevators
3. Install electric eyes on
on all elevators
4. Computerize elevator
control mechanisms -
East and West Towers
Remarks:
1. Door mechanisms on all four cars
in East Tower have been replaced;
cars 1 and 2 in West Tower complete.
2. Awaiting arrival of parts to begin work.
3. Same as 2 above.
4. Requires awarding of new
contract.
Space Acquisition
1. Crystal City #1
2. l.'ortheast Mall
Sub-basement
3. Crystal City #2
4. Additional Space
Remarks:
1. 65,000 sq. ft,
available starting
5/1/90
2. 16,000 sq. ft. occupied
2/16/90
Request
Sent
01/01/89
08/26/88
12/07/90
02/01/90
COMPLETION
DATE
03/31/90
04/14/90
Rent*
Begins
04/01/90
02/01/90
09/30/90
02/01/91
COST
$ 90,000
$140,000
03/01/90
05/01/90
04/15/90
09/30/90
$ 52,386
$600,000
-------
ACTIVITY
START
DATE
COMPLETION
DATE
COST
E. Space Acquisition (Continued)
Remarks:
3. 50,000 sq. ft. for
1990 growth
4. Space request to GSA
to reduce overcrowding
* Rent usually begins one month before occupancy.
F. Indoor Air Management Plan
1. Prepare Comprehensive
Indoor Air Management
Plan
01/31/90 $ . 20,000
Remarks: Completed.
with unions.
Negotiating
6. Copy Center Exhausting
1. Main Mall Copy Center 02/20/80
Room 3501
Remarks: Will exhaust
toner, paper dust and
heat directly outside
2. Northeast Mall Copy 02/26/90
Centers - Rooms 107,206,
and 320
Remarks: Will exhaust t.cr,:r,
paper oust and heat uiiu^ciy
outside.
3. Southeast Mall Copy 03/05/90
Centers - Rooms 216 and
310
Remarks: Will exhaust toner,
paper dust and heat directly
outside.
03/09/90 $ 9,780
03/16/90 $ 27,380
03/30/90 $ 23,340
-------
ACTIVITY
START
DATE
COMPLETION
DATE COST
G. Copy Center Exhausting (Continued)
4. Award contracts for other 03/01/90
copy centers
Remarks: 24 copy centers
in total, 18 left to do.
Estimated at $10,000 each
Until $ 180,000
Completed
-------
Exhibit ES-2:
! Iraployee Survey
EPA Headquarters
Percent or All Respondents Who Had Symptoms ORen or Always Last Year that
Got Better Upon Leaving Work, by EPA Headquarters Building and by Group of
Symptoms
SYMPTOM
Indoor Air Quality Symptoms
Headache
Runny nose
Stuffy nose/sinus congestion
Dry, itching, or tearing eyes
Burning eyes
Dry throat
Unusual fatigue or tiredness
Sleepiness or drowsiness
Respiratory or Ru-lOce Symptoms
Cough
Wheezing or whistling in chest
Shortness of breath
Chest tightness
Fever
Aching muscles or joints
Erconomic Symptoms
Pain or stiffness in upper back
Pain or stiffness in lower back
Pain or numbness in shoulder/neck
Pain or numbness in hands or wnsts
BUILDING
WATERSIDE
MALL
16%
8%
16%
17%
10%
10%
15%
15%
4%
1%
2%
2%
1%
4%
6%
6%
6%
2%
CRYSTAL
MALL
11%
9%
17%
12%
8%
7%
14%
19%
5%
1%
1%
1%
1%
4%
6%
6%
5%
2%
FAIRCHILD
16%
7%
15%
15%
11%
9%
11%
13%
4%
2%
2%
2%
'0%
2%
6%
4%
5%
2%
Reference: Part II. Question 7.
