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United States
Environmental Protection
Agency
HEALTHY INDOOR
ENVIRONMENT PROTOCOLS
FOR HOME ENERGY
UPGRADES
Indoor Air Quality (IAQ)
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HEALTHY INDOOR ENVIRONMENT PROTOCOLS FOR
HOME ENERGY UPGRADES
This document is available for public review and comment until December 9, 2010.
Purpose:
The Healthy Indoor Environment Protocols for Home Energy Upgrades are intended to enhance the ability of other
federal agencies, industry standard organizations, state and local programs, and the home energy retrofit industry to better
integrate health protections into home energy upgrade programs. The protocols apply to single family and multifamily low-rise
residential dwellings, and are intended for voluntary adoption by weatherization assistance programs, federally funded housing
programs, private sector home performance contracting organizations, and others working on residential retrofit or remodeling
efforts.
This document DOES NOT:
• Set new EPA regulatory standards.
• Provide guidance for diagnosing occupant health problems or building-related illness.
• Replace the need for training or training documents.
• Provide detailed guidance on how to achieve the intent of each recommendation in all situations.
The U.S. Environmental Protection Agency (EPA) is developing these voluntary protocols in conjunction with the U.S.
Department of Energy (DOE) Workforce Guidelines for Home Energy Upgrades, and coordinated with the White House
Council on Environmental Quality (CEQ) Recovery Through Retrofit initiative. Together, these complementary documents
will: provide a robust and practical set of resources for retrofit contractors, trainers, and program administrators; help improve
the quality of the work performed in this expanding industry; promote occupant health and safety; and drive consumer
demand for energy efficiency retrofit services.
For more information:
http://www.epa.gov/iaq/homes/retrofits.html
http://www. weatherization.energy.gov/retrofit_guidelines
http://www.whitehouse.gov/sites/default/files/Recovery_Through_Retrofit_Final_Report.pdf
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Table of Contents
WHY EPA DEVELOPED THESE PROTOCOLS i
HOW THE PROTOCOLS ARE ORGANIZED.. .. i
CONTAMINANT SOURCES OF CONCERN 1
ASBESTOS 1
EN VI RON MENTAL TOBACCO SMOKE (ETS) 2
GARAGE AIR POLLUTANTS 2
LEAD 3
MOISTURE (MOLD AND OTHER BIOLOGICALS) 3
OZONE 6
PESTS 6
RADON 7
OTHER BELOWGROUND CONTAMINANT SOURCES 9
EMERGING ISSUES 10
PCBs, DRYWALL & SPRAY POLYURETHANE FOAM 10
CRITICAL BUILDING SYSTEMS FOR OCCUPANT HEALTH 10
COMBUSTION SAFETY (CO, VOCS & PARTICULATES) 10
Vented Ap pi i ances 10
Unvented Appliances 11
EXHAUST VENTILATION FOR LOCALIZED CONTAMINANT SOURCES 12
WHOLE HOUSE VENTILATION FOR DISTRIBUTED CONTAMINANT SOURCES 12
SAFETY 13
HOME SAFETY 13
OCCUPANT AND WORKER SAFETY.. ..13
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Why EPA Developed These Protocols:
Millions of American homes will be retrofitted in the coming years to improve energy efficiency or make them more
"green." Integrated healthy home and energy efficiency retrofit activities can lower utility costs for Americans and improve
indoor air quality at the same time. Leading weatherization assistance and energy efficiency retrofit programs have
demonstrated the feasibility of integrating many occupant health and safety improvements into their work. However,
there is also the potential for home energy retrofit activities to negatively impact indoor air quality and public health — if
the appropriate home assessment is not made before work begins and issues that may impact indoor air quality are not
appropriately addressed. These protocols provide guidance for conducting such home assessments and also provide the
specific responses necessary to maintain or improve health and safety in conjunction with energy efficiency retrofits or other
remodeling activities.
The protocols are intended to enhance the ability of other federal agencies, industry standard organizations, state and
local programs, and the home energy retrofit industry (i.e., home weatherization, energy efficiency retrofit and housing
rehabilitation professionals) to better integrate health protections into energy focused programs. The protocols apply to single
family and multifamily low-rise residential dwellings. Together with better resources for workers and programs, the protocols
will improve the quality of home weatherizations and other energy efficiency retrofit or remodeling jobs, and reduce failures
and call-backs.
How The Protocols Are Organized:
The document is organized to highlight priority health concerns that may relate to home energy efficiency retrofits. Priority
Issues are identified based on whether they are known to pose significant health risks to occupants or workers and whether they
can be affected by energy efficiency retrofit activities. For each Priority Issue identified in Column 1, the matrix identifies the
following:
1. Assessment Protocols in Column 2 provide EPA-recommended assessment protocols for evaluating both existing
conditions of concern and the potential for additional health concerns that may arise as a result of retrofit activities.
2. Minimum Actions in Column 3 include actions that weatherization and home energy retrofit contractors should take to
ensure that the work they perform in a home does not introduce new health concerns or make existing conditions worse.
These often reference existing standards.
3. Expanded Actions in Column 4 include recommended indoor environment improvements that can be made during
many home energy retrofit projects. The expanded actions are usually low- or no-cost, simple improvements that can be
performed by home energy retrofit workers with proper training and sufficient resources.
EPA anticipates the need for supplemental assessment tools such as worksheets and checklists, to help assessors and contractors
manage critical job information. Therefore, EPA plans to develop sample assessment tools to accompany these protocols, such
as the following sample tool concepts (not included in this draft):
• Sample Mold and Moisture Assessment Form
• Sample Radon Testing and Assessment Form
• Sample Home Ventilation Worksheet
For more information, please see http://www.epa.gov/iaq/homes/retrofits.html.
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HEALTHY INDOOR ENVIRONMENT PROTOCOLS FOR HOME ENERGY UPGRADES
PRIORITY ISSUES
ASSESSMENT PROTOCOL
Assessment measures to help weatherization and
home energy retrofit contractors identify serious
threats to occupant health commonly found inside
homes. This is not a guide for diagnosing occupant
health problems or building-related illness.
Minimum Actions
Critical steps to ensure work does not increase
known health risks to occupants or workers
(i.e., "Do No Harm"). EPA recommends these
protections for ALL retrofit projects.
iOR ENVIROI
Expanded Actions
Simple, mostly inexpensive additional actions
to promote occupant health that are feasible
for most energy efficiency retrofit projects. EPA
recommends consideration of these improvements
when feasible.
