IAQ Standards and Guidelines

Occupational Safety and Health Administration
Environmental Protection Agency
Other US agencies
Other countries
State and local governments
ASHRAE

Although there are no currently defined federal regulations covering indoor air quality (IAQ), there are a number of standards and guidelines recommended by international health associations, industry organizations, state governments, and private programs and researchers. The US Environmental Protection Agency (EPA)  has certain IAQ requirements for its own facilities, both in allowable emissions from products and final acceptance for pollutant air concentrations in newly constructed buildings. Federal regulation has been proposed and numerous programs exist to control pollutant emissions from materials and furnishings used in buildings. The current GREENGUARD Environmental Institute has been established to control emission levels and pollutant contributions from construction materials and furnishings in buildings. In addition, ASHRAE/ANSI Standard 62-2001, Ventilation for Acceptable Indoor Air Quailty, the American Society of Heating, Refrigerating and Air-Conditioning Engineers  ventilation standard,  ensures adequate and effective ventilation to buildings. Ventilation and pollutant source control have been recognized as the primary ways to control indoor air quality in buildings. Currently, these programs are voluntary, but use of these controls is very effective in minimizing pollutant levels and odors in buildings.

Occupational Safety and Health Administration

Even though the Occupational Safey and Health Administration (OSHA) estimates that of more than 70 million Americans working indoors (some 21 million are exposed to poor indoor air), the agency has yet to implement guidelines it proposed in 1994. If the regulations went into effect, OSHA could fine companies that violated them. The proposed regulations would have done some of the following:¹

• Banned smoking in the workplace or required employers to provide separately ventilated smoking areas.

• Develop IAQ compliance plans in non-industrial work sites to protect workers from certain indoor air contaminants, inadequate ventilation, and sick building syndrome, also referred to as building-related symptoms.

• Have periodic inspections and air testing.

• Maintain written records including documentation of reported IAQ problems.

• Control for specific contaminants such as restricting the use of chemicals and pesticides.

• Have a good maintenance program.

• Conduct employee training programs about IAQ.

The Occupational Safety Health Adminstration had estimated the costs for proposed regulations to employers to initially be $1.4 billion with another $8.1 billion annually (primarily related to proper maintenance of building systems and ventilation). Though many companies and Congressional representatives expressed concern about these costs, OSHA also conservatively estimated a savings to employers of $15 billion every year due to increased employee productivity and reduced absenteeism.

In a study of 2000 companies that had adopted no-smoking policies, it was estimated that the average company saved $500 per smoker every year in reduced property damage, cleaning, and maintenance costs.²

In addition, the proposed rule was thought to benefit society by preventing 3 million severe headaches and 4.5 million upper respiratory symptoms caused by poor IAQ. By preventing exposure to secondhand smoke, OSHA estimated that between 5,583 and 32,502 cancer deaths; and between 97,700 and 577,818 coronary heