F, or indirectly in discussions of air quality relative to some possible eere.energy/buildings/publications/pdfs/energysmartschools/ess_o-and-m-guide.pdf.

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Occupational Safety and Health Act of 1970fiTo assure safe and healthful working conditions for working men and women; by authorizing enforcement of the standards developed under the Act; by assisting and encouraging the States in their efforts to assure safe and healthful working conditions; by providing for research, information, education, and training in the ˜eld of occupational safety and health.flThis publication provides a general overview of a particular standards-related topic. This publication does not alter or determine compliance responsibili- ties which are set forth in OSHA standards, and the Occupational Safety and Health Act of 1970. More- over, because interpretations and enforcement poli- cy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the courts.Material contained in this publication is in the public domain and may be reproduced, fully or partially, without permission. Source credit is requested but not required.This information will be made available to sensory- impaired individuals upon request. Voice phone: (202) 693-1999; teletypewriter (TTY) number: 1-877- 889-5627.

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Indoor Air Quality in Commercial and Institutional Buildings Occupational Safety and Health AdministrationU.S. Department of LaborOSHA 3430-04 2011The guidance is advisory in nature and informational in content. It is not a standard or regulation, and it neither creates new legal obligations nor alters existing obligations created by OSHA standards or the Occupational Safety and Health Act. Pursuant to the OSH Act, employers must comply with safety and health standards and regulations issued and enforced by either OSHA or by an OSHA- approved State Plan. In addition, the Act™s General Duty Clause, Section 5(a)(1), requires employers to provide their workers with a workplace free from recognized hazards likely to cause death or serious physical harm.

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2ContentsIntroduction 3Background 3 Bene˜ts of Mitigation of IAQ Problems 4 Health Effects 4 Sources of Indoor Air Pollutants 5 Common Pollutant Categories 6 Prevention or Control IAQ Problems 6 IAQ Management Approach 6 Identi˜cation and Assessment 7 Control Methods 7 Seeking Professional Assistance 8Applicable Standards and Regulations 9 OSHA Standards 9 Standard Interpretations 9 State Programs 10 National Consensus Standards 10OSHA Assistance, Servicesand Programs 11Appendix A: Common Indoor Air Contaminants 16Appendix B: Steps to Improve Indoor Air Quality 19Appendix C: HVAC System Maintenance Checklist 20Appendix D: Investigating IAQ Problems and Complaints 21Appendix E: Selected Resources 22 Hazard Recognition 22 Evaluation and Control 23Appendix F: OSHA-Sponsored Environmental Tobacco Smoke Workshops 25 Workshops I – III 25References 26

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3IntroductionIndoor air quality (IAQ) is a major concern to businesses, schools, building managers, tenants, and workers because it can impact the health, comfort, well-being, and productivity of the building occupants. OSHA recognizes that poor IAQ can be hazardous to workers™ health and that it is in the best interest of everyone that building owners, managers, and employers take a proactive approach to address IAQ concerns. This OSHA guidance document on IAQ provides practical recommendations that will help prevent or minimize IAQ problems in commercial and institutional buildings, and help resolve such problems quickly if they do arise. It provides ˚exible guidance to employers to help them keep their build- ings free of pollutants or conditions that lead to poor IAQ. It also provides information on good IAQ management, including control of airborne pollutants, introduction and distribution of adequate make-up air, and maintenance of an acceptable temperature and relative humidity. Temperature and humidity are important because thermal comfort underlies many complaints about fipoor air quality.fl Some of the information presented here has been derived from the Environmental Protection Agency™s (EPA) report, fiAn Of˜ce Building Occupant™s Guide to IAQfl (1)1 and other documents listed in Appendix E, Selected Resources. The issue of environmental tobacco smoke will only be addressed in Appendix F, or indirectly in discussions of air quality relative to some possible components of tobacco smoke, e.g., carbon monoxide, carbon dioxide, particulates, etc. In 1998, OSHA conducted a series of three workshops on this issue and the proceedings of these work- shops were published in 1999. See Appendix F for more information.This document is directed primarily at employers, building owners and managers, and others responsible for building maintenance, but may also be used as a basic reference for all those involved in IAQ issues. Furthermore, information present- ed here can help with the decision of whether or not the services of an outside professional may be needed. The advice of a medical professional should always be sought if there are any immediate health issues. Contractors and other professionals (e.g., industrial hygienists or other environmental health and safety professionals) who respond to IAQ concerns, as well as members of the general public, may also ˜nd this information helpful.BackgroundIAQ has been identi˜ed by the EPA as one of the top ˜ve most urgent environmental risks to public health (2). The Centers for Disease Control and Prevention (CDC) estimates that the majority of Americans spend approximately 90 percent of their time indoors (3). On average, of˜ce workers spend approximately 40 hours a week in of˜ce buildings. These workers also study, eat, drink, and, in cer- tain work settings, sleep in enclosed environments where make-up air (i.e., fresh air added to re- circulated air) may be compromised. For this reason, some experts believe that more people may suffer from the effects of indoor air pollution than from outdoor air pollution.Each building has its own set of circumstances. Air quality may be determined by the site of the building, its original design, renovations, whether air handling systems have been maintained, occupant densities, activities conducted within the building, and the occupants™ satisfaction with their environment. IAQ problems can arise from a single source or any combination of factors. Inadequate IAQ may begin with poor building design or failure of the building enclosure or envelope (roof, facade, foundation, etc.). Other issues may be associated with the location of the building and mixed uses of the building. Many common IAQ problems are associated with improperly operated and maintained heating, ventilating and air-conditioning (HVAC) systems, overcrowding, radon, moisture incursion and dampness, presence of outside air pollutants, and the presence of internally generated contami- nants such as use of cleaning and disinfecting supplies and aerosol products, off-gassing from materials in the building, and use of mechanical equipment. Improper temperature and relative humidity conditions can also present problems, especially concerning comfort.Many IAQ complaints are associated with ˚aws in building design and by inadequate routine preventive maintenance of building enclosures (envelopes), plumbing, and HVAC systems (2, 4, 5). To resolve many IAQ problems, a preventive main-tenance program should be established based on the system™s recommended maintenance schedule outlined by the architect or engineer, the manufac- turer, or an HVAC professional. Regular preventive maintenance not only ensures that systems are operating properly, but also can result in cost savings, improved operating ef˜ciency, and increased worker productivity (6). The U.S. Green 1The numbers in parentheses refer to speci˜c entries in the last section of this document titled fiReferences.fl

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4Research has linked building dampness with signi˜cant health effects. Numerous species of bacteria and fungi, in particular ˜lamentous fungi (mold), can contribute signi˜cantly to indoor air pollution (4, 15-20). Whenever suf˜cient moisture is present within workplaces, these microbes can grow and affect the health of workers in several ways. Workers may develop respiratory symptoms, allergies, or asthma (8). Asthma, cough, wheezing, shortness of breath, sinus congestion, sneezing, nasal congestion, and sinusitis have all been associated with indoor dampness in numerous studies (21-23). Asthma is both caused by and worsened by dampness in buildings. The most effective means to prevent or minimize adverse health effects is to determine the sources of persistent dampness in the workplace and elimi- nate them. More details on preventing mold-related problems can be found in the OSHA publication titled: fiPreventing Mold-Related Problems in the Indoor Workplacefl (17). Other environmental fac- tors such as poor lighting, stress, noise, and thermal discomfort may cause or contribute to these health effects (8). Building Council (USGBC), among others, has demonstrated that IAQ issues can be readily and practically addressed when building systems are retro˜tted for energy ef˜ciency. (http://www.usgbc.org/DisplayPage.aspx?CMSPageID=221#v2008)Bene˜ts of Mitigation of IAQ ProblemsGood IAQ in buildings is an important component of a healthy indoor environment. It contributes to a favorable and productive environment for building occupants, giving them a sense of comfort, health, and well-being. Signi˜cant increases in worker productivity have also been demonstrated when the air quality was adequate (6). Research has also shown that workers in buildings with adequate air quality have reduced rates of symptoms related to poor air quality (7).Health Effects Symptoms related to poor IAQ are varied depend- ing on the type of contaminant. They can easily be mistaken for symptoms of other illnesses such as allergies, stress, colds, and in˚uenza. The usual clue is that people feel ill while inside the building, and the symptoms go away shortly after leaving the building, or when away from the building for a period of time (such as on weekends or a vacation). Health or symptom surveys, such as the one included in Appendix D, have been used to help ascertain the existence of IAQ problems.Failure of building owners and operators to respond quickly and effectively to IAQ problems can lead to numerous adverse health consequences. Health effects from indoor air pollutants may be experi- enced soon after exposure or, possibly, years later (8, 9, 10). Symptoms may include irritation of the eyes, nose, and throat; headaches; dizziness; rashes; and muscle pain and fatigue (11, 12, 13, 14). Diseases linked to poor IAQ include asthma and hypersensitivity pneumonitis (11, 13). The speci˜c pollutant, the concentration of exposure, and the frequency and duration of exposure are all important factors in the type and severity of health effects resulting from poor IAQ. Age and preexisting medical conditions such as asthma and allergies may also in˚uence the severity of the effects. Long- term effects due to indoor air pollutants may include respiratory diseases, heart disease, and cancer, all of which can be severely debilitating or fatal (8, 11, 13).

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6Prevention and Control of IAQ ProblemsIAQ Management ApproachIdeally, an employer should use a systematic approach when addressing air quality in the work-place. The components of a systematic approach for addressing IAQ are the same as those for an overall safety and health program approach, and include management commitment, training, employee involvement, hazard identi˜cation and control, and program audit. Management needs to be receptive to potential concerns and complaints, and to train workers on how to identify and report air quality concerns. If employees express concerns, prompt and effective assessment and corrective action is the responsibility of management.It is recommended that building owners/managers develop and implement an IAQ management plan to address, prevent, and resolve IAQ problems in their speci˜c buildings. The EPA™s report, IAQ Tools for Of˜ce Buildings, provides a set of ˚exible and speci˜c activities that can be useful to building owners/managers for developing such a plan. A key feature of the plan is the selection of an IAQ Coordi- nator. The role and functions of an IAQ Coordinator are described in Section 3 of the EPA™s report, IAQ Tools for Schools Action Kit (24). Other critical features of the plan include establishing necessary IAQ policies, assessing the current status of IAQ in buildings through periodic inspections, maintaining appropriate logs and checklists, performing necessary repairs and upgrades, and implementing follow-up assessments or other needed actions.Employers who lease space should be familiar with the building management™s program and methods for mitigating or resolving indoor air quality prob- lems. It is especially important for employers to know who to contact in buildings where there is mixed use and pollutants are emanating from other sources in the building. Employers should negotiate leases that specify IAQ performance criteria. For example, a lease should specify that the space be ventilated with outdoor air while occupied and at a rate described in ASHRAE 62.1 Ventilation for Acceptable Indoor Air Quality. An important management strategy is to foster a team approach for problem solving and consensus building. The IAQ Team should include, but not necessarily be limited to, building occupants, administrative staff, facility operators, custodians, building healthcare staff, contract service providers, and other interested parties.Common Pollutant CategoriesAlthough there are numerous indoor air pollutants that can be spread through a building, they typically fall into three basic categories: biological, chemical, and particle (1).BiologicalExcessive concentrations of bacteria, viruses, fungi, dust mites, animal dander, and pollen may result from inadequate maintenance and housekeeping, water spills, inadequate humidity control, condensation, or water intrusion through leaks in the building envelope or ˚ooding.ChemicalSources of chemical pollutants (gases and vapors) include emissions from products used in the building (e.g., of˜ce equipment; furniture, wall and ˚oor coverings; pesticides; and cleaning and consumer products), accidental spills of chemicals, products used during construction activities such as adhesives and paints, and gases such as carbon monoxide, formaldehyde, and nitrogen dioxide, which are products of combustion.Particle (Non-biological)Particles are solid or liquid, non-biological, sub- stances that are light enough to be suspended in the air. Dust, dirt, or other substances may be drawn into the building from outside. Particles can also be produced by activities that occur in buildings such as construction, sanding wood or drywall, printing, copying, and operating equipment.Some of the most common indoor air pollutants, and the means to control or prevent them, are discussed in Appendix A.