CONTAMINANT SOURCES OF CONCERN
ASBESTOS
Determine potential asbestos hazard. Consider the
age of housing, especially homes built after 1930
and before the 1970s, which may have asbestos
as insulation. Asbestos may be present in other
building materials in homes built or renovated
prior to the 1990s. If unsure whether material
contains asbestos, contact a qualified asbestos
professional to assess the material and sample and
test as needed. Possible asbestos containing areas
include:
• Attic insulation (especially vermiculite)
• Wall insulation (e.g., vermiculite, insulation
blocks, etc.)
• Insulation on steam pipes, boilers and furnace
ducts
• Vinyl flooring (including 9x9 inch or 12 x
12 inch floor tiles, vinyl sheet flooring and
the mastics and adhesives used to secure the
flooring)
• Cement sheet, millboard and paper used as
insulation around furnaces and wood burning
stoves
• Door gaskets in furnaces, wood stoves and coal
stoves (seals may contain asbestos)
• Soundproofing or decorative surface materials
sprayed on walls or ceilings
• Patching and joint compounds and textured
paints on walls and ceilings
• Roofing, shingles and siding (including asbestos
in cement or adhesives)
• Artificial ashes and embers (used in gas-fired
fireplaces)
Assessment Guidance:
N/A
• If suspected asbestos-containing material (ACM)
is in good condition, do not disturb. If suspected
ACM is damaged (e.g., unraveling, frayed,
breaking apart, etc.), immediately isolate the area
and do not disturb. Contact a professional for
abatement or repair.
• If unsure whether material contains asbestos,
contact a qualified asbestos professional to assess
the material and sample and test as needed.
• Keep activities to a minimum in any areas having
damaged material that may contain asbestos.
• When working around ACM, do not:
• Dust, sweep or vacuum debris.
• Saw, sand, scrape or drill holes in the material.
• Use abrasive pads or brushes to strip materials.
• Do not remove or disturb the attic insulation that
looks like vermiculite (as opposed to fiberglass,
cellulose or urethane foams).
Note:
In addition to the continued safety of the occupants,
appropriate identification of ACM is vital to the
safety of workers, who may not be cognizant of
asbestos hazards.
Note:
"Blower doors" (which are powerful fans used
to detect leaks by lowering pressure inside) can
potentially disturb asbestos in homes, thereby
potentially establishing or increasing a hazard.
Relevant Guidance:
EPA Guidance on "Asbestos in Your Home"
http://www.epa.gov/asbestos/
• If ACM is damaged, it may be abated by repair
or removal by a trained professional. Typically,
asbestos can be repaired by either:
• Sealing or Encapsulation: Treat the material
with a sealant that either binds the asbestos
fibers together or coats the material so fibers
are not released. Pipe, furnace and boiler
insulation can be repaired this way.
• Covering or Enclosure: Place a protective
layer over or around the ACM to prevent
release of fibers. Exposed insulated piping
may be covered with a protective wrap or
jacket.
• If there is a significant advantage to removing
asbestos (and it can be done safely), it should
be completed only by a professional trained to
handle asbestos safely.
Relevant Guidance:
EPA Guidance on "Asbestos in Your Home"
http://www.epa.gov/asbestos/
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
ENVIRONMENTAL TOBACCO SMOKE (ETS)
Determine if there is a smoke-free building policy
(multi-family buildings only).2
Assessment Guidance:
N/A
Minimum Actions
Occupant Education:
Provide information on local smoking cessation,
if appropriate. Also provide general information
about tightening homes and the goals of
minimizing pollutants and chemicals in homes.
Expanded Actions
In multi-family buildings, recommend adoption
of smoke-free housing policy.
Relevant Guidance:
EPA Indoor airPLUS Construction Specification
5.4
http://www.epa.gov/indoorairplus/construction_
specifications.html
GARAGE AIR POLLUTANTS
If there is an attached or tuck-under garage,
identify the location of air leaks from the garage
to occupied spaces, which may provide pathways
for hazardous emissions to enter occupied spaces.
For example, look for leaks around walls, doors,
ceilings, duct work, air conditioners, furnaces, and
electrical and pipe penetrations.
Assessment Guidance:
EPA Draft Model Healthy Indoor Environment
Assessment Questionnaire (under development)
• Air seal walls/ceilings separating living spaces. At
a minimum, air seal these locations (if present):
• Doors (ensure tight closure and install
weather-stripping)
• Electrical, plumbing and duct penetrations.
• Cracks between mud sill, rim joists, subfloors
and/or bottom of gypsum board
• Duct work, supply diffusers, return grilles and
air handlers in the garage
• Test-in and test-out using advanced blower
door techniques
• Specify carbon monoxide (CO) monitors/
alarms in homes with attached garages, at least
one per floor level
Relevant Standard:
BPI Home Energy Auditing Standard 7.10 and
8.1.3
NFPA 720 OR Consumer Product Safety
Commission Carbon Monoxide Questions and
Answers: CPSC Document #466; Blasnik and
Fitzgerald advanced blower door methods
• If occupants spend significant time in the
garage (e.g., workshops, playrooms, hobbies,
etc.), install exhaust fan(s) rated for continuous
operation and vented outdoors in attached
garages in accordance with Section 5.6 of EPA
Indoor airPLUS Construction Specifications.
• Educate occupants about safe storage of
chemicals (e.g., oil, gasoline, pool cleaners,
fertilizers, etc.) that may be stored in garages.
Relevant Guidance:
EPA Indoor airPLUS Construction Specification
5.6
http://www.epa.gov/indoorairplus/construction_
specifications.html
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
Minimum Actions
Expanded Actions
Assume lead-based paint exists in pre-1978 homes
unless testing confirms otherwise. Determine if
paint will be disturbed by the work.
Assessment Code/Standard:
EPA Renovation, Repair and Painting (RRP)
Program Rule (40 CFR Part 745)
http://www.epa.gov/lead/pubs/renovation.htm
HUD Lead-Based Paint Poisoning Prevention in
Certain Residential Structures, Subparts J and R
(24 CFR 35.900; 24 CFR 35.1340 & 35.1350)
MOISTURE7 (MOLD AND OTHER BIOLOGICALS)
Determine if there are signs of water damage, wet
spots, condensation or mold. Determine if there
is evidence of past water damage (e.g., rot, stains,
etc.) in interior occupied spaces, attics, basements/
crawl spaces or exteriors. Note the location,
moisture source, recommended repair or past
effective repair. Measure interior relative humidity
to determine if large sources of interior humidity
exist.
Determine if the air conditioning (AC) unit or
central system components are the likely cause of
any liquid water sources or high indoor relative
humidity (e.g., incorrectly installed condensate
pan, broken or improperly insulated or dripping
condensate lines, low air flow, low refrigerant
levels, clogged coil, leaky or uninsulated ducts).
• Comply with EPAs RRP Rule.3 Key elements
include:
• Follow lead-safe work practices if disturbing
greater than 6 feet2 interior or 20 feet2 of
exterior painted surfaces.
• Contain the work area to avoid resident
exposure.
• Minimize lead dust and leave work area clean.
• Achieve visual post-cleaning criteria.
• Use a Certified Renovator.4
Relevant Code/Standard:
EPAs Renovation, Repair and Painting (RRP)
Program Rule (40 CFR Part 745) & Proposed
Rulemaking (FR Vol.75, No.87, May 6, 2010,
pp.25038-25073)
http://www.epa.gov/lead/pubs/renovation.htm
http ://edocket.access.gpo.gov/2010/pdf/2010-
10102.pdf
Occupant Education:
EPA Renovate Right pamphlet
http://www.epa.gov/lead/pubs/
renovaterightbrochure.pdf
If moisture issues can be solved (see
Expanded Actions column to the right), then
weatherization and energy retrofit activities
proceed in conjunction with moisture control
interventions.
If moisture issues cannot be solved:
• If moisture issue will likely lead to or
aggravate high indoor humidity problems, do
not air seal, replace atmospherically-vented
combustion equipment with high efficiency
units or otherwise lower air infiltration rate.8
This includes homes that have significant
condensation/humidity problems, such
as condensation on multiple windows,
condensation in attics or significant moisture/
mold beyond the scope of remedies in the
Expanded Actions column.
• Follow the U.S. Department of Housing
and Urban Development (HUD) lead-safe
rehabilitation practices (required for HUD
projects that use up to $5,000 of federal
assistance5). In addition to EPAs RRP, this rule:
• Lowers the thresholds from 6 feet2 interior to
2 feet2 in any room.
• Requires repair of paint that is disturbed
using lead-safe work practices.
• Requires meeting dust clearance testing
standards if greater than 2 feet2 of paint is
disturbed.6
Relevant Code/Standard:
24 CFR Part 35, Subpart J: Rehabilitation, and
relevant elements of Subpart R: Methods and
Standards for Lead-Paint Hazard Evaluation and
Hazard Reduction Activities (e.g., 24 CFR 35.
1340; 24 CFR 35.1350)
Wet Attics:
• Repair minor roof leaks prior to attic insulation
or air sealing.
• Provide adequate attic insulation.
• Prevent roof underlayment (roof decking)
condensation or ice dam problems by
meticulously air sealing the ceiling (between
the living area and the attic). Address indoor
humidity sources causing attic condensation (see
remedies below).
• Air seal and insulate all attic ductwork if it
is beyond the scope of the weatherization to
extend the thermal envelope.
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
MOISTURE (MOLD AND OTHER BIOLOGICALS) (continued)
Assessment Guidance:
Air Conditioning Contractors of America (ACCA)
Quality Installation (QI) Specification
http ://www.acca.org/quality/
Also see: Sample Mold and Moisture Assessment
Form (under development)
Minimum Actions
• If there are plumbing leaks or rainwater
leaks in wall cavities, attics or ceiling
cavities beyond the scope of remedies in the
Expanded Actions column, do not insulate
these areas until the leaks are fixed.
Relevant Guidance:
N/A
Expanded Actions
Exterior Water:
• Prior to insulating basement or crawl space walls
near wet areas, address surface water pooling
near the foundation by:
• Repairing, modifying or replacing gutters and
down spouts.
• Grading and subsurface drainage at critical
locations (e.g., localized drain and grading
beneath valleys) per EPA Indoor airPLUS
Construction Specification Section 1.1.
• Ensure energy efficient replacement windows
and doors are installed with proper flashing
details to ensure drainage to the exterior. See
EPA Indoor airPLUS Construction Specification
Section 1.6.
Wall Assemblies:
• Use caution when increasing insulation levels
of wall assemblies, especially increasing cavity
insulation, which can lead to moisture and
condensation problems. Consider installing any
new insulation over the exterior of sheathing,
if possible, with exterior wall cladding/siding
installed over the new insulation. Consider
back-ventilating and back-draining behind
the wall cladding/siding (Note: these are more
expensive options).
Interior Humidity or Condensation:
• Cover exposed earth in basement or crawlspaces
with a vapor barrier material (e.g., 6-mil
polyethylene sheeting), taped at all seams and
edges per EPA Indoor airPLUS Construction
Specification Section 1.2.
• Depending on the Climate Zone, provide
dehumidification to address high humidity and
condensation problems (e.g., adding whole
house ventilation to meet ASHRAE Standard
62.2-2010 (see Section 4, Whole Building
Ventilation), improving dehumidification
performance of the home's air conditioning
system, or adding an ENERGY STAR qualified
dehumidifier to the basement, crawlspace or air
conditioning system).
(Continued on nex.
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
Minimum Actions
MOISTURE (MOLD AND OTHER BIOLOGICALS) (continued)
Expanded Actions
• Prevent condensation on cold surfaces by
adding vapor barriers and insulation between
cold surfaces and warm-humid air, with vapor
barriers installed on the warm side of the
insulation.
• Install new ENERGY STAR qualified bath fans,
or repair existing bath fans, vented outdoors
per ASHRAE Standard 62.2-2010, to address
bathroom moisture/humidity issues (see Section
5, local exhaust).
• Recalculate the home's heating and cooling
design loads after expected weatherization
modifications, and compare with ratings of
existing equipment. Ensure the capacity of any
new heating and cooling equipment matches
the expected design loads after weatherization,
including the latent capacity of cooling and
dehumidification equipment. Oversized cooling
equipment will have significantly reduced
moisture removal/dehumidincation capabilities,
and oversized heating and cooling equipment
may be prone to short cycling and premature
equipment failure. Notify homeowners/clients
of any existing equipment that may be oversized
after weatherization modifications.
Simple AC System Tune-up and Repairs:
• In homes with AC systems, find the cause of
condensation or poor AC performance and
repair:
• Insulate condensate lines.
• If appropriate, reinstall window AC units to
ensure condensate drips to the exterior and
not on or into the wall.
• Find and repair cause of condensation on
supply grilles.
• Replace dirty filter and clean evaporator coil.
• Adjust slope of condensate pan to drain
correctly.
• Seal duct leaks.
• Investigate and repair other performance
problems (i.e., low supply or return air flow,
low refrigerant charge), if feasible.
(Continued on next page)
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
MOISTURE (MOLD AND OTHER BIOLOGICALS) (continued)
Minimum Actions
Expanded Actions
Relevant Guidance:
Air Conditioning Contractors of America (ACCA)
Quality Installation (QI) Specification
http ://www.acca.org/quality/
ASHRAE Standard 62.2-2010, "Ventilation
and Acceptable Indoor Air Quality in Low-Rise
Residential Buildings," including Normative
Appendix A — Existing Buildings
EPA Indoor airPLUS Construction Specifications
1.1, 1.2 and 1.6.
http://www.epa.gov/indoorairplus/construction_
specifications.html
Determine if there is any air-cleaning equipment
designed to produce ozone (i.e., ozone generators)
in the house.
Assessment Guidance:
California Air Resources Board (GARB) resources
on ozone producing air cleaners.
http://www.arb.ca.gov/research/indoor/ozone.htm
• Recommend removal of air-cleaning equipment This cell is intentionally blank.
designed to produce ozone (i.e., ozone
generators).
Relevant Guidance:
EPA Indoor airPLUS Construction Specification
4.7
http://epa.gov/indoorairplus/construction_
specifications.html
http://www.epa.gov/iaq/pubs/ozonegen.html
Identify evidence of mice, squirrels and other
rodents; termites as indicator of moisture
problems; birds; bats; or other pest infestations.
Note the location. Identify if pesticides and/or
rodenticides are used.
Assessment Guidance:
Alliance for Healthy Homes, Community
Environmental Health Resource Center Protocols
http://www.afhh.org/res/res_cehrc.htm
http:/lwww.cdc.gov/ rodents
If there is indication of current or past
infestation, educate the clients about Integrated
Pest Management (IPM) through pamphlets or
other appropriate guidance.
Advise owner/resident to regularly clean/fix
screens (e.g., when replacing HVAC filters),
remove clutter, eliminate wood piles near house,
and remove any bushes, trees or other vegetation
closer than 2 feet away from structure.
Alert owner of any termite infestations and
inform of the need to seek assistance from
an IPM Greenpro or Greenshield certified
professional.
Patch exterior holes 1/4-inch x 3/8-inch or
larger using pest resistant materials (e.g., copper
mesh, hardware cloth, sheet metal, concrete,
etc.) before applying air sealing materials that
are less resistant (e.g., caulk or foam) or before
insulating.
Protect air intake and exhaust vents from
rodents, birds and pest entry. For example, cover
openings with 1/4-inch galvanized mesh.
Apply boric acid or gels in holes for roach issues.
(Note: Some states require licensing).
Follow relevant state pesticide applicator
standards.
(Continued on nex.
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PRIORITY ISSUES
PESTS (continued)
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
Minimum Actions
Relevant Guidance:
http ://www.healthyhomes training, org/ipm
http://www.epa.gov/pesticides/factsheets/ipm.htm
Occupant Education:
How To Control Pests Safely. New York City
Department of Health and Mental Hygiene
http ://www.healthyhomes training. org/ipm/NYC_
Pests_Healthy_Home.pdf
Expanded Actions
• Provide scalable garbage cans and/or advise
clients to use them.
Relevant Guidance:
How To Control Pests Safely, New York City
Department of Health and Mental Hygiene
http ://www.healthyhomes training. org/ipm/NYC_
Pests_Healthy_Home.pdf
Test homes for radon to help ensure home energy
retrofit actions do not increase radon exposure.
Tests, and follow-up action if needed, may be
conducted using either of the options described in
the Minimum Actions column at right.
Perform radon testing in accordance with state
and federal guidance, as appropriate. Some states
regulate the activities of radon services providers
through registration, certification or licensing
programs. Individuals conducting radon tests
should be trained/certified through either:
• The National Environmental Health
Association (NEHA) National Radon
Proficiency Program, or
• The National Radon Safety Board (NRSB)
certification program.
Note:
An optional second pre-work radon test may be
taken and averaged with the initial pre-work
test, to increase confidence that the short term test
better reflects the annual average radon level in
the home.
Determine whether the home has a radon
mitigation system. Most mitigation systems use
active soil depressurization and include a radon
vent fan, usually located in an attic, attached
garage or on the exterior of the home.
The options described below are intended to
minimize the potential for increased occupant
exposure to radon that may be caused by home
energy retrofit work, while minimizing additional
costs.
Perform radon testing and mitigation in
accordance with state and federal guidance, as
appropriate (see Assessment Protocol at left).
Note:
An optional second post-work radon test may be
taken and averaged with the initial post-work
radon test to increase confidence that the short
term test better reflects the annual average radon
level. DO NOT average the pre-work and post-
work test results.
Test-In/Test-Out Option: Test for radon before
and after energy retrofit work.
If pre-work radon level is 4 pd/L or greater, take
appropriate limited radon reduction actions
during retrofit work (see Expanded Actions
column at right), AND
• IF post-work radon level is less than 4 pCi/L,
no further action is required.
• IF post-work radon level is 4 pCi/L or greater,
but NOT greater than pre-work radon level,
inform client about radon and provide client
with EPA's Citizens Guide to Radon.
EPA recommends radon mitigation in all homes
that test at 4 pCi/L or greater. Radon levels less
than 4 pCi/L still can pose a health risk, and in
many cases may be reduced.
The following recommended lower cost, limited
actions may help reduce the radon level in a home
or aid more advanced mitigation if necessary:
• Air seal sumps (e.g., install airtight sump cover)
in such a way that water can drain from above
and below the sump cover.
• Install airtight drain fittings (e.g., trap or flange
system) in foundation floor drains.
• Seal and caulk penetrations, openings, or cracks
in floors and below grade walls that contact the
ground, per ASTM C920.
• Cover exposed earth floors in basements and
crawlspaces per Section 1.2 of EPA Indoor
airPLUS Construction Specifications or ASTM
E2121.
Note:
Only active soil depressurization (ASD) systems
installed per ASTM E2121 have been shown
to reliably reduce radon below 4pd/L. If
all the above limited radon reduction actions
are attempted and radon remains high, EPA
recommends full compliance with ASTM E2121.
(Continued on nex.
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PRIORITY ISSUES
RADON (continued)
ASSESSMENT PROTOCOL
Assessment Guidance:
Follow state regulation where it exists. Otherwise
see EPA guidance for testing and mitigation at
http://www.epa.gov/radon/pubs/index.html.
Also see: Sample Radon Assessment Form (under
development)
HEALTHY INDOOR ENVIRONMENTS
Minimum Actions
• IF post-work radon level is greater than pre-
work radon level, mitigate per ASTM E2121
OR take further radon reduction actions (see
Expanded Actions) to reduce radon to pre-
work conditions or below, then re-test. Repeat
this step until post-work radon level is at or
below pre-work radon level.
Iff re-work radon level is less than 4 pd/L, radon
reduction actions may not be necessary. Consider
limited radon reduction actions during retrofit
work if pre-work radon level is close to 4 pCi/L
(see Expanded Actions) AND
• IF post-work radon level is NOT greater than
pre-work radon level, no further action is
required.
• IF post-work radon level is greater than
pre-work radon level, but less than 4 pCi/L,
radon reduction is not required to comply
with EPA guidance. However, greater radon
risk may be present and appropriate radon
reduction actions are recommended (see
Expanded Actions).
• IF post-work radon level is greater than pre-
work radon level AND is 4 pCi/L or greater,
mitigate per ASTM E2121 OR take limited
radon reduction actions (see Expanded
Actions) to reduce radon to pre-work
conditions or below, then re-test. Repeat this
step until post-work radon level is at or below
pre-work radon level.
OR
Post-Work Test Option: Test radon after retrofit
work is performed, AND
• If post-work radon level is 4 pCi/L or greater,
mitigate per ASTM E2121.
• If post-work radon level is less than 4 pCi/L, no
further action is required.
Expanded Actions
Homes 'with an active radon mitigation system:
If the existing radon mitigation system does not
reduce radon below 4 pCi/L or is not working as
designed, troubleshoot the system. Follow state
residential radon regulations where applicable.
Relevant Guidance:
ASTM C920, Standard Specification for
Elastomeric Joint Sealants, Class 25.
For guidance on sealing crawlspaces, see EPA
Indoor airPLUS Construction Specification 1.2
or ASTM E2121, Standard Practice for Installing
Radon Mitigation Systems in Existing Low-Rise
Residential Buildings (section 7.3).
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PRIORITY ISSUES
RADON (continued)
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
Minimum Actions
Homes 'with an active radon mitigation system:
Verify that the radon fan is operating. If not
operating or if the tested radon level is 4 pCi/L or
more, advise the client to consult their state radon
office (http ://www.epa.gov/radon/whereyoulive.
html) or a qualified radon mitigation contractor
(http://www.epa.gov/radon/radontest.html).
Relevant Standards/Guidance:
ASTM E2121, Standard Practice for Installing
Radon Mitigation Systems in Existing Low-Rise
Residential Buildings
EPA's Citizen's Guide to Radon
http://www.epa.gov/radon/pubs/citguide.html
Expanded Actions
OTHER BELOWGROUND CONTAMINANT SOURCES
If there is a sewer gas smell in the home (e.g.,
during fan depressurization test), visually evaluate
the integrity of sewer vent system (e.g., ensure
drain traps have water in them, inspect drain lines
for breaks or leaks).
If soil or groundwater contamination is suspected
on or near the building site (e.g., former industrial
sites), volatile contaminants or breakdown
products may pose an indoor air quality risk
through soil gas intrusion. In such cases, EPA
recommends further assessment before air sealing.
Consult your state or tribal brownfield voluntary
cleanup program or environmental regulatory
agency for information on the risks of vapor
intrusion in your area.
Without discovering and correcting the cause or
source, corrective measures, such as the installation
of plastic sheathing or air sealing, will only
exaggerate these problems.
• Fill dry drain traps with a non-toxic liquid that
has a slow evaporation rate (e.g., mineral oil),
and repair or replace failed or unattached sewer
vent system components before air-sealing
activities.
• If soil gas vapor intrusion is suspected, assess
and mitigate in accordance with state or local
regulation. If state or local regulation does not
exist, follow EPA guidance.
Note:
Soil depressurization systems similar to radon
mitigation systems are typically recommended to
solve soil gas vapor intrusion problems.
Relevant Guidance:
American Society of Plumbing Engineers Data
Book: A Plumbing Engineers Guide to System
Design and Specifications. Volume 2, Plumbing
Systems (p. 10).
If there is an untrapped floor drain, consider a
low-cost floor drain seal retrofit often used during
radon mitigations.
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
OTHER BELOWGROUND CONTAMINANT SOURCES (continued)
Assessment Standard:
EPA Vapor Intrusion Primer, ASTM E2600,
or EPA Draft Guidance for Evaluating the
Vapor Intrusion to Indoor Air Pathway from
Groundwater and Soils.
Minimum Actions
State or local regulation where applicable.
Otherwise EPA Vapor Intrusion Primer, ASTM
E2600, or EPA Draft Guidance for Evaluating
the Vapor Intrusion to Indoor Air Pathway from
Groundwater and Soils.
Expanded Actions
http ://www.epa.gov/waste/hazard/correctiveaction/ http ://www.epa.gov/waste/hazard/correctiveaction/
eis/vapor.htm eis/vapor.htm
Also see:
http://www.epa.gov/ada/gw/vapor.html
EMERGING ISSUES
PCBs, DRYWALL & SPRAY POLYURETHANE FOAM
Assess if there are any concerns over the following
emerging issues (additional guidance may be
necessary):
• PCBs in caulk
• Contaminated drywall
• Spray polyurethane foam
Assessment Guidance:
No inexpensive assessments have been identified
for these emerging issues.
CRITICAL BUILDING SYSTEMS FOR OCCUPANT HEALTH
COMBUSTION SAFETY (CO, VOCS & PARTICULATES)
When using spray polyurethane foam, ensure
workers use proper protection including an
appropriate respirator, chemical resistant gloves
and additional chemical resistant clothing to
prevent dermal exposure. Ensure sufficient
ventilation and foam cure time to protect
tenants before re-entry in the home. Also see:
http://www.epa.gov/dfe/pubs/projects/spf/
spray_polyurethane_foam.html
• If PCBs may be present, see: http://www.epa.
gov/pcbsincaulk/
• If contaminated drywall issues are suspected
in the home, see: http://www.cpsc.gov/info/
drywall/guidance04l0.pdf
VENTED APPLIANCES
Determine if there are any existing or potential
safety issues with combustion appliances, such as
gas, kerosene or oil burning ranges, ovens, stoves,
furnaces, wood stoves or fireplaces.
Determine if there are any potential safety issues
that may result from changes to the building
envelope, using Combustion Appliance Zone
(CAZ) Worst Case Depressurization testing per
BPI Section 7.5.
Assessment Standard:
BPI Home Energy Auditing (EA) Standard
10/19/09, Section?
• Conduct CAZ Testing per BPI Standards and
ensure compliance.
• If a whole house fan is used for night cooling,
warn occupants to open many windows before
operating the fan.
• Repair, modify or replace combustion
equipment (e.g., water heater, furnace, boiler,
gas range, fireplaces, woodstoves, etc.) and
address other issues/deficiencies as needed to
meet BPI standards.
• If the home smells of wood smoke, investigate
cause and repair.
• Install carbon monoxide (CO) monitors/alarms
if not present, one per floor level.
Address CAZ pressure — with combustion
make-up air, fan interlocks, transfer grilles,
jumper ducts, louvered doors or door undercuts
— or disable offending exhaust equipment.
When water heaters are replaced, add a heat trap
to the hot water line of new set-up.
If replacing combustion equipment as part of
the retrofit process, replace existing with sealed
combustion equipment, per Section 5.1 of EPA
Indoor airPLUS Construction Specification and
ACCA QI Standards.
(Continued on next page)
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
VENTED APPLIANCES (continued)
Note:
When conducting CAZ testing, 5 Pa
depressurization limit may not be appropriate
for all venting conditions. See BPICAZ
Depressurization Limits table:
httpjlwww. bpi. org/Web %20Downloadl
BPI%20Standards/Building%20Analyst%20
Professional_2-28-05nNC-newCO.pdf
UNVENTED APPLIANCES
Identify any unvented gas or kerosene space
heaters or vent-free fireplaces.
Determine whether any local or state laws
prohibiting these devices apply.
Recognize all unvented heaters as moisture
sources.
Assessment Guidance:
N/A
Minimum Actions
Relevant Standard:
BPI Home Energy Auditing Standard, Section 7
NFPA 720 OR Consumer Product Safety
Commission Carbon Monoxide Questions and
Answers CPSC Document #466
• Install carbon monoxide (CO) monitors/alarms
if not present (one per floor level).
• Verify that kitchen exhaust fan exhausts to
outdoors.
• Recommend removing all unvented combustion
appliances. If the primary source of heat, replace
with vented, code-compliant heating systems.
• Red tag illegal unvented gas or kerosene space
heaters according to local and state law and
advise clients to remove them as appropriate. If
the primary source of heat, replace with vented,
code-compliant heating systems.
• If occupant intends to disregard these
recommendations, educate occupants about
the hazards of operating illegal unvented
space heaters or operating vent-free appliances
inconsistently with manufacturer's directions.
For example, some manufacturers' directions
call for open windows, as use of the device
requires additional ventilation to remove
products of combustion such as NO2, CO2,
ultrafine particles and water vapor.
Relevant Standard:
BPI Home Energy Auditing Standard, Sections
3.2 and 7
NFPA 720 OR Consumer Product Safety
Commission Carbon Monoxide Questions and
Answers CPSC Document #466
Expanded Actions
Relevant Guidance:
EPA Indoor airPLUS Construction Specification
Section 5.1
ACCA QI Standards
http://www.epa.gov/indoorairplus/construction_
specifications.html
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
Minimum Actions
Expanded Actions
EXHAUST VENTILATION FOR LOCALIZED CONTAMINANT SOURCES INCLUDING KITCHENS, BATHS, DRYERS, ETC.
Determine if home complies with local exhaust
requirements of ASHRAE Standard 62.2-2010,
using Appendix A - Existing Buildings.
Determine if dryers vent to the outdoors
(condensing dryers are exempt).
Check for laundry room exhaust fans.
Inspect/verify that kitchen/bath/dryer exhaust do
not discharge into crawlspaces, attics or within
walls.
Assessment Standard:
ASHRAE Standard 62.2-2010, "Ventilation
and Acceptable Indoor Air Quality in Low-Rise
Residential Buildings," including Normative
Appendix A — Existing Buildings
BPI Home Energy Auditing (EA) Standard,
Section 8.2
Also see: Sample Existing Homes Ventilation
Worksheet (under development)
• If bathroom, dryer and kitchen exhaust
requirements or the alternative compliance
method in Appendix A of ASHRAE Standard
62.2-2010 are not met, repair, replace or
install exhaust ventilation that meets ASHRAE
Standard 62.2-2010 requirements and ensure
ducts are sized and installed and venting
properly to outdoors OR install additional
ventilation measures as necessary to meet
ASHRAE Standard 62.2-2010 requirements,
using Appendix A - Existing Buildings to
account for existing fans and windows.
• Ensure that all clothes dryers exhaust to the
outdoors (condensing dryers are exempt).
Relevant Standards:
ASHRAE Standard 62.2-2010, "Ventilation
and Acceptable Indoor Air Quality in Low-Rise
Residential Buildings," including Normative
Appendix A - Existing Buildings
BPI Home Energy Auditing (EA) Standard,
Section 8.2
• If the home is in compliance with ASHRAE
Standard 62.2-2010 without bathroom or
kitchen exhaust fans (i.e., using Appendix A),
EPA recommends installation of exhaust fans,
vented to the outdoors, per ASHRAE Standard
62.2-2010 requirements of Section 5, to
improve pollutant source removal.
Relevant Standard:
ASHRAE Standard 62.2-2010, "Ventilation
and Acceptable Indoor Air Quality in Low-Rise
Residential Buildings," including Normative
Appendix A - Existing Buildings
WHOLE HOUSE VENTILATION FOR DISTRIBUTED CONTAMINANT SOURCES, INCLUDING FORMALDEHYDE, OTHER VOCS, AND PARTICLES
Determine if existing ventilation meets ASHRAE
Standard 62.2-2010 requirements, using Appendix
A - Existing Buildings. (This will require blower
door testing and measuring fan flows—e.g.,
bathroom, kitchen exhaust). Determine if
additional ventilation measures are needed to meet
the ASHRAE Standard 62.2-2010 requirements.
Assessment Standard:
ASHRAE Standard 62.2-2010, "Ventilation
and Acceptable Indoor Air Quality in Low-Rise
Residential Buildings," including Normative
Appendix A — Existing Buildings
Also see: Sample Existing Homes Ventilation
Worksheet (under development)
• Install additional ventilation measures as
necessary to meet ASHRAE Standard 62.2-
2010 requirements, using Appendix A - Existing
Buildings to account for existing fans and
windows.
Relevant Standard:
ASHRAE Standard 62.2-2010, "Ventilation
and Acceptable Indoor Air Quality in Low-Rise
Residential Buildings," including Normative
Appendix A - Existing Buildings
• Ensure newly installed central forced-air HVAC
systems have minimum MERV 8 filter, no filter
bypass, and no air cleaners designed to produce
ozone.
• For existing systems, check with the manufacturer
to determine if MERV 8 filters can be installed.
• During remodeling/renovation activities,
follow the guidance in EPA Indoor airPLUS
Construction Specifications Sections 6.1
(structural plywood, oriented strand board
(OSB), and composite wood products), 6.2
(interior paints and finishes), and 6.3 (carpets and
carpet adhesives), where applicable.
Relevant Guidance:
EPA Indoor airPLUS Construction Specifications
4.7, 6.1,6.2 and 6.3
http://www.epa.gov/indoorairplus/cons truction_
specifications.html
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
Minimum Actions
Expanded Actions
HOME SAFETY
Determine if there are working CO monitors/
alarms and smoke detectors.
Identify knob and tube electrical wiring.
• Test/install working CO and smoke alarms.
If new batteries are needed, install a 10-year
lithium battery.
• Do not bury unsafe wiring in attic insulation.
Identify harmful chemicals in accessible locations. Relevant Standard:
BPI Home Energy Auditing Standard, Section 7
Assessment Guidance:
N/A NFPA720 OR Consumer Product Safety
Commission Carbon Monoxide Questions and
Answers CPSC Document #466
Occupant Education:
Hot water heater set-back rationale; instructions
on how to test smoke and CO alarms; other safety
measures for young children, elderly, etc.; referral
to other local programs
• Recommend safe storage of harmful household
chemicals (e.g., remove from accessible
locations).
• For households with small children and/or
elderly occupants, discuss scald prevention with
clients and adjust hot water heater setpoint to
120 degrees Fahrenheit to prevent scalding.
• For households with small children, recommend
installation of gates at top of stairs.
• In homes with elderly persons, install grab bars,
handrails and lighting as appropriate.
• Recommend replacement of knob and tube
wiring following applicable electrical codes
using qualified personnel.
Relevant Guidance:
N/A
OCCUPANT AND WORKER SAFETY
Occupants and workers need to be protected from
unsafe exposures during retrofit and renovation
activities. By law, employers and supervisors are
required to ensure that workers are working with
an OSHA written Safety and Health Plan.
Typical OSHA Construction Plan Includes:
Falls
Ladders
Electrical
Chemicals
Confined Space
29 CFR 1926.501
29 CFR 1926.1053
29CFR1926SubpartK
29 CFR 1926.59
29 CFR 1926.21 (b)(6)(i)
Free help with developing these plans is often
available from state or federal training (consulting)
programs.
Assessment Guidance:
OSHA 1926 Safety and Health Regulations for
Construction
Safety and Health Plans shall address multiple
construction issues, including the following:
• When known pollutants are being produced
or disturbed during retrofit activities, follow
appropriate standards to minimize worker and
occupant exposure, including EPA lead safe,
BPI, OSHA, NIOSH, etc. (see below).
• Ensure proper ventilation and adequate
worker hazard protection during these types of
activities.
Additional Resources:
OSHA website
http ://www. osha.gov/
National Institute for Occupational Safety and
Health (NIOSH) website
http://www.cdc.gov/niosh
When possible, choose construction products with
manufacturers that disclose all ingredients and
verify that they are free of formaldehyde, mercury,
and other known toxic substances.
Additional Resource:
Healthy Building Network PHAROS Tool
http://pharosproject.net
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
OCCUPANT AND WORKER SAFETY (continued)
Lead: Determine if retrofitting/renovation
activities will expose workers to lead dust (paint)
(e.g., pre-1978 buildings).
Asbestos: Determine if workers will be exposed
to asbestos containing material (e.g., pre-1980
buildings).
Falls: Determine if workers will be exposed to
heights of 6 feet or greater.
Ladders: Determine if workers will be using
ladders.
Electrical: Determine if workers will be exposed to
electrical hazards.
Minimum Actions
Expanded Actions
Lead: If the facility was built before 1978,
retrofitting/renovation activities involving existing
paint are assumed to contain lead and require
compliance with EPA 40 CFR 745 RRP. OSHA's
Lead Standard for the Construction Industry at 29
CFR 1926.62, covers hazards from lead.
Asbestos: If the facility was built before 1980,
retrofitting/renovation activities may expose
workers to asbestos containing material and
require compliance with 29 CFR 1926.1101,
which provides the required protection measures.
See page 1 for more guidance.
Falls: If work is required at heights of 6 feet or
greater, then the workers must be protected with
guard rails or tied off to prevent falling, Refer to
OSHA rule at 29 CFR 1926.501.
Ladders: If ladders are used, portable ladders
must be able to support at least four times the
maximum intended load. Ladders that must lean
against a wall are to be positioned at a 4:1 angle.
Ladders are to be kept free of oil, grease, wet paint
and other slipping hazards. The area around the
top and bottom of the ladder must be kept clear.
Ladders must not be tied or fastened together to
provide longer sections. Metal ladders must not be
used while working on electrical equipment and
electrical wiring. Additional information available
at: OSHA's 29 CFR 1926.1053.
Electrical: Exposure to electrical hazards is a leading
cause of death and injuries for construction work.
29 CFR 1926 Subpart K contains requirements
in protecting workers from electrical hazards.
Employers must make sure that all non-double-
insulated electric equipment is equipped with a
grounding conductor (three-wire type). Worn or
frayed electric cords must not be used. Employers
must provide either ground-fault circuit interrupters
or an assured equipment grounding conductor
program (which includes the regular testing of
all equipment grounding conductors) to protect
employees from ground faults.
OSHA publication "Lead in Construction"
which can be found at http://www.osha.gov/
Publications/osha3142.pdf provides information
on OSHA requirements to protect workers from
lead hazards in the construction industry.