ES-6
-------
vuiuiiic i i .iii[ii»yi:i:
EPA Headquarters
5-3: Percent of All Respondents Who Had Symptoms Often or Always Last Year and that
Got Better Upon Leaving Work, by Sector in Waterside Mall
SYMPTOM
: Headache
i Nausea
Runny nose
Stuffy oose/sinus congestion
^-.p^jring
Cough:
Wheezing or whistling in chest
Shortness of breath
I _._ «i_i_^_
i ([jncst tffiutness
irjryi ifrfrmg_ or tearing eyes
Sore/strained eyes
Blurry/double vision
burning eyes
re throat
Hoarseness
Dry throat
rjonsoal fatigue or tiredness
Sleepiness or drowsiness
; Chills,
i Fever
Aching muscles or joints
: Problems with contact lenses*
Difficulty remembering things
Bizaaess/lightheadedness
Feeling depressed
Tension or nervousness
Difficulty concentrating
Dry or itchy skin
P'ain or stiffness in upper back
Pain- or stiffness in lower back
Pain or numbness in shoulder/neck
Pain or numbness in hands or wrists
WATERSIDE MALL SECTOR
EAST
TOWER
14%
1%
1%
15%
6%
4%
1%
1%
1%
14%
15%
4%
9%
3%
3%
8%
12%
13%
2%
4%
3%
24%
2%
3%
5%
9%
6%
6%
4%
4%
4%
2%
WEST
TOWER
13%
1%
9%
13%
7%
5%
1%
2%
1%
15%
14%
4%
10%
3%
3%
9%
15%
14%
5%
0%
4%
25%
2%
2%
5%
10%
6%
6%
8%
7%
5%
2%
MALL
2ND FLOOR
18%
1%
9%
16%
7%
6%
1%
3%
3%
21%
22%
7%
13%
7%
5%
15%
17%
18%
5%
0%
5%
45%
3%
5%
4%
12%
10%
8%
5%
4%
6%
4%
MALL
3RD FLOOR
19%
2%
10%
21%
8%
6%
2%
3%
2%
18%
18%
3%
11%
5%
3%
12%
17%
17%
5%
1%
5%
38%
3%
4%
5%
10%
10%
8%
7%
6^0
7^c
2%
NE
MALL
16%
2%
8%
16%
7%
4%
1%
3%
2%
13%
14%
3%
9%
3%
2%
8%
12%
14%
6%
1%
4%
31%
3%
3%
6%
9%
6%
6%
6%
7%
6%
\%
SE
MALL
18%
14%
8%
16%
6%
2%
2%
2%
2%
20%
19%
3%
10%
9%
4%
14%
15%
20%
4%
5%
6%
29%
1%
4%
5%
12%
10%
5%
4%
6%
4%
2%
3e percentages are *3ased upon only the people who wear contact lenses at work 'sometimes, often or always" (Pan II. Question
i. i* opposed to aH respondents in the budding.
Reference P:irt II, Question 7.
-------
EPA Headquarters
Exhibit 5-9: Number and Percentage or Responding Employees Indicating Impact of Symptoms on
Ability to Work Last Year, by EPA Headquarters Building
Symptoms Reduced
Ability to Work
Waterside Mall
Crystal Mall
Fairchild
Symptoms Resulted
In Staying Home or
Leaving Work Early
Waterside Mall
Crystal Mall
Fairchild
NUMBER
2,999
430
393
2,967
429
387
PERCENT RESPONDING
NEVER
32%
32%
38%
44%
46%
50%
RARELY
32%
31%
34%
30%
28%
28%
SOMETIMES
29%
31%
23%
23%
22%
21%
OFTEN
6%
6%
4%
2%
3%
1%
ALWAYS
1%
1%
1%
•
•
•
'Always' was not a possible answer in Question 9.
Reference: Part II, Questions 8 and 9.
5-19
-------
Volume I: Emplovec Survcv
EPA Headquarters
Exhibit 5-10: Percentage of Responding Employees Associating Symptoms with Building Last Year, by
EPA Headquarters Building
WATERSIDE MALL CRYSTAL MALL
FAIRCHILD
Percent Associating
Symptoms with Building
62%
56%
49%
Symptoms Improved
over the Last Year
11%
8%
8%
Symptoms became Worse
over the Last Year
29%
26%
24%
Symptoms Remained
the Same
60%
66%
68%
Employees Responding
2,922
418
379
Reference: Part II, Question 11.
5-21
-------
Exhibit 5-12:
Volume I- Employee Survev
EPA Headquarters
Percent of Responding Employees Reporting Increased Frequency and Duration
or Infection Since Beginning Work at Building
Percent Having Infections:
More Frequently
Less Frequently
Same Frequency
Employees Responding
Percent Whose Infections:
Last Longer
Last Shorter
Last the Same
Employees Responding
BUILDING
WATERSIDE
MALL
39%
5%
56%
2,989
36%
3%
61%
2,935
CRYSTAL
MALL
31%
7%
62%
433
31%
4%
65%
428
i
FAJRCHILD
23%
9%
67%
396
23%
4%
72%
382
"Infections" refer to colds, flu, bronchitis, etc.
Reference: Part II, Question 17.
5-24
-------
& The University ol Arizona
>™ i *
"CGI " "'}• i'lK>
i"" 5" irr;
. ^^
Occu5a-.onai Sa'e-v anr; Kc-ai'i p ^.O 6 ""
Mecca Technology
y 31, 1
Jeff Davidson. PhD
Section Chief
Existing Chemical Assistance Group
Division Office of Toxic Substances
U.S. Environmental Protection Agency, Mail Code TS-778
East Tower 409
401 M St., SW
Washington, DC 20460
Dear Dr. Davidson:
. I appreciate the opportunity to be of assistance to the
U.S. Environmental Protection Agency, Office of Toxic
Substances, in evaluating several matters relating to indoor
air pollution including an episode of building related
illness at EPA headquarters at Waterside Mall in Washington,
DC as well as a citizen's petition regarding "Control of Risk
Associated With Certain Carpeting." Since the indoor air
pollution episode at Waterside Mall precipitated the
citizen's petition which relies, to a considerable extent,
upon research conducted at the University of Arizona, School
of Health Related Professions, Tucson, Arizona, the
interpretation of pertinent data in that petition and our
experience with indoor air pollution situations may be of
value to your office in addressing issues in the petition.
In July of 1988, I was requested by Mr. David Weitznan,
CIH. Industrial Hygiene Programs Manager with the U.S. EPA to
provide a scientific seminar on indoor air quality to EPA
employees at the Waterside Mall faculty. At the same time, I
conducted a walk-through survey of various office areas
whare specific individuals had reported a variety of symptoms
Ccllowing the initiation of renovation activities in October
of 1937. including the installation of new carpet.
This survey revealed rnau the- office renovation program
installation of carpeting, divider partitions and
office furnishings. The nylor pile carpet, _n most areas,
:isd been installed with a f^i-r-c^.-: wadding, whereas in hign
traffic a:cds, vhc carper '.n>; A.-.S . ::^t.-.llcd with adnesivcs.
Other facility improvements .:.-•! :dcd cleaning and paintinq.
-------
.'ne pr until1/ c:c"iOi.ai;i •_ j ox.pur ^o.'ic. u-d cy '••_i:"-ci^:: ornpioyocs
- n •-J-dca vyc aia ndiSdi ^rr itrit:ijn, nsiujcsi. ncjcichcs and 3k4.ri
»• a sr.es. Interestingly, thcue ^ynproms aro characteristic of
r.hose reported *n otnci cases ci cuildir.g-related illness and
ridvc; been associated with a variety of indoor air pollutants
including chemical and biological agents. In other indoor
-i-r toil-tioii scenarios, r»o suspect source or agent has ocen
L.ic-Tir i £ied.
Over the past ten years I have had the opportunity to
evaluate numerous cases of building-related illness in homes,
office workplaces and schools. Although the source of the
problem was frequently linked to an offending agent or source
of which there were many, interestingly the symptoms
expressed by affected individuals in this environment were
quite s'imilar to those described by certain individuals at
the EPA. This observation of commonality in symptomatology
with multiple causes indicates that when a variety of
pollutant sources contribute to an indoor episode, stating
that a causal relationship exists between just one agent and
the onset of health problems is difficult, if not impossible.
This particular point was expressed at the seminar I
presented to the employees at EPA headquarters. The myriad
of compounds introduced into the air of the EPA facility
during the course of the renovation would preclude
establishing an association between any one compound and the
onset of health problems in certain individuals. My
experience in evaluating such episodes reveals that several
of the materials employed during renovation activities at the
EPA could have -potentially contributed to the onset of ..
problems in some individuals. These materials include paint,
carpet adhesive, particle board based furniture and certain
carpets. In practice, I have'questioned an association
between these individual materials-and the onset of the
"tight building" syndrome, although no specific chemical
agent was targeted as causative. The air quality of the EPA
facility was certainly further compromised by inadequate
ventilation in certain areas as well as the presence of the
odor of mold in some stairwells which could be indicative of
potential biological problems.
The citizens' petition submitted by the National
Federation of Federal Employees (NFFE) seeks to protect its
members and the public from potentially injurious agents.
Unfortunately, the petition focjses almost entirely on the
compound, 4-phenylcyclohexene (4-PCH), a known by-product
produced in the manufacture c: carboxylated styrene-butadienc
rubcer (5BR) latex employed ro adhere the secondary carpet
beicking to the carpet tuft. :~\ research at tne University of
Arizona, 4-PCH was discoveroc ~.o bo a unique and odifcrous
r:cnnpounc comnon to many SBr-r- ••.•-•"- carpets and, therefore,
of f ;rtner roses:""
-------
'*: /M 1'^or.a riccivcc a number o: CdlLb i i -:~i .-ono-k-a:iLo
Lhc general public pertaining to new 'jarpct odor -i:-> well cis
rrq'.icbtis tor analysis. IP. many instances, r.o 4-PCH w«s
dore::tcd in carpet samples suomittcd for analysis; in ocvcral
-^scs, Lhe adhesive employed to glue down the carpets, rather
• hrin t-hc- carper, itself, was found to be particularly
of f CMS i'":. In other instances, carpeting several years old
was cited ss a cause of ill-health althougn this situation
was not consistent with our observation that only some new
carpets contribute to an odor problem.
As health specialists and toxicologists, we appreciate
that most health effects are dose-dependent and. at the same
time, there are varying degrees of susceptibility within the
population. These concepts are applicable to 4-PCH as well
as other chemicals. Recent studies aimed at elucidating the
acute toxicity cf 4-PCH, with which you are familiar, reveal
a compound that Is not particularly toxic. At the same_time,
animal inhalation studies at concentrations several orders of
magnitude greater (16,000 ppb to 60,000 ppb) than those
levels experienced by the public following installation of
new carpet (4 ppb to 50 ppb), .demonstrated no indication of
irritant effects. Although the results of animal studies
cannot be directly extrapolated to humans, this information
suggests that 4-PCH should not serve as a irritant, at least
for the majority of the public. . It is also noteworthy -that
our indoor measurements of 4-PCH levels suggest that only
higher initial levels (greater than 5 ppb) may be associated
with possible health effects. A review of the EPA Task Force
study of t'-e indoor air quality authored by Highsmith et al
(July 7, i 38) revealed 4-PCH levels of only 1.5 ppb in a
newly renovated mall office, with lower levels measured
elsewhere. Based on our experience, such levels are below
those measured in "problem" environments.