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7the effectiveness of ventilation (5, 26), and exces-sive population density (e.g., overcrowding). Ł Ensure that good housekeeping practices are being applied.Ł Ensure that routine preventive maintenance and upkeep of buildings is being performed. A preventive maintenance program provides the care to all building systems and components that keeps them operating at peak performance according to manufacturer™s speci˜cations, and also allows for early detection of problems (1, 18).Ł Ensure that scheduled renovations are isolated from the building™s general dilution ventilation system when occupants are in the building.Control MethodsThere are three basic control methods for lowering concentrations of indoor air pollutants:1. Source managementSource management includes removal, substitution, and enclosure of sources. It is the most effective control method when it can be applied practically. For example, the U.S. Consumer Product Safety Commission recommends installing carpets that are low-volatile organic compound (VOC) emitters, and encourages consumers to ask retailers or installers about the carpet industry™s voluntary figreen labelfl program for new carpets (27). According to the carpet industry, the green and white logo displayed on carpet samples informs the consumer that the speci˜c manufacturer™s product has been tested by an independent laboratory and has met the criteria for very low emissions (28). The label, however, is not a guarantee that the carpet will not cause health problems (27). Another example is that the employer can set up temporary barriers or place the space under negative pressure relative to adjoining areas to contain the pollutants during construction activities. 2. Engineering controlsa. Local exhaust Local exhaust, such as a canopy hood, is very effective in removing point sources of pollutants before they can be dispersed into the building™s indoor air.b. General dilution ventilationGeneral dilution ventilation systems, when properly designed, operated, and maintained, will control normal amounts of air pollutants. A well-designed and functioning HVAC system controls temperature and relative humidity levels Lastly, following up with affected personnel will serve to validate the effectiveness of the mitigation activities. For more information about the IAQ management approach, refer to OSHA™s Safety and Health Topics Page on Injury and Illness Prevention Programs. (http://www.osha.gov/dsg/topics/safetyhealth/index.html).Identi˜cation and AssessmentMethods used in an IAQ investigation may include identifying pollutant sources, evaluating the HVAC system performance, observing production process- es and work practices, measuring contamination levels and employee exposures, providing medi- cal testing or physical examinations, conducting employee interviews, and reviewing records of medical tests, job histories, and injuries and illness- es. The Appendices provide resources and check- lists that building owners, managers, and occupants can use to investigate IAQ complaints, document walkthrough inspections, and correct IAQ problems.To prevent IAQ problems effectively and ef˜ciently, building managers should know and understand the history of the building (construction, uses, maintenance, etc.). If possible, owners and man- agers should maintain blueprints and construction documents, including information about any renovations of the building.Some important practices include:Ł Inspect and assess the building envelope, includ-ing the roof, walls, and foundation, and promptly respond to identi˜ed problems. Routinely check the building for water leaks, seals around doors and windows, and any visible damp or moist parts of the building. Clean and dry any damp or wet building materials and furnishings within 24 to 48 hours after detection to prevent the growth of mold.Ł Ensure and validate that the building is maintained under a slight positive pressure (i.e., air comes out of the building when exterior doors are opened).Ł Check whether the temperature and humidity are maintained in a recommended comfort range (temperature: 68 to 78 degrees and relative humidity: 30% to 60%) (25).Ł Ensure that routine maintenance of the HVAC system is being performed, including the performance of the system bringing outdoor air into the building. (1).Ł Monitor carbon dioxide (CO2) levels. The carbon dioxide levels can be used as a rough indicator of

