ft, OC
EPA Report of the Indoor
Air Quality/Total
Human Exposure
Committee (IAQTHE)
Review of the EPA
Indoor Air Quality
Implementation Plan
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D C. 20460
December 15, 198S
The Honorable Lee. M. Thomas T^e ^''i.'U
Administrator
'U.S. Environmental Protection
Agency
401 M Street, S.W.
Washington, DC 20460
SEi Report on the SPA Indoor
Air Quality Implementation
Plan
Dear.Kr Thomas:
I am pleased to transmit via this letter the final
report of the Science Advisory Board1s (SAB) indoor Air
Quality and Total Human Exposure Committee (IAQTHE) on its
review of the "EPA Indoor Air Quality Implementation Plan"
as required under Sections 403(c) and (d) of Title IV of the
Superfund Amendments and Reauthorizatlon Act of 1987 (P.L,
99-499). This same report is also being transmitted to the
Congress under separate cover as required under Section
403(d) of the Act.
The Committee found the Implementation Plan and its
Appendices to be useful and well done. It is clear that
the Agency has identified in a rather comprehensive manner
the level of our knowledge concerning indoor air pollution.
Nevertheless, the Committee was concerned that
recommendations of earlier SAB review panels who provided
advice on the total human exposure program in 1985 and the
indoor air program in 1986 have not been addressed,
particularly with regard to program management and strategic
planning. These earlier recommendations and how they relate
to the present review are discussed in the attached report.
The major conclusions and recommendations of the
Committee concerning the Implementation Plan include the
need for: development of criteria for establishing research
priorities; a full time Director with expertise, authority,
and direction to set-up an adequate program; adequate
funding to support an effective indoor air quality program;
coordination of research with other agencies; increasing the
role of research on the sick building syndrome (SBS) and
building related illnesses (BRI); more emphasis on strategic
planning to address both long and short term goals; and,
wide dissemination of EPA's research findings.
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Letter to Mr. Thomas Page
The Committee appreciates this opportunity to review
and present our views on the Agency's Indoor Air Quality
Implementation Flan.
Sincerely,
fy^ -- '
Morton Lippmann, Ph.D.
Chairman
Indoor Air Quality and Total
Human Exposure Committee
Don Barnes
Erich Iretthauer
Eileen Claussen
Don Clay
Ray Loehr
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THS SCIENCE ADVISORY BOARD
INDOOR AIR QUALITY AHD TOTAL HUHAN EXPOSURE
COMMITTEE
REPORT OH THE
INDOOR AIR QUALITY IMPLEMENTATION PLAN
(As required by Section 403(d) of the Radon Gas
and Indoor Air Quality Research Act of 1936)
December IS, 19SS
SCIENCE ADVISORY BOARD
U.S. ENVIlQNUtiTAI, PROT1CTI01I AGENCY
WASHINGTON, DC
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'ABSTRACT
Under the provisions of Title IV of the Superfimd Amendments
arid Reauthorization Act of 1987 (P.L. 99-499), the Science
Advisory Board of- the U.S. Environmental Protection Agency has
established the Indoor Air Quality/Total Human Exposure Committee
(IAQTHE) to review the Agency's Indoor Air Quality Implementation
Plan and to provide continuing advice to the Administrator on
indoor air issues. This is the Conumittett's first report,
reflecting its views on the Imp lenient at ion Plan forwarded to the
Congress in 1987. The Committee's major recommendations include
the need for? criteria for establishing research priorities? a
full-time Director with expertise, authority, and direction to
set-up an adequate program? adequate funding to support an
effective indoor air quality program,'coordination of research
with other agencies? increasing the role of research on the sick
building syndrome and building related illnesses; more emphasis
on strategic planning to address both long and short term goals;
and wide dissemination of EPA's research findings.
Key Wordaj. Indoor Air Quality, Radon
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U.S. Environmental Protection Agency
KQTICE
This report has been written as part of the activities of
tne Science Advisory Board, a public advisory group providina
**tra*ural scientific information and advice to th* Administrate?
and other officials of the Environmental Protection Agency The
Board is structured to provide a balanced expert assessment of
scientific matters related to problems facing the Agency. This
report has not been reviewed for approval by the Agency? and,
hence, the contents of this report do not necessarily represent
the views and policies of the Environmental Protection Agency or
other agencies in the Federal Government. Mention of trade names
or commercial products do not constitute a recommendation for
X1S6 *
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U.S. ENVIROrotENTAL PROTECTION AGENCY
SCIENCE ADVISORY BOARD
WASHINGTON, D.C,
Indoor Air Quality/Total Human Exposure Committee
Chairman
Dr. Morton Lippmann, Professor, Institute of Environmental
Medicine, New York University Medical Center, Tuxedo
NY
Vice-chairaan
Dr. Jan A.J. Stolwijk, Chairman, Department of Epidemiology and
Public Health, School of Medicine, Yale university, New
• fiav-an, CT
Or. Joan Daisey, Indoor Environment Program, Lawrence Berkeley
Laboratory, Berkeley,* CA
Ms, Mary Ellen Fise, Product Safety Director, Consular Federation
of America, Washington, DC
Mr. Seymour Jablon, Bethesda, MD
Dr. Victor G. Latle», Professor of toxicology, Environmental
Health Sciences C»nt»rf University of Rochester Medical
Center, Rochester, NY
Dr. Jonathan X. Samet, Professor o£ Medicine, N*w Mexico Ttimor
Registry, University of H«w Mexico Medical center,
Albuquerque, NX
Dr. Keith J. Sehiager, Director, Radiological Health Department,
University of Utah, Salt LaXe city, UT
Dr. Jerome J. Wwoloimki, Chief, Air and Industrial Hygiene
Laboratory, California Department of Health, Berkeley, CA
or. Jam«« I. Wood*, Senior Engineering Manager, Honeywell
Controls Division, Golden Valley, MK
science Advisory Board s.taff
Mr. A. Robert Flaak, Executive Secretary and Environmental
scientist, Science Advisory Board (A-101F) , U.S.
Environmental Protection Agency, 401 X Street, SW,
Washington, DC
Ms. Carolyn Osbome, Staff Secretary, Science Advisory Board
(A-101F) , U.S. Environmental Protection Agency, 401 M
Street, SW, Washington, DC
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TABLE OF CONTENTS
1.0 EXECUTIVE SUMMARY ................ 1
2,0 INTRODUCTION .............*..*. 2
2.1 Background .*..*...*..,.,... 2
2.2 Charge to Committee ....... 4 .... 3
2.3 Previous Recommendations of Science
Advisory Board Committees and Panels . . . 3
2.4 Format of this Report ........... 5
3,0 POLICY OBJECTIVES AND RESEARCH STRATEGIES . , , . 5
4,0 PROGRAM MANAGEMENT AND COORDINATION .,..,,. 5
4.1 Internal Management ...... 5
4.2 Interageney Coordination . . 6
4.3 Budgetary Constraints , 6
5.0 GENERAL COMMENTS ON THE IMPLEMENTATION PLAN ... 7
5.1 Radon Gas ............,»*... ?
S.2 Other Indoor Pollutants ..... 7
5,3 Sick BtiiMinf Syndrome and Building
Related Illnesses ............. 3
5.4 Workshop on Strategy * * 8
APPENDICES
A. Specific Comments on the Implementation Plan
and its Appendices.
a. Report of the Radiation Advisory Committee to the
Indoor Air Quality and Total Human Exposure
Committee
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EXECUTIVE
(SAB) Was established under Sectio? 403 ^ t/ iSf A^vj"sory B«ard
indoor Air Qualify S.«rSh A?? a? 1995 ^ Thi«^Rafn GaS and
the Committee concerns its review of thl" ..pp* T / * -r<5port of
Implementation Plan- (EPA ?™7* ^ Quality
its assoli^d1 ^ndi^'tfL^? f** ^fle^^ation Plan and
ES -<"'°":n:'":::r"? ^~~ ~
ssasra: a
-a
ooi.^ ^ Tf,J The Sick Gilding Syndroa* (SBS) and Buildina
Related IlInmsBmm (HI) m incrwlngly bLiag1 nwoaniMd a!
2? ^oor air «^i"i "
«xi»tinf res*arcsh effort.
Act of
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^^
help ft,™ th. basis
2-0
o Of "^ us"* Ea* » Ct di«cted the
establish a research ^ oroa™ Tn !J?ental Protec*i<»» Agency to
research progru ^tas to bl S.JSJ5 ?^* Pj** Poll«tantS. J The
in order to bStef understtnd thf hl^f^^ data »«I«i«ition
gas and other inIOolSr^iiu^^lth ^f^^tions of radon
state, I0cal, HI prive of
of
. ov tia*..
envxronaental and health ri«t* ™ 4at H 8. to mitigate
submitted in July 1987. revised and expanded version
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orally at the meeting with individual written comments provided
by committee members following the meeting. Initially, the
Committee planned to submit its comments to Congress on the
Implementation Plan after the committee completed, its review of
the report required under Section 403(e) of the Act. Since this
latter report has not been made available for Committee review,
it is not now possible to complete the Committee review until
early 1989, therefore, the Committee has finalized its
recommendations concerning the Implementation Plan in the interim
in this report.
Under the provisions of Sections 403(c) and (d) of the Radon
Gas and indoor Air Quality Act of 1986, the Committee has been
charged with the following responsibilities*
a) To assist the Administrator in carrying out the
research program for radon gas and indoor air quality [Section
403(C)].
b) Review the plan for implementation of the research
program on indoor air quality and submit its comments on the plan
to Congress [Section 403(d)j.
The Committee has taken this charge broadly. Under Section
403 (e) of the Act, the Administrator must submit a report to
Congress which details his activities under Section 403, making
recommendations as appropriate. At its November l§-20, 1987
meeting, the Committee provided the Agency with its comments
regarding the preliminary outline of this report. Although not
specifically mandated to review this particular document, the
Committee recommended that under the provisions of Section
403 (c), the Agency provide them with the opportunity to review
the report and make appropriate suggestions prior to its
submission to Congress. The Committee asked for the opportunity
to review this report prior to its submission to Congress.
The Committee views its charge to include providing
continuing scientific advice to both the Administrator and the
Congress, as appropriate.
2,3 Previous Recommendations bv Science Advisory Board
Committees and Panels
On September 3-4, 1986, the SAB's Indoor Air Quality
Research Review Panel publically reviewed the Agency's indoor air
quality research program as part of the SAB's continuing series
of research reviews designed to examine the research programs of
the Agency's Office of Research and Development (ORD). The
purpose of these reviews was to provide the IPA Administrator and
the Assistant Administrator of ORD with insight as to their
research programs. specifically, the SAB reviews were to
identify whether research was being don* in a scientifically
sound manner, and whether the research was appropriately targeted
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to regulatory needs of the Agency. The present Committee
(IAQTHE) is, in part, a successor to that earlier research review
panel. With many of the foirmer members serving on the present
Committee an excellent link to previous SAB experience and
deliberations concerning indoor air quality has been established.
The indoor Air Quality Research Review Panel reached a
number of pertinent conclusions that are appropriate to mention
here since they are closely tied to the efforts of the present
Committee. Their major conclusions include the following:
a) The Agency should develop and adopt a clear policy
statement that indoor air quality is an important and essential
part of its responsibility. This statement should clearly define
the policy and program goals toward which the research is
directed*
b) Responsibility for the indoor air quality program
should be assigned to an individual of strong, proven leadership
who has appropriate scientific stature and specific experience in
this area, who would devote full time attention to this program
and to the implementation, of a research needs assessment.
c) An effective indoor air quality program must toe
multi-disciplinary with clearly recognizable goals.
d) The Agency should carefully articulate how it plans
to integrate work carried out by other public agencies and
private organizations into its own research program.
It appears that although much progress has been made, some
of the previous concerns of the SAB have yet to be fully
addressed. Through its implementation plan and supporting
documents EPA has articulated policy objectives for its approach
to characterize and understand human health risks from exposure
to pollutions in indoor environments. Nevertheless, a strong
program of research must emerge, not just a collection of
competent research that is not always linked together.
The Agency has attempted to provide sound leadership for its
indoor air research efforts, but still has not identified a
single, well qualified individual to lead the program. The
several managers who have been shepherding the program thus far
are capabl* and are doing commendable jobs, however, the program
would be better served by a full-time manager who is not
splitting ti»* with other major responsibilities.
Effort* have been made to provide adequate interdisciplinary
links within the Agency to foster indoor air research.
Nevertheless, a stronger programmatic strategy is needed to focus
it. such a strategy is only now coming about. Interagency
coordination has developed considerably »ino* the P^ous
review, with member agencies of the CIAQ participating more, and
with the EPA representative to that group being a senior manager
in the indoor air program area within EPA.
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2.4 Format of this Report
This report links earlier activities of the Science Advisory
Board to the present effort in reviewing indoor air quality
research programs. This report contains three sections which
are: Policy Objectives and Research Strategies, Program
Management and coordination, and General Comments on the
Implementation Plan. Detailed, specific comments from several
Committee members concerning the reviewed documents are contained
in Appendix A.
Since the SAB his a permanent standing committee on
radiation - the Radiation Advisory Committee (RAC) - it decided
that the RAC should perform the review of the radon gas portion
of the Implementation Plan and provide its comments to the IAQTHE
Committee. Three members of the RAC were appointed to serve on
the IAQTHE Committee to provide a bridge. The general comments
and conclusions of the RAC have been integrated into the present
report, however, their complete report is included as Appendix B.
This report constitutes the formal report of the Science
Advisory Board's Indoor Air Quality and Total Human Exposure
Committee to Congress and to the Administrator of the U.S.
Environmental Protection Agency on ita review of the Agency's
Indoor Air Quality Implementation Plan as required by Section
403 (d) of the Radon Gas and Indoor Air Quality Research Act of
1986,
3,0 POLICY OBJECTIVES AND RESEARCH STRATEGIES
Although not specifically charged with responsibility to
regulate indoor air pollutants, EPA is still the Federal agency
for which indoor air quality is closest to its central mission.
The Agency does regulate some indoor air pollutants through other
means. For example, household pesticides are regulated under the
Federal Insecticide, Fungicide and Rodentieide Act, and toxic
chemicals undar thm Toxic Substances Control Act. While this
creates some degree of control over indoor pollutants, it is not
an integrated approach to the problem. The ability to enforce
regulation of indoor exposures is severely limited by physical,
fiscal, and political constraints* Therefore, alternatives such
as education and licensing (or authorization or certification) of
those responsible for providing indoor air quality should also be
considered.
4,0 PROGRAM MANAGEMENT AND COORDINATION
4.1 Internal Management
The U.S. Environmental Protection Agency has completed a
fairly comprehensive review of th* status of our knowledge of
indoor air pollution, identifying a number of research needs
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?' U
and design a research stratgy which will
0?* tei? L9°alS* The current S^rch program s one
^« ."» JdMt*^**™*l™4y Siting Unel
. There are few clear directions for the future in
the existing program. Although many of the ongoing research
projects address important indoor air quality problems, therl are
also instances in which projects or lomponLts of projects are
rather peripheral and/or repeat work which has already bet n done?
«*^™ i! J^i!:10**1 to the succes* o* the indoor air quality
progran that the Agency appoint a full-tine Director for the
^ th CCif
e
?PCCif i? e*P*rtise in i«to«r air qualiy and that he
«f • * given •*•«?»*• authority and control If budget to
establish research priorities, and to design and
, a
strong research program. The fact that the Agency Ms not ye?
designated a single director suggests a half-hlarted coUittmint
n
*hich Con9^s clearly views as important. Because
limited resources which will be available to this oroaram
:.hc1next11fesr y*ars' this Doctor must also be abT? ?o
effectively collaborate with other agencies through the CIAQ in
order to stretch resources to meet stated goals. Although a
single, senior Director is needed to focus the indoor air ouality
progran, we must compliment th« current managers for navincr
accomplished as much as they have with such a fragmented and
poorly supported effort. «nte« ana
4-2 Interaaencv
_ Xt is lilwly that some of the research being performed at
other agencies can help to meet national and EPA research needs.
Good communications and relations between agencies will be
essential in this effort, it would be desirable if other members
of the CIAQ provided a listing of indoor air quality research
projects for each of their agencies, much like EPA has done in
Appendix B of the June 1587 Implementation Plan. This would be
useful to EPA in avoiding duplication of research efforts.
4.3 Budgetary Constraints
The EPA indoor ait- quality budget i* simply inadequate to
meet the n«*d» of thm progran as stated by the Agency, even with
its present narrow focus. This is a problem that can be traced
to inadequate funding from Congress as well as a less than
aggressive approach from EPA in seeking expanded funding. For
example, in FY88 th« budget allocated to th» Office of Research
and Development was $2.3 million, with an additional $o.3 million
going to the Offic* of Air and Radiation. This issu«* requires
further attention fron both Congress and 1PA.
A possible mechanism of funding that has not been
sufficiently utilized is the EPA's Extramural Exploratory
Research Crants Program. For FY 88 and FY 89, this program has
about an $8 million budget, reduced from about $11 million in
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eary .i,, the I98i
towards innovae rsercn
5'° SEVERAL COMMENTS QH THE IMPUm^TATT
5. 1 Radon
of the IAB-S siai,^ ^ t« »• Present
°
survey be supported and carried out as soon asossible.
lad^tail"d COBdnents *^« contained in th« report of the
Advisory Committee to th« IAQTHE Committee - See
«d - Taon
are included in Appendix A (see pages A-4 through A-6)
5-2 Other Indoor
lan1e of Govern is still biased heavily toward
environments rather than a dual approach that also
ST "JSST »u™%r'Cial I1? .PUbAic »^^/public access holdings?
we were surprised that the document contained no risk
assessments for
populations are not presently pos«4ble. Although we agree that
S8m«*? are ?"««»«r they are not impossible as
by EPA's Scoping Study on Indoor Air Quality (prepared
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by-,t»eJ?f£!Ce of Pro
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SPECIFIC COMMENTS ON THE IMPLEMENT.ATION.
AND ITS APPENDICIES
Dr. Joan Dmiscy A-l
Mr. Seymour Jablon A-3
Dr. Vic Latiea A-3
Dr. Jon Samet A-4
Dr. Jerome Wesolowski A-6
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C.0HMENTS FROM DR. JOAN DAISEY
Appendix At
p. 1-7: Some relative risk estimation is feasible at present
e.g., radon, VQC.
p. 2-5, Table 2-1: This type of information can be helpful in
, establishing research priorities. The figure of 4% of the
population exposed to gas phase' organics, in the table, is
ridiculous* The T1AM (Total Exposure Assessment Methology) study
as well as others have demonstrated that this figure is more like
100%!
p. 2-29: The last sentences of paragraph 2 and: 3 contradict each
other.
p. 2-noffj The whole issue of samplers for VQC needs a critical
look. sampler development must be well integrated with overall
EPA research objectives. The qannister sampler has been very
strongly pushed for VQC despite the success of the adsorbent
sampling method used for the TEAM study, the cannister samplers
were originally designed to take grab sampels in remote locations
where levels are low. They are very bulky to handle and ship and
require expensive controls in order to be used to obtain an
integrated sample. The Tenax adsorbent sampler also has some
limitations with respect to the compounds which it can collect.
However, there are commercially available multi-sorbent samplers
which can be used to extend the range of compounds sampled. The
multi-sorbent sampler has been used at LBL (Lawrence Berkeley
Laboratory) for indoor air studies and shown to have very high
accuracy and precision. It is quit* feasible to develop sorbent
samplers for more reactive and/or polar compounds for use in field
studies. Project 13 in the Research Program (Appendix B) is an
Assessment of Screening (Sampling, presumably) Techniques for
Indoor Air Pollutants* A very critical look at the cost-
effectiveness of the various sampling devices available, their
specific applications, the need for each application and at their
acceptability to th* public since they must be used in homes,
buildings, etc., is needed. It is not clear why a field test is
needed in this project since most of the devices mentioned have
already b««n widely used in the field.
Appendix Bi
Project 14 - Why ar« ther* plans to develop a method for nicotine?
Or. Hammond has developed a very good sampling and analysis method
for this compound.
Project 15 - Are there plans to couple a micro-processor with the
A-l
realtime NOZ monitor?
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Section I. A. a. a. The strategy for this needs to be discussed
Section I.B. Item number 1 should be "Scope of the Problem.11
COMMENTS gggKLMH. SEYHOUH JABLQJT
Implementation Plan:
Page 5: The very first item under the general heading of
. 'Indoor Air Policy Objectives and Strategy' refers to the intent
to "...refine its assessment of the nature and magnitude o^ the
health ... problems posed by individual air pollutants...11. This
general intention is specified with respect to radon on page 15 of
Appendix C. 'EPA Radon Program.' There, the first item under the
heading 'Radon Exposure and Health Risk' is: ''Conduct a National
Assessment of Representative Structure Types and Geographical
Locations."
The EPA clearly realizes that the data presently available
concerning the distribution of radon levels in residences,
workplaces, schools and other public buildings is inadequate: there
are available surveys in particular places, often relying on
volunteers, using a variety of measurement devices. Something like
ten percent of the housing stock of the country may exceed the
recommended guideline of 4 pCi/1 for radon. As the experience with
the Reading Prong made plain, there can be large areas where,
unsuspected, residents may be exposed to high, and dangerous,
levels of radon. The proposed assessment is, therefore, not onlY
highly desirable but needed urgently, in the face of this need,
which is recognized by EPA, it is disturbing to learn that despite
the fact that the proposed survey has been in the planning and
review process for yeacs, there are no funds in the FY as budget
for the survey. I would point out that the Plan, as reported to
the Congress, is apparently not supported by the intention to act,
at least not this year. I regard this as very unfortunate, to say
the least. *
Preliminary Outline?
To my untutored eye, the Outline seems quit* thorough and
complete. I presume that the Radon Measurement Proficiency Program
would come under Volume II, lv.,B.,l, "Radon Exposure and Health
Risks". Thi» is an important program, especially since it seems
quite pos«ibl« that EPA will one day be mandated to certify
organization* that offer measurement services and having this
program in place, with the , kinks worked out, will be very helpful.
COMMENTS FROM DR. VIC LATIES
Implementation Plan; objectives and Strategy section fpgs 5-71 i
1. The section seems too focussed upon EPA 'a own intramural
activities. Nowhere does it ncognize efforts within the
A- 3
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environmental health sciences by other parts of the Agency itself
or by other parts of the Federal government. For instance take the
first point: "The Agency will conduct research and analysis to
further refine its assessment » This statement, coupled with
the appendix outlining what intramural work is being done pays no
attention to EPA's Extramural Exploratory Research Grants and
Centers program, which can support research at universities on
questions of interest to EPA. I have been sensitized to the role
2£ 5 «t ef.fort bv service on one of its study sections and think
that EPA gives it too little support. This report ignores its role
in generating the interest of the larger university community in
problems associated with indoor air guality. EPA's intramural
scientists however worthy simply can't solve all the many problems
in this vast area by themselves.
2. Emphasis on improving exposure data and on modeling seems
excessive to me. These are important topics but our knowledge of
health effects remains weak for many of the substances important
for indoor air quality. No other agency has either the enduring
interest in air quality or the in-house expertise to run a program
in that area. EPA .should support research on the health effects
of air quality, if it does not, the whole area is likely to wither
COMMENTS FROM DR. JON SAMET
With regard to the "1PA Indoor Air Quality Implementation
Plan", I have only brief comments to offer. I concur with the
overall objectives, but have some concerns about the approach that
will be taken to meet the first objective, "Problem
Characterization," The strategies listed are largely directed at
describing the overall extent of the indoor air quality problem
largely by combining a description of exposures with risk
assessment methodology. Does this strategy represent the
appropriate basis for problem-solving or merely provide more
elegant descriptions of problems that we already know about? He
need strategies for identifying those individuals placed at high
risk by their individual exposures; without this capability,
interventions to reduce health effects will be unsoundly based.
I see the work scopes described under "Problem
characterization" as not appropriately balanced between studies of
exposure and of health effects. Inevitably, a risk projection model
will indicate health effects for many exposures that are likely to
be measured in U.S. homes. However, these risk assessments will
be subject to substantial uncertainty unless appropriate
laboratory, clinical, and epidemiological studies are planned and
performed.
With regard to Appendix c "EPA Radon Profraii," I think that
the committee should have access to materials that are mentioned
in the document to fully understand the current radon program. The
A-4
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co™ents about specific -
strikingly different froa the information already available;
used ta ™*it.bT 00^ yf fortunate if th«* national survey were not
used to answer important questions related to the determinanL of
as if.Bi.fi 4-f r 1fmls'1 ^olofy an
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«• P*»- 12 confuses the
CQUMSKTS FROM pp
Appendix A -
comment «p i
scs o vo*t« orfanic conpouiute and
PfrMpf th* OR0 authors are trying to saythat ?he
« *.h° all P°"uta«ta ««»t be astiaatM. HeVertlieless
Oio a«J om ^ ^ doomwit. is l«ft with tte iiiprcsaioi, that
ORO ana OPD hav« different viawa on the efficacy of IAO risk
, , - so that such fundamental differences
resolved.
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of the Syndrome, the sym, the i facor!
Although the authors state that EPA is *dtina a «<9,,»iii
- H^/?- t 5MV
sources. Thus, it does not in fact reflect a 55S?
SPP*«C!i'. i**}" thia COUM bc remedied by a thorough
on SBS and by improving the "Building Syste»«» chaptll.
s a US«^1 start in assessing current
Specific
i"l* *lthou9h "Estimation of health hazards from specific
situations or sources nay be nore useful than trying to
^ in specific risk nwnbcrs) , However risk
* in "^ to
lS * «-*««tiS fas, n nonco^uslon gal!
± £5 orfanj-c, and a non-coabustion organic. To denonst?ate
JS f8 1 °onfuillon 'I «ot« the awkward sentence on p. 2-123,
noneonfcustion gaa-plia»« organic compound is formaldehyde which
«!°«.4* prCKillcJ: °f conbustion". A better definition might be
Combustion product* can be divid*d into inorganic ams**.
principally nitrogen diojcid*, carbon monoxide and sulfur dioxide »
P^r^iCiegf and organic compoundqf including PAH and formaldehyde" .
i. «P^ l~7 ***•*> 1st sentence, insert the article "as" before
"an 8 -hour day",
A-7
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tV°
not cpl: V° •«t«i<». of th. first paragraph are
have
ba
does £TS, pPAiances contribute to far larger
than
VOCs is
mistake. Why does tliioort l»i «-* I??
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t?Me 3^2? " "
-
p. 1-12.
Radon is also actively monitored.
™ "2l.u220ir"-*t*t" V--i««^idi»l pollutants from such
* «eaaur«d and correlated with source presence or use
are not measured. " Wilt is meant
not
™ . *
that. heir eraissions quantified, they should say
a verv c«i*?* Sj*0" ?ate "•••«»« usually the emission, of
?i Bixtur* of organic and inorganic gaseous and
ro»Pini±fV' Zf «*Iitl«>* ^* <"»apl«* mixture that
3 incomplete combustion can contain a variety
usa of t*11*' *1** * ™«**1** chemical
A-9
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p. 1-12. The authors should refrain from using such
Mass-media jargon as "formaldehyde is a suspected actor in the sick
building syndrome," Further, why single out formaldehyde as one of
the factors in SBS?
p, 1-18. There are typographical errors in the last three
columns of the E.T.s. section of the Table,
p. 2-1. Again, one doesn't normally refer to noncombustion
and combustion particles but rather to particles and
combustion-generated particles. Likewise one does not'normally
refer to noncombustion fas-phase organic compounds but to organic
compounds and combustion-generated organic compounds.
p. 2-2. The authors bring out the important difference
between_exposure, concentration and dose. However, they use two
erpre&aions for exposure, viz, "nominal exposure11 and "exposure."
They never state the difference between exposure and nominal
exposure.
p. 2-4. The authors state the lower tail of distribution can
identify especially sensitive populations." It is not clear how
an exposure distribution will identify who is sensitive in the
population.
p, 2-4. The authors state risk estimates for populations
exposed to indoor air pollutants are therefore premature.1* Refer
to an earlier general comment on this issue.
p, 2-41* The section on Sulfur Dioxide is structured
differently than those on Carbon Monoxide and Nitrogen Dioxide,
specifically exposure and conclusions are missing, as well as the
opening paragraph describing the compound. Furthermore, the first
paragraph on monitoring discusses particulate matter, not sulfur
dioxide*
p, 2-6. Nitrogen dioxide and sulfur dioxide are indeed
products of complete combustion, certainly not of incomplete
combustion.
p. 2-8. I suspect that the statement that most American hones
use natural gas and that most do not vent the combustion products
outdoors i» in error.' It likely true for gas ranges and ovens but
is not tru* for water heaters, wall space heaters and furnaces.
A reference is needed.
p. 2-9. The GEOMET Technologies, Inc. reference that burner
design does not influence emissions is out of date. Research by
the Gas Research Institute has produced a burner design that
appears to reduce N02 emissions. Research by LBL for the us CPSC
showed substantial differences in NO, emissions for unvented
gas-fired space heaters even after adjustment for heat output which
was attributed to differences in burner design,
A-10
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p. 29. Last paragraph: 500 and 600 hours should be 500 and
soo homes.
p. 2-14. Traynor conducted a study measuring the emissions
of NO, NQ2, CO, and C02 from several wood stoves. This study should
be referenced.
p. 2-16. "The absence of reliable emission factors from the
indoor sources makes it impossible to establish a relative ranking
between.." This statement is simply not true. The emission rates
illustrated in Table 2-6 vary for well known reasons: 1) the rates
listed are for appliances with different combustion rates, e.g.,
the emission rates for the gas space heaters were obtained from
heaters whose inputs ranged from 12,000 BTO/H to 40,000 BTU/H, and
2) contrary to the statement on p. 2-9 burner design does affect
emission rates. Moschandreas has conducted and reported upon an
extensive study of the various test methods and showed that the
various methods generally gave comparable results within the
experimental errors produced by state-of-the-art instrumentation.
p. 2-17. What are the authors referring to as unburned
benzene hydrocarbons? What is a benzene hydrocarbon? How is it
different from benzene? Do they mean aromatic hydrocarbons? Are
they referring to PAH? If so, strictly speaking, they probably
should not be referred to as unburned since they are formed in
flames and are in a sense combustion generated.
p. 2-17. Emission rates from combustion appliances are. well
known with the exception of SVOC. It has not been demonstrated
that these are produced in sufficient quantity to warrant extensive
study to obtain these rates.
p. 2-26, In contrast to what is implied, cigarettes are a
minor source of NOj On* could not measure the rise in N02 in a
room where a cigarette is smoked (see for example, Good, Eviron.
Int. S, 1982).
p. 2-29. Systems designed for monitoring N02 in ambient air
have been employed to monitor it in indoor environments in many
studies. Improvements would be very welcome but it is not true
that the system* are too large and complex to be used indoors. It's
been done frequently.
p. 2-30* It is unlikely that H02 is absorbed by materials:
it is adsorbed. In addition, there are studies which have
guantitated this effect for various materials. These results and
references should be added to this report.
p. 2-31. How do you "roughly assume"?
p. 2-41. The authors have offered no proof that, NO, is
likely to have either an additive or synergistic effects with other
A-U
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pollutants.11 In fact, the statement contradicts the one on
p. 2 -31 which states "Thus we have no significant knowledge of
additivity, synergism, or antagonism associated with NO in
mixtures with other combustion products, Much less with the Zf«ll
range of indoor air chemicals,1*
p. 2-110. The discussion regarding the variation of emission
rates from adhesives is somewhat naive, indicates a lack of
knowledge of the studies in the Table, and the authors implication
that there is a right answer is incorrect. Certainly temperature
is important. For "wet" building materials such as adhesives the
age( of the material is very important. The relative humidity may
be important for certain products because of the specific chemistry
involved, e.g., formaldehyde from urea-formaldehyde remains because
of ^ hydrolysis," product loading may also be important for products
which contain the chemical as a bulk constituent, e.g.. again
formaldehyde in urea-formaldehyde resins and p-dichlorobenzene in
moth crystals; air exchange rate, per se. is probably not important
but the local velocity of the air stream near • the boundary layer
may be very important. Unfortunately the report misses the major
surprise _of Table 2-23'; the rates listed are amazingly similar when
one considers that l) the ages of the adhesives range from 0.5 h
to 14 days: 2) the chamber volumes ranged from 3,8 L to 1000 Lj 3}
air exchange rates varied from 0.04 h-1 to 14 h-lf and most
importantly, 4) it is highly probable that none of thai, researchers
testing the same adhesive from the same manufacturer with the
same formulation. Why would anyone expect to measure the same
emission rate from different products? Presumably some of the
adhesives even cane from different continents. One of the major
points of the study cited which examined 15 different adhesives
(Girman et al., 1984b) was that there were large variations in
organic emissions from different adhesives, even those with the
same nominal application (and this from a study that used the same
methodology in determining rates so that the comparison should be
valid) .
p. 2-42. The authors state that" . . . particulate matter
consists of liquids, aerosols or solid particles ...*, Aerosols
are not a type of particulate matter. An aerosol is a gas system
with solid and/or liquid particles dispersed in it.
p. 2-47, Tli* reference to Sexton and Repetto (1982)
concerning the mutag*nic density for cooking stoves and cigarette
smoke is incorrect. The correct reference is Sexton et al., 1984.
p. 2-50. The authors state that human exposures to inhalable
particulate . . , probably has increased due to concentrations of
fine aerosols or ultra-fin* particulars generated within homes and
offices." What is the evidence for this increase?
p. 2 -61. Chang* PNA to PAH.
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p»2-63. The authors state that "... nonpolar fraction.,-only
accounts for about one-third of the mutagenicity*..". Because
one-third i* larger than usually reported, a reference here is
important.
p.2-64. The last sentence of 2.3*7 and the first of 2.3.7.1
are almost identical.
p.2-64, Sec. 2.3.7,1 In their article, Pandy, et.al. did not
say the dwellings were "unventilated11 tout only »fillventilated*< cf.
(p,414 of Vol. 4 of Stockholm conference).
p.2-122. A Bore recent paper on the "BaJce-Out11 procedure is:
Girman, J., Alevantis, L*, Kulasingham, G., Petreas, and Webber,
L.(1987) "A Bake-Out of an Office Building" proceedings of the 4th
International Conference on Indoor Air Quality and climate, Berlin.
Table 2-39. A more recent paper which demonstrated irritant
effects to be associated with HCHQ exposure in a state-wide random
survey of mobile homes is: Liu, Kai-Shem Huang, Fan-Yen? Hayward,
S.8., and Wesolowsfci, J.J. (1987). "Irritant Effects of
Formaldehyde In Mobile Homes", proceedings of the 4th International
Conference on Indoor Air Quality and Climate, Berlin.
p. 2-95. Top of page -it might be worth noting that the
araphiboles are also more resistant to acid than is chrysotile.