With regard to the issue of multiple chemical
sensitivity (MCS), I would agree with the petitioner that
evidence of an association with 4-PCH is lacking. In the
medical community, MCS is a controversial issue. Having had
the opportunity to assist medical toxicologists and other
physicians in evaluating such cases, I can relate that
numerous types of exposures have been linked to the onset of
such a syndrome.
The issue of indoor air pollution is a complex one that
deserves tne attention of our health community. I share with
the petitioner his concerns regarding the EPA episode of
•ouildi:icj-r°latcd illness. The causels) of this illness,
however, are difficult to rosoivo on the basis of our currcr.t
I'.vcl of kr.owlodge rogardir.u rho offccrs of low level
•j'-'nrd.tiip.ar.rs on human hcaltr.. The presence of 4-PCH -it
ocii't ocular ly low level:; durirj '.nc period of tnc renovation
i'. EPA, ':o-pled ^i.th the faor tna*. so nany other factors
-------
.ndo-r j.illution b Ltudt ion3, romj^.^^ on'j to 'jonoi^'lo that no
5-.11LC ^?cnt can be Mnrjlo'i o.- ai -iav..r,g ca ^e-a tnc cpisocc
0/_-r the pAsr. several ycs.rs, I nave cncc-Jiaged the S5R
latcix jr.d carpet rnanufacturinc; industry to explore -"GLhods to
reduce1 tne level of voldtile organic compounds (VOGs),
including 4-PCH, from their products. Both Lndustry groups
have responded, even in the absence of definitive data that
demonstrates a causal relationship between 4-PCH or other
products and the onset of health prcbiezns, ay supporting
research at the University of Arizona and elsewhere, to
alleviate potential problems with their products. Based upon
research efforts to date, I would expect that the level of 4-
?CH and other VOCs in carpet should significantly decrease.
- As professionals interested in the health_of the public,
I can assure you that we will continue to investigate
situations relevant to indoor air pollution. I would
encourage your office to support additional research which
will help elucidate the causes of indoor air pollution and
methods for their control.
" If I can be of further assistance, please-do not
hesitate to call.
Sincerely, £
Mark Van Ert, PhD
Director, Occupational Safety
and Health Program
-------
APPENDIX '•>
Revised: March 26, 1990
Attachment A
WORK STATEMENT
PURPOSE;
It is the intention of the US EPA Headquarters Operations to
have the Town Center Management Corporation secure all labor,
material, equipment, and supervision for the thorough and
complete cleaning of heating, ventilating, and air conditioning
(HVAC) systems servicing the EPA within spaces that it leases at
the Waterside Mall complex in Washington, D.C.
KEY EPA PERSONNEL;
Title Name/Address Responsibility
Project Officer Jim Engleka Overall Project
EHSD Management
401 M St., SW
Washington, DC
20460
(202) .382-3640
Contracting Officer xxxx xxxx
GENERAL DESCRIPTION;
1. Independently, and not as an agent of the United States
government, the contractor shall furnish to the Town Center
Management Corporation all labor, materials and equipment
required to power brush and vacuum clean (and/or steam
clean, as needed) all of the HVAC systems servicing the EPA
at Waterside Mall. Such cleaning is to effect the removal of
dirt, dust, mold, and other contaminants from the HVAC
systems. It is the intent of this Statement of Work that the
meaning of the term heating, ventilating and air-
conditioning (HVAC) systems as used herein includes: heating
and cooling coils, reheat coils, filters, housings, air
supply and return chambers and plenums, make-up air ducts,
motors, fans, deflectors, dampers, baffles, drain pans,
blower wheels, return air ducts and air supply ducts.
-------
2. All work shall be performed by the Contractor in accordance
with accepted industry standards. Monitoring of the
Contractor's performance of work may be conducted without
notice to the Contractor, and at any time, by EPA
representatives designated by the Contracting Officer.
Additionally, the affected HVAC systems may be inspected at
any reasonable time during the performance of this cleaning
work by EPA representatives designated by the Contracting .
Officer. Representatives of the Town Center Management
Corporation may elect to be present during such monitoring
and/or inspections; the EPA will advise the Town Center
Management Corporation in advance of its intent to conduct
monitoring and/or inspections.
3. The Contractor must not change, alter, damage or modify the
mechanical, electrical, pneumatic or other components
of the HVAC system. However, the contractor may cut
access openings in sheet metal ducts as needed to
facilitate cleaning. The Contractor shall use the same
gauge sheet metal as the original construction to cover
access openings. Such openings shall be securely sealed
with permanent gasketing material and fastened in place
with screws to insure against subsequent air leakage.
If dampers or other components of the system must be.
moved by the Contractor in order to effect proper
cleaning, they must be returned to their proper
position by the Contractor prior to the start of the
following EPA business day. Any damage, accidents, or
incidents that occur during the performance of work
must be immediately reported verbally and in writing to
the Town Center Management Corporation and to the EPA.
The Contractor is also requested to promptly notify
Town Center Management Corporation and the EPA of any
problems or deficiencies noted concerning the HVAC
systems.
4. The Contractor shall take appropriate steps to prevent the
dissemination of dust, dirt, and other contaminants within
the building during the performance of work. Prior to
cleaning any ductwork, it shall first be placed under
negative pressure with respect to surrounding spaces. A
vacuum system shall be used in this regard which shall be
arranged to capture debris and contaminants and to ensure
maximum cleaning efficiency and results. All debris and
contaminants collected during the cleaning process shall be
discarded into appropriate collection containers outside of
the building. The Contractor is responsible for properly
disposing of all collected dust and dirt, as well as debris
and wastes, off of the premises.
-------
The Contractor shall take appropriate measures to prevent
the disturbance of, or damage to, asbestos containing
building materials; the Contractor shall take necessary
action to prevent the release of asbestos fibers into
the air. Special attention is called to the asbestos
areas located on the second ..floor of the Mall.
Information about the location of asbestos containing
building materials that are, or likely to be, in the
Contractor's work areas shall be provided to the
Contractor by the Town Center Management Corporation.
[This includes ceiling tiles, if any.] The Project
Officer may arrange for an Asbestos Monitor to be
present to observe the Contractor's work in certain
locations where such surveillance is indicated by the
EPA Headquarters asbestos management plans. If any
asbestos containing building materials are disturbed or
damaged, the Contractor must immediately notify the
Town Center Management Corporation and the Project
Officer. The Contractor is fully responsible for
complying with all applicable asbestos related
regulations.
The contractor shall use drop cloths or other
appropriate means to protect office furniture,
fixtures, and equipment from dust and other
contaminants. Floors, floor coverings and other
surfaces within EPA work areas shall be immediately
cleaned if dirtied or soiled by the Contractor.
5. The Contractor shall use electric augured rope brushes, or
equivalent means, to clean the interior of ductwork.
If cleaning is required prior to the removal of
insulation lining the ductwork, portable shakers, or
equivalent means, may be used.
6. The Contractor shall remove from the interior of HVAC
systems all fiberglass and other fibrous or porous
sound insulating materials capable of trapping dust,
dirt, or other particulate contaminants. Such
insulating materials shall be replaced by the
Contractor using methods and materials approved in
advance by both the EPA and Town Center Management
Company. Replacement sound insulation shall be a non-
fibrous type that has extremely low potential for
trapping and retaining dust, dirt, and other
contaminants.
7. The Contractor shall use only methods and materials approved
in advance by the EPA and the Town Center Management
Corporation. Methods or materials may only be changed
with the written permission of the EPA and the Town
Center Management Corporation.
8. The Contractor shall adhere to at least the following
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cleaning methods for ductwork, which represent the minimum
approach acceptable to the EPA. However, more efficient
methods may be used, provided the cost of performing such
alternative methods do not add to the cost of the contract.
If alternative methods are to be used, advance approval from
the EPA and the Town Center Management Corporation must be
obtained by the Contractor.
RETURN AIR DUCTWORK -
A. the Contractor shall remove, wash, and clean return air
grills. Upon removal, such grills shall be covered
with plastic bags and taken to the loading dock area
outside of the building for washing and cleaning;
B. the Contractor shall connect a portable vacuum to the
most remote point of the return air duct system, to
place it under negative pressure;
C. the Contractor shall clean the interiors of the
individual ducts starting from the main trunk down to
the return openings in the individual rooms;
D. this process shall be repeated for each room serviced
by the individual HVAC system before cleaning the
associated horizontal main return trunk line;
E. the Contractor shall reinstall all return grills;
F. where possible, the interiors of the main return lines
shall be cleaned by individuals within the duct line.
SUPPLY DUCTWORK -
A. Since there may be reheat coils in runouts, the
horizontal sections of runouts shall be vacuumed
prior to vacuuming of the vertical sections;
B. the main trunk supply lines shall be cleaned out prior
to the supply runouts;
C. the supply diffuser grills shall be removed, cleaned
and washed. Upon removal, the grills shall be covered
with plastic bags and taken to the loading dock area
outside of the building for washing and cleaning;
D. vacuum shall be applied to appropriate points of the
ductwork during cleaning and power brushing;
F. filter media shall be temporarily installed immediately
upstream of the supply air diffusers to prevent the .
dissemination of residual particulates into workspaces
when the air handling unit is turned on. The filter
media shall remain in the system for a period of 24
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hours after cleaning while the AHU operates. The
contractor shall follow-up 24 hours later to remove
filter media;
H. the contractor shall reinstall supply air diffusers
after the filter media is removed.
9. The Contractor shall thoroughly clean the interiors of all
return air chambers and plenums.
RETURN AIR PLENUMS AND CHAMBERS -
A. All surfaces within return air chambers and above-the-
ceiling plenums shall be thoroughly cleaned.
Where such plenums are separated from work
areas by suspended acoustic ceiling tiles,
the upper surfaces of ceiling tiles shall be
vacuum cleaned;
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B. the Contractor shall promptly notify the designated
representatives of the EPA and the Town
Center Management Corporation whenever
acoustic ceiling tiles are damaged or broken/
so that replacements can be promptly
installed by the Contractor. A stock of
replacement tiles shall be maintained by the
EPA and/or the Town Center Management
Corporation for use by the Contractor.
Damaged or broken acoustic ceiling tiles, up
to 1% of the total number of tiles cleaned,
shall be provided to the Contractor at no
cost to the Contractor. The Contractor shall
be responsible for replacing at. his/her own
expense all tiles damaged or broken in excess
of 1% of the total number of tiles cleaned.
Submittals;
Not later than fifteen (15) business days prior to the
initiation of work under this contract, the Contractor shall
submit a brief history of comparable work previously performed
together with a list of at least three (3) local references to
the Town Center Management Corporation and the EPA Contracting
Officer. (The name and address of the referenced company and the
name of a contact person with phone number must be included.)
Prior to the initiation of work under this contract, the
Contractor shall meet for one hour with the members of the EPA's
Indoor Air Quality Subcommittee, at a time and place convenient
to all parties. The purpose of this meeting is to facilitate a
labor/management interview of the Contractor, and to provide an
opportunity for a dialogue between the Contractor and the NFFE
and AFGE Unions.
Not later than ten (10) working days prior to the initiation
of work under this contract, the Contractor shall submit to the
EPA Project Officer a written statement detailing all of the
methods and materials proposed for use, including Material Safety
Data Sheets (MSDS) for chemicals proposed for use. The EPA
Project Officer shall review the methods and materials proposed
for use by the Contractor, within five working days of receipt.
The EPA Project Officer shall then advise the Contracting'
Officer, the Town Center Management Corporation, and the
Contractor in writing as to their acceptability. In the event any
method(s) or material(s) are determined by the EPA to be
unacceptable, the Contractor shall make appropriate modifications
acceptable to the EPA.
Coordination and Scheduling;
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Contractor shall perform w^rk within the building only
between the hours of 5:00 pm and 6:30 am. All EPA occupied spaces
and Contractor work areas shall be left clean at the end of each
Contractor work day. The HVAC units that have been cleaned each
night by the Contractor shall be left in operable condition for
use beginning on the following EPA work day. The Town Center
Management Corporation will make every effort to start each.
cleaned HVAC unit as soon as possible after the Contractor's work
is completed. Each unit should then be run for a period of at
least two hours prior to reoccupancy of the affected work areas
by EPA employees.
The EPA's Facilities Management and Services Division (FMSD)
is responsible for coordinating, through the Environmental Safety
and Health Division (EHSD) Project Officer, those security and
internal' housekeeping matters that may arise during the course of
work under this contract.
The Contractor's work shall be conducted in three separate
phases, and conducted in concert with the EPA's "Operation
Cleansweep" efforts. The EPA's management and staff are
undertaking a comprehensive cleaning of their work areas
beginning on "EARTH DAY" - April 22, 1990. Following the EPA's
own cleanup of its work areas beginning on this date, HVAC system
cleaning can commence. The Contractor shall perform HVAC system
cleaning in accordance with the following schedule:
1) the "Hall" systems - beginning on June 4,
1990, after completion of EPA's "Operation
Cleansweep" activities in this area;
2) the "West Tower" systems - beginning on June
18, 1990, after completion of EPA's "Operation
Cleansweep" activities in this area;
3) the "East Tower" systems - beginning on July 2,
1990, after completion of EPA's "Operation
Cleansweep" activities in this area.
Competitive Technical Evaluation Criteria:
Contractor selection will be based on the technical quality
of cleaning methods and materials proposed, and upon verification
of satisfactory past performance. Contractor selection shall not
be exclusively based on cost considerations.
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Reports Required and Description:
The Contractor shall submit, on a daily basis, a written
report to the Project Officer concerning status of work
performed, any deficiencies, and any problems preventi-ng
execution of daily work. Additional information must be included
in such reports, as described previously in this Statement of
Work (e.g., damage to EPA or TCM property, incidents, accidents,
or problems or deficiencies involving the HVAC system that are
noted)..
Recommended- Sources List;
Riteway
Pritz
Environmental and Safety Reo/uirements!
Contractor shall comply with all District of Columbia and
Federal fire, occupational safety and health, and other safety
and environmental standards and regulations. Such regulations and
standards include, but are not limited to, those promulgated by:
the National Fire Protection Association, the federal
Occupational Safety and Health Administration, the federal
Environmental Protection Agency, the District of Columbia Fire
Department.
Warranty of Service:
The Contractor's warranty with respect to all work performed
and all materials provided shall run for a period of one (1)
year. The warranty period shall commence on August 1, 1990 and
end at midnight on July 31, 1991.
FILE:
C:\WP50\SHERRY\JE-SOW.DUCT
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\ APPEND! '. I
-' UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON DC 20460
0 ?389
ADMINISTRATION
AND RESOURCES
MEMORANDUM MANAGEMENT
SUBJECT: Guidance Regarding Employee Requests for Alternative
Workspace or Work Assignments
FROM: Ch.-rles L. Grizzle
Assistant Administrator
TO: All Headquarters Managers and Supervisors
The following 'is provided as guidance to help you make
decisions regarding employee requests for alternative workspace or
work assignments as a result -of health related problems.