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8storing food properly, and choosing cleaning products and methods that minimize the introduction of pollutants into the building (18). These steps are outlined in Appendix B.Seeking Professional AssistanceSome indoor air problems can be resolved when good practices are put in place to control contaminants and building personnel follow good housekeeping approaches. Other problems may be dif˜cult to resolve, however, and may require outside assistance. A building owner or manager may ˜rst want to consult local, state, or federal government agencies (e.g., education, health, environmental protection, or agriculture agencies) for assistance or direction in solving IAQ problems. These governmental agencies may be able to help an employer identify the types of experts who could best assist them.Examples of experts include:Ł Structural engineers – address issues with structural elements such as corrosion problems in a building™s foundation; Ł Architects – responsible for designing the building envelope and can mitigate water intrusion problems by designing vapor barriers;Ł Mechanical engineers – test and balance HVAC systems and may be able to assess and recom- mend repairs/replacement of HVAC systems and local exhaust ventilation systems; andŁ Industrial hygienists – assess general IAQ parameters such as air changes in a building, carbon dioxide levels, carbon monoxide levels, and other indoor pollutants, and also evaluate contaminant levels.There may be private ˜rms or consultants in your area with experience in IAQ work. Such ˜rms may be found in general resources such as a telephone directory (e.g., under fiEngineers,fl fiEnvironmental and Ecological Services,fl fiLaboratories-Testing,fl or fiIndustrial Hygiene Consultantsfl), on the Internet, or by asking building owners/managers for refer- rals. Some professionals who work with IAQ issues must meet licensing and certi˜cation requirements to practice in their disciplines. A consultant should base any testing recommendations or protocol on a thorough visual inspection, walkaround, and interviews with building occupants.to provide thermal comfort, distributes adequate amounts of outdoor air to meet the ventilation needs of building occupants, and also dilutes and removes odors and other contaminants. Testing and rebalancing of HVAC systems are essential when partitions are moved in buildings. Appen- dix C contains an HVAC System Maintenance Checklist that can be used to assist in routine maintenance of the HVAC system. For certain situations, such as painting and carpet cleaning, temporarily increasing ventilation can help dilute the concentration of vapors in the air.c. Air cleaningAir cleaning primarily involves the removal of particles from the air as the air passes through the HVAC equipment. Most HVAC system ˜ltration is provided to keep dirt off of coil surfaces to promote heat transfer ef˜ciency. Most smudging observed around air supply diffusers in a ceiling result from entrainment (trapping) of dirt particles in the space that accumulate there because of poor housekeeping.3. Administrative controlsa. Work ScheduleThrough scheduling, managers can signi˜cantly reduce the amount of pollutant exposure in their buildings. For instance:1. Eliminate or reduce the amount of time a worker is exposed to a pollutant (i.e., schedul- ing maintenance or cleaning work to be accomplished when other building occupants are not present).2. Reduce the amount of chemicals being used by or near workers (i.e., limit the amount of chemicals being used by the worker during maintenance or cleaning activities).3. Control the location of chemical use (i.e., perform maintenance work on moveable equipment in a maintenance shop as opposed to the general area, or locate the equipment (e.g., printers, copiers) in a separate room).b. Education Education of building occupants regarding IAQ is important (29). If occupants are provided with information about the sources and effects of pollutants under their control, and about the proper operation of the ventilation system, they can alert their employer and/or take action to reduce their personal exposure.c. HousekeepingHousekeeping practices should include prevent- ing dirt from entering the environment (using, for example, walk-off mat systems), removing dirt once it is in the building, disposing of garbage,

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9Applicable Standards and RegulationsOSHA does not have a general IAQ standard, but does provide guidelines addressing the most common workplace complaints about IAQ, which are typically related to temperature, humidity, lack of outside air ventilation, or smoking. OSHA standards address potential hazardous conditions leading to serious physical harm or death. Such standards may include those for speci˜c air contaminants, ventilation systems, or the General Duty Clause of the Occupational Safety and Health Act of 1970 (OSH Act). This section highlights OSHA standards, standards interpretations (of˜cial OSHA letters of interpretation of its standards), and national consensus standards related to IAQ.OSHA StandardsAll OSHA regulations, interpretations, and the OSH Act can be found on www.osha.gov. Important OSHA statues and standards include: Ł Occupational Safety and Health Act of 1970Section 5(a)(1), often referred to as the General Duty Clause, requires employers to fifurnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.flSection 5(a)(2) requires employers to ficomply with occupational safety and health standards promulgated under this Act.flSome of the applicable OSHA Standards are:Ł 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses.Ł 29 CFR 1910.94, Ventilation.Ł 29 CFR 1910.1000, Air Contaminants.Ł 29 CFR 1910.1048, Formaldehyde.Ł 29 CFR 1910.1450, Occupational exposure to hazardous chemicals in laboratories.Standard InterpretationsŁ Enforcement policy for respiratory hazards not covered by OSHA Permissible Exposure Limits. (January 24, 2003.) https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETA-TIONS&p_id=24749.Ł Air monitoring results, citations, and employee exposure records. (March 27, 2002.) https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24261.Ł The use of ozone gas from ozone generators in a large room. (April 3, 1995.) https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21753.Ł Request for a list of all OSHA-regulated air contaminants. (March 22, 1995.) https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21731.Ł Record retention requirements for indoor air quality documents and reports. (August 1, 2002.) http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24255.Ł Reiteration of existing OSHA policy on indoor air quality: of˜ce temperature and environmental tobacco smoke. (February 23, 2003.) http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=IN- TERPRETATIONS&p_id=24602.

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