This is especially true of crocidolite.
p. 2-95. One of the more important uses of asbestos has been
in spray-on fireproofing and acoustical insulation.
• ;* •( ,, ,
p. 2-96. Many of the studies mentioned in thiys report
measured concentrations of, airborne asbestos in ng/m^. Such
measurements involve to* use of indirect preparation, including
ashing and sonic dispersion. This means that the results_are not
interpretable in terms of fiber concentration or fiber size. _ in
most of these studies this is not a serious flaw, as long as fairly
high concentrations are detected. However, the Sebastian study on
floor tile should have been repeated using direct methods. This
is because it is not elear how iiuch the fiber* were bound in a
vinyl matrix, which would have been oxidized and removed by ashing,
thus fiber* might have been counted which may or may not have been
biologically relevant.
p. 2-97. Top of page- Most fibers are not too short to be
detected In the optical microscope. They are simply too thin.
p. 2-97, Bottom - chrysotile identification by morphologytis
not enough. Electron diffraction is required for positive
identification.
A-13
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p 2-99. The relationship 300 ng/m3 - 10,000 fibers/in3 seems
rather high. A reference is needed. Our work would indicate^ that
10,000 fibers /m3 usually equals approximately 0.1 to 1 ng/m .
p. 2-103. A discussion of asbestos in homes would be
appropriate,
p 2-130. Polonium 214 decays to lead-21Q with a half-life
of 164 microseconds, rather than 22 years. It is lead-210 that
has a half- life of 22 years.
D 2-131. The text states that radon decay products are very
small particles which agglomerate rapidly and readily attach to
surfaces. Of course atoms can be considered particles in the
Save-plrticle quality sense. However, it would be more informative
just to say Sat the decay product atoms are solids at room
temperature; so that when they are produced by the decay of the
radon gas atoms, they readily agglomerate or attach to surfaces.
p 2-131. Bottom of the page- The lower limit of detection
for radon in air is listed as SOO pci/»f<0.5 pCi/D - Since the
report lists levels measured in outdoor air which are lower than
500 pCi//, this is clearly not a lower Unit of detection for some
methods Even for methods typically used in indoor air , lower
limits of detection are commonly achieved using longer integration
times.
p. 2-132. Bottom of the page- "The radon is released from
the water at elevated temperature*, and when the water is. ..
should read "Radon release from the water increases as the water
temperature increases, or when the water is...
u 2-134. Mow could comparison to the National Ambient Air
Quality Standard for particular matter be illuminating in any way?
D 2-137, 2-138, It does not make sense to state that the
link between a given air concentration of radon and the consequent
ration dosage involve* the ratio of indoor radon levels to
outdoor level*.
p, 2-146, second to last sentence. "Typo on knowledge".
p 2-146. This section should briefly discuss the , measurement
Snits that are often used, viz., cfm/m3. Th* Pfe^saA|^t?v
should disc**, typical V*!UM found, i * well y the generally
accepted "consensus" standard of about 1000 cfm/m .
p, 2-li3. The author* state that "Biologically ' «£j™5
exposures to electric and magnetic fields ... are widespread.
• ThEgiv* ^ definition of "biologically ^ relevant", if, ai i I
suspect, they are referring to heaitH endpoints studied in the
A-14
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theiwcfda3C^eri«entS *iac%ss*d subsequantly, then they should change
(p.2-167), "There are data consistent with a ofiSSifele^v emphasis?
connection between exposure,.,.». «uu«i«.t&j
h* in£lJli;< od°rs is discussed in the welfare section. It would
be interesting to state why here instead of in the health section
say under a comfort heading,
p.4-22. First paragraph, second sentence. Delete "in" 1
p.5-1, last sentence of Introduction. Insert the word "to"
before w a source ".
p.5-11, The authors state that "...the problems are caused
by a mixture of pollutants and by the interaction of these mixtures
with *h« building system." Although this may be true in many
cases, there are others wh*re the problem is caused by a single
parameter, e.g. excess CO, Further,, the interaction can be with
more than ]ust the system, e.g. it can be with psychological
psychosocial factors, etc.
p»5-l. It is not clear what ttie difference is between two of
the six categories, "building system source and sink effects" and
effects of sources and sinks". Further, an important research
need is missing, viz. research in areas such as psychological,
psychosocial, mass hysteria, etc. Occupants and their behavior can
be considered part of the building "system". Although these are
difficult research areas, the SBS problem will never be fully
understood unless ±hey are taken into account. The author's lacjc
of discussion of these topics in this document is conspicuous.
Appendix E-
This is a useful reference base. It would be much more useful if
it could also be categorized according to subject matter, i would
also recommend a clear statement on tfce first page indicating where
abstracts and papers could be sent by author* in order to minimize
emissions in subsefuent updates.' It also would be very useful if
this data base could be put on floppies (in. ASCII) and made
available on reque*t to authors and researchers in IAQ.
A-15
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OF THE RADIATION ADVISQRV
TO THg
IMPOQR AIR QUALITY. AND TOTAL. HOMAM
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RAC
Radiological Assessments Corporation
November 13, 1987
Dr. Morton Lippmann, Chairman
Indoor Air Quality/Total Human Exposure Subcommittee
Science Advisory Board
U.S. Environmental Protection Agency
Room 1145 W, Waterside Mall
401 M Street SW
Washington, D.C 20460
Dear Dr, Lippmann:
The Radiation Advisory Committee has reviewed the "EPA Indoor Air
Quality Implementation Plan-A Report to Congress Under Title IV of the
Superfund Amendments and Reauthorization Act of 1986;Radon Gas and
Indoor Air Quality Research." In order to keep in mind the objectives of the
Report to Congress, I have restated Congressional expectations as they were
presented to us earlier this summer.
"...The Report is to describe the state of knowledge concerning risks to
human health of indoor air pollutants; the locations and amounts of
indoor air pollutants in structures through the country; existing
standards for indoor air pollutants suggested by Federal and Slate
governments or scientific organizations and the risk to health
associated with such standards; research needs and the relative priority
of these needs; and the effectiveness of possible government actions to
mitigate health risks associated with indoor air quality problems."
The Committee kept this charge in mind as we performed our review. It is
noted, however, that we focused on those sections dealing with radon (the
main report and Appendix C). Our comments are summarized in the
information that follows.
Radiological Assessments Corporation
-------
Dr. Morton Uppmarut
, Page!
General Comments
In general, the plan is satisfactory and should meet the expectations of
Congress. The summary should be carefully edited and Appendix C
should be updated to include recent date that have been published on
radon. r
The Committee is concerned, however, with recent information
regarding the status of the National Radon Survey, which Is included
as a part of the plan and which has been specifically mandated by
Congress. It was pointed out to the Committee at its last meeting, that
funding for the National Radon Survey has been eliminated in the
budget plan for FY 1988, The Committee can understand that faced
with limited funds and unlimited demand, it might be decided that
this relatively expensive project should be deferred or even cancelled
all together. We find this troublesome, however, since without this
authoritative survey, it is going to be very, difficult to decide how to
attack the indoor radon problem. It is certainly recognized that risk
from radon in indoor air ranks highly among total airborne
constituents known to be present in most buildings.
As one of its responsibilities recently, the Radiation Advisory
Committee established a Subcommittee to review Agency plans for
the National Radon survey. Consequently, the Committee made
recommendations' for what is considered a scientifically satisfactory
study for the frequency distribution of radon exposures nationwide.
The study might nol answer all questions raised about factors
influencing the radon levels, since it was realized that some of these
answers would require a much larger study. Nevertheless, the
National Survey would answer key questions related to radon in
indoor air and assist greatly in putting exposure to radon and progeny
in better perspective.
The Committee believes that it is essential to obtain a reasonable fix
on th* magnitude of the indoor air radon problem. This step can best
be taken with the proposed National Survey on radon. It is therefore
strongly recommended that this survey be supported and carried out
as soon as possible.
Radiological Assessments Corporation
-------
Dr. Morton Lippmann
Comments on The Reeort to Con
Specific Commenfc on the Report to
Summary
Pagel
The summary deals with generalities and lacks specific tangibles The
Committee believes that Congress will find it difficult to understand
what is being proposed as a plan based on the summary alone
Effective summaries are difficult to write, of course, but this one could
have been much more specific about the general types of pollutants to
be looked and how the relative importance of each will be addressed
As it is currently written, the summary does not do justice to the rest
of the document,
As a minor point, HUD is not mentioned here. It's role is given on
page 21 and the planned coordination with HUD throughout seems
much less than we would have expected, given that HUD has been
involved in substantial research in this area and presumably has a
continuing interest, especially, as specifications for new houses are
involved.
Pages 7-10, Activities and Accomplishments to Date
This section contains a lot of specifics and is generally good and
informative. However, there is nothing here at all about progress that
EPA has already made on radon. More information should be
included here on what has been accomplished to date.
Pages 10-17, Near Term Implementation Plan
This section is also good where it is specific, however, much of the
material contains generalities. Again there is nothing presented on
radon and a cross reference to Appendix C as a minimum would be
helpful. Note that in the table on page 24 under radon in the right
hand column on health effects, the end product should not be
"cancer" which implies cancer in general, but "lung cancer" since this
is the only type of cancer which radon induces.
Radiological Assessments Corporation
-------
Dr. Morton tippmann
Comments on The Report to Congress paS° 4
Appendix C
Since pages Ml are missing, the reader might wonder why these pages
were omitted. 'As a minimum, some statement about their content
and why they were not included should be added.
page 12, lines 1-4
It is true that radon comes from radium but the radium comes from
uranium, and it is the distribution of uranium in soil that begins the
decay chain. We recommend adding to the first sentence".,.and is
itself a decay product of uranium."
page 14, Implementation Plan
We recommend separating radon exposure and health risk since they
are quite distinct and health risk dtsewes its own bullet.
page 17, (d)
This section points to a highly desirable need to ensure sound
measurement methods. However, it also brings up the question of
how all the measurements made by commercial firms could be
utilized. For example, for epidemiologkal purposes, lor contributing
to our^ knowledge of a national average background level, etc Perhaps
such firms could be required to publish their results or submit them to
EPA in a form that would make them useful.
pagt 17, (e)
Health risks should have its own section and tht information could be
expanded. Reviewing the miner studies is still an important thing to
do and information on them keeps accruing. This fact is somewhat
buried ill the last paragraph-
page 18, paragraph 1
Isn't NCI (Boicef also conducting or collaborating in some studies in
New Jersey, Stockholm, and China?
page 18, paragraph 2
The BUR IV Report being referred to as published in 1987 has not yet
been released.
Radiological Assessments Corporation
-------
Dr. Morton Lippmann
Comments on The Report to Congress
Pago 5
page 19, paragraph 1
Among these four mitigation techniques there is no discussion of
lT°' VTiah°n' *hrouShou* P^s 19-21 even though it is
that simple basement exhaust fans are very effective I some
&* *?"' t appears ** ^
expanded based on the recent work by OEET,
page 20
It seems that greater involvement with HUD could have been
expected in (c) and (d).
page 24, Public Information
EPA deserves credit for getting something done here. The brochures
produced by the Agency are very good, wocnures
page 25, line 1
"A copy of DOE's Radon Research Program Plan is attached as
Appendix E the plan is not attached. Appendix E is a bibliography.
review. Please contact me if
comments will 1
can be of further assistance.
Sincerely,
., Ph.D.
airman
copy to; Members, Radiation Advisory Commitej
Radiological Assessments Corporation
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