First, a determination must be made that the employee is
unable to remain in their current work location. The attached
agreement specifies how this will be accomplished. Briefly, this
agreement . provides that the determination will be made by the
physician at the Waterside Mall Health Unit. This will be .done
based on either the EPA physician's personal examination of the
employee or the. .documented results of a personal examination from
the employee's private physician. If the EPA physician determines
that the employee should not remain in the current workspace, the
physician will notify the employee's immediate supervisor.
If you receive notification from the Health Unit that your
employee should not remain in the current workspace, several
decisions must be made. The first is whether or not the employee
can perform the current job from another location. Of course, this
decision may be impacted by where the new workspace is located.
While an employee may be able to perform the job satisfactorily
from down the hall; this may not be possible from a different
building. Some jobs, such as receptionist, can only be performed
in their current location. If you decide that the employee cannot
perform the job from another location, it will generally be in
everyone's best interest to reassign the employee to a new job in
a new location. If this cannot be accomplished within your
immediate organization, you and your er.ployee should seek out
possible reassignnents within your AA-ship and throughout the
Agency. The Office of Hur.an Resources Management will make a
special effort to assist you in matching these people with
available ^obs in other parts of the Agency.
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If you decide that the employee can perform the current job
from another location, you should again look within your own
organization, to see if there is acceptable alternative space. If
there is not, there are several other options. These include
working in other space assigned to the AA-ship, working at a
contractor's facility, or in some instances, working at home. If
none of these are suitable, as a last resort, your AA nay ask the
Office ef Administration (OA) to provide alternative workspace.
Because the space that OA has available for this purpose is so
limited, I an asking you to make every effort: to find an
alternative workspace without resorting to requesting it from OA.
If you find that you must request alternative work space from OA,
the request should come from an Assistant or Associate.
Administrator to assure that the issue has been raised to an
appropriate level within your organization before you seek an
outside solution. Requests from an AA to the Director, Office of
Administration for alternative workspace must certify that there
is no suitable alternative • other than the one requested and should
detail any known restrictions or necessary special requirements.
OA will respond promptly with information on whether or not the
request can be granted.
As you know, every situation will be different. However, X
believe that by. working with other managers and our employees and
the alternatives discussed here, we -will be able to satisfy
everyone's needs.
•It you have any questions or require additional information,
please call Marita. A. -Llaverias, OHBM, en 382-3319. This
memorandum is intended as. intra-nanagenent guidance to supervisory
personnel within the meaning of Section 7114(b)(4)(c) and 7132 (a)
of Title 5, U.S. Code.
Attachment
cc: John C. Chanberlin
Kenneth F. Dawsey
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FOR THE UNION
FOR THE AGENCY
Rufus Morison,
oXnn Batsi
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ALTERNATIVE WORKSPACE POLICY
Employees desiring to be considered for relocation to
alternative workspace are required to submit the following
documentation:
1) A narrative explanation of the medical basis for any
conclusion which indicates the likelihood that the employee
is or is not expected to experience subtle incapacitation;
•
2) A narrative explanation of the medical basis for any
conclusion that, duty restrictions or accoaaodations are or are
not warranted;
3) A narrative explanation of the medical basis for any
conclusion which indicates the likelihood that an individual
is or is not expected to suffer harn by carrying out his/her
normal duties.
This process is voluntary, and esployees say use the services
of the Health Unit or a private physician to obtain this
documentation.
Any medical information provided by an employee in connection
with' this process shall be kept confidential and will not be
released to any person or-organization without the written consent
of the employee, except as provided in law or regulation.
All pertinent medical documentation shall be submitted to the
physician in attendance at the Waterside Kail Health Unit. The
physician will at the employee's written option, ei'ther: 1)
translate the medical documentation into layman's terwr to that the
employee's supervisor. can act on the request for alternative
workspace; or 2) certify to the supervisor that the employee is
eligible for alternative workspace. . The supervisor shall notify
the employee of the disposition of the request within a reasonable
time. If a request is denied, the supervisor shall provide the
employee written reasons for the denial.
An employee cay determine, after moving into alternative
workspace, that the space is not appropriate and request that
further action be taken. The Agency shall sake reasonable
accommodations-for employees making such requests.
Kothing in this policy supercedes 5 CFR Part 339, the title
of which is, "Kedieal Determinations Related to Erployability", or
the collective bargaining agreement between KFFE Local 2050 and the
Agency.
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APPENDIX !5
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
AIR AND ENERGY ENGINEERING RESEARCH LABORATORY
RESEARCH TRIANGLE PARK
NORTH CAROLINA 27711
December 18, 1989
SUBJECT: Testing Indoor Materials
FROM: W. Gene Tucker, Chief
Indoor Air Branch (MD-54)
TO: Julius Jimeno, Acting Director
Environmental Health and Safety Division
Office of Administration (PM-273)
As discussed with Gail Kleiner the other day, the purpose of this memo is to provide
guidance on how you might deal with manufacturers and suppliers of materials and
furnishings for EPA office buildings. This guidance is based on interpretations by
ORD/AEERL's Indoor Air Branch, of EPA and other research to date on source testing
and indoor air quality modeling. I believe the materials testing approach described
below, coupled with appropriate attention to ventilation system design and operation,
aesthetic and ergonomic factors, and building maintenance will provide an attractive
and healthy work environment for EPA employees.
We recommend that you require emission testing data from manufacturers or suppliers
of certain types of materials and products. Based on our work to date, we would
include the following types:
o Coatings (paints, varnishes, waxes),
o Flooring or wall covering materials made of plastics,
fibers, or fabrics
o Adhesives (e.g., for floor or wall coverings),
o Furniture or furnishings with substantial amounts of
pressed wood or fabrics,
o Non-merallic materials used in the ductwork of the
ventilation system,
o Office machines and supplies (e.g., coated papers), and
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o Maintenance materials (e.g., floor waxes, rest room
odorizers).
All of these materials have the potential to cause concerns when a building is new, or
when it is renovated, or when it is maintained. Some of them can also become
problem sources as they age, because they absorb and re-emit pollutants or support
the growth of microorganisms. Some also have the potential to contain toxic
substances that would be of concern for effects other than sensory irritation-based
symptoms.
The emission testing that we recommend is mostly for vapor-phase organic
compounds. In the case of office machines like copiers and electronic air cleaners,
testing for ozone emissions would also be appropriate. It is most important that
emission rates be determined. The most suitable methods for conducting such tests
are flow-through chambers. Enclosed is an EPA report (EPA-600/8-89-047), "INDOOR
AIR SOURCES: Using Small Environmental Test Chambers to Characterize Organic
Emissions from Indoor Materials and Products". It provides technical guidance on how
to test materials, and gives details on test methods, experimental procedures, and data
analysis techniques.
We recommend that the manufacturer or supplier provide Material Safety Data Sheets
(MSDS's) for chemicals used in the manufacture of the product, along with an
emission rate testing report. The report should:
o Identify and report emission factors for the 5 major
organic compounds emitted (i.e., the 5 compounds with the
largest emission factors)
o Identify the presence (or absence) of and report emission
factors for any specified compounds (for example, you may
request data on 4-PC from carpet with a latex backing and
data on formaldehyde from furniture and furnishings); if
absence is claimed, the detection limit should be
reported
o Report emission factors for total measured organic
compounds, in units of toluene equivalents
o Report emission factors as milligrams/hour per m2 for
surface materials and coatings; milligrams/hour per kg for
sealants and adhesives; and milligrams/hour per unit for
furniture, machines, and other items
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o Report emission factors at three "ages" of the product:
- For coatings, adhesives, and caulks: approximately
1, 10, and 100 hours after application to a surface
- For solid materials: approximately 0-1, 10, and 50
days after production
o Report ozone emission rates for office machines in
units of milligrams/hour
o Report chamber testing conditions (temperature, air
exchange rate, humidity, and product loading), and
storage and handling procedures used
If you chose to follow these recommendations, we would be glad to help you design a
standard reporting format.
Given the above information, we will be able to help you in the following ways:
o Predicting indoor concentrations and employee inhalation
exposures, as a function of time, for the building
conditions and product applications you are considering
o Evaluating (by IAQ modeling scenarios) the likely benefits
of product conditioning before use, or ventilation options
for the building
Your office will have to be responsible for assessing (or having someone else such as
ECAO-RTP assess) the health and comfort effects associated with the predicted
exposures. Others will also have to oe involved in selecting the "specified compounds"
mentioned above, although the Indoor Air Branch can certainly contribute to the
selection. For starters, I suggest you consider specifying compounds known to be in
the product that are also known to be toxic or irritating at an air concentration of 5 -
mg/m3 or less.
Dr. Bruce Tichenor of my staff will be available to consult with you and the
manufacturers and suppliers on the testing procedures discussed in the enclosed EPA
report. Our laboratory can also conduct limited chamber studies to check the quality
of results submitted by the manufacturers or suppliers.
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Testing of emissions from indoor materials and products is not yet widely practiced
Few manufacturers have their own testing facilities, although many have talked with
us and visited our laboratory. Carpet manufacturers represented by the Carpet and
Rug Institute have recently begun such testing, and some office furniture
manufacturers are having some of their products tested. We know of two testing
laboratories in this country that accept commercial clients. Several other companies
are considering getting into this business; we will keep you apprised of any new
entries. The two labs we know, of are:
Air Quality Sciences, Inc.
1331 Capital Circle - D
Atlanta, GA 30067
Contact: Dr. Marilyn Black
(404)-933-0638
Georgia Tech Research Institute
Emerson A-112
Georgia Institute of Technology
Atlanta, GA 30332
Contact: Dr. Charlene Bayer
(404)-894-3825
Feel free to call me (FTS 629-2746) or Bruce (629-2991) if you have any questions
or need additional information.
Enclosure
cc: Mike Berry
Kevin Teichman
Bob Axelrad
Bruce Tichenor
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