Additional information on protecting the
workers from fall hazards can be found at: http://
www.osha.gov/SLTC/etools/construction/falls/
mainpage.html.
Additional resources on ladder safety can be found
on OSHA's website at: http://www.osha.gov/
Publications/osha3124.pdf.
Additional information on electrical safety
available at: http://www.osha.gov/SLTC/etools/
construction/electrical_incidents/mainpage.html.
14
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
OCCUPANT AND WORKER SAFETY (continued)
Mold: Determine if workers will be exposed to
mold.
Hazard communication: Determine whether
workers will be exposed to chemicals.
Minimum Actions
Expanded Actions
Confined space: Determine if workers are exposed
to confined space hazards.
Mold: Mold is found in damp, humid
environments that have poor air exchange. Most
molds do not harm healthy people but can cause
allergies and asthma in others. If mold is suspected
to be disturbed during activities, refer to the CDC
Mold Prevention Strategies, NIOSH Interim
Recommendations for Cleaning and remediation,
or EPA's publication, A Brief Guide to Mold,
Moisture and Your Home for guidance.
Hazard communication: If renovation/retrofitting
activities will require the handling of chemical
substances, compliance with 29 CFR 1926.59
is necessary. It requires that chemical safety
information be made available for all chemicals in
use, containers are properly labeled, and workers
handling them are properly trained.
Confined space: Ensure work space has breathable
air (i.e., ventilate the work space if necessary).
Section 5(a)(l) of OSH ACT requires employers
to protect workers from workplace hazards that
are serious in nature. 29 CFR 1926.21 (b)(6)(i)
requires that all employees required to enter into
confined or enclosed spaces shall be instructed as
to the nature of the hazards involved, the necessary
precautions to be taken, and the use of protective
and emergency equipment required.
Mold Guidance Documents can be found at
http://www.epa.gov/mold/ and http://www.
cdc.gov/mold/cleanup.htm. All suspect moldy
areas should be remediated by properly trained
individuals. The moisture source needs to be
identified (http://www.epa.gov/mold/) or mold
will return.
Additional resources on confined space hazards
in the General Industry may be found on
OSHA's website at: http://www.osha.gov/SLTC/
confmedspaces/recognition.html.
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PRIORITY ISSUES
ASSESSMENT PROTOCOL
HEALTHY INDOOR ENVIRONMENTS
OCCUPANT AND WORKER SAFETY (continued)
Spray polyurethane foam: Determine if workers
are using spray polyurethane foam.
Drywall with impurities: Determine whether
drywall has been imported from China.
Minimum Actions
Spray polyurethane foam: Spray polyurethane
foam (SPF) is extremely hazardous, and if it is
going to be used,the NIOSH Alert "Preventing
Asthma and Death from MDI" provides best
safe practices for SPF use. SPF should only be
applied with full face supplied air respirators
and protective clothing. The work area should
be ventilated for hours before reentry is allowed.
OSHA's standard for MDI in general industry
is 29 CFR 1910.1000 Subpart K and for
construction is 29 CFR 1926.55 Appendix A.
Expanded Actions
Drywall with impurities: if drywall suspected
to contain sulfur/mercury impurities is used,
immediately reassess and substitute with a less
hazardous alternative. There is no known abatement
for Chinese drywall containing sulfur/mercury.
For Spray Polyurethane Foam, follow
recommendations provided on EPA's website:
http://www.epa.gov/dfe/pubs/projects/spf/spray_
polyurethane_foam.html
SPF is a widely used and highly-effective insulator
and sealant; however, eye, skin, and inhalation
exposures to its key ingredient, isocyanates, and
other chemicals in SPF products of concern in
vapors, aerosols and dusts during SPF installation
can cause: asthma, lung damage, respiratory
problems and other breathing difficulties, skin and
eye irritation, and potentially other adverse health
effects.
Minimum Health Protections include:
• Building occupants and other trade workers not
involved in the SPF installation should vacate the
premises.
• Review product ingredients and use information,
such as material safety data sheets (MSDSs).
• Isolate the work site.
• Wear prescribed personal protective equipment:
chemical resistant (nitrile) gloves, appropriate
respirator, and chemical resistant clothing.
• Ventilate the work site.
• Clean the area thoroughly before re-entry of
unprotected workers or occupants.
NIOSH Protective Clothing and Ensembles Safety
and Health Topic website
http://www.cdc.gov/niosh/topics/protclothing
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End Notes:
1 DISCLAIMER: Tightening a building is essential for energy efficiency, but may have the unintended consequence of allowing
contaminants that would otherwise be diluted to build up to unhealthy levels, including secondhand smoke in homes of smokers or in
attached multi-family dwellings adjacent to smokers.
2 Smoking by residents in single-family dwellings is an occupant behavior that is beyond the scope of this document.
3This is not a complete summary of the regulatory requirements. The full requirements can be found at: http://www.epa.gov/lead/pubs/
renovation.htm. The intent of this DRAFT protocol is to promote the most health protective steps that are feasible and practical. The
minimum action recommended in this DRAFT protocol is to comply with whatever the most current version of the RRP Rule prescribes.
The current version of the RRP Rule does not require dust wipe testing and passage of clearance standards after demolition, removal of
greater than 6 ft2 of plaster, or use of machines that disturb paint through high-speed operation; or dust wipe testing after use of heat gun at
temperatures below 1,100 degrees Fahrenheit; removal or replacement of windows or doors; scraping greater than 60ft2 of painted surfaces;
or removing greater than 40ft2 of trim of molding. However, a subsequent final rulemaking may include these more stringent requirements.
4 Reference EPA website to find accredited training programs: http://cfpub.epa.gov/flpp/searchrrp_training.htm.
5 More stringent requirements apply for HUD projects that use over $5,000 of federal assistance.
6 Dust clearance testing includes measuring for lead dust on floors, windowsills and window troughs. See http://www.nchh.Org/Portals/0/
Contents/factsheet_lead_dust.pdf.
7This assessment is designed to help contractors and assessors identify existing or potential moisture problems.
8 Replacing an atmospherically-vented combustion device with a high-efficiency, fan-powered exhaust or sealed
lower the ventilation rate and affect indoor humidity levels. If an atmospherically-vented combustion device is <
problem, it should be repaired in accordance with the Combustion Safety section of this Protocol.
17
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United States
Environmental Protection
Agency
http://www.epa.gov/iaq/homes/retrofits.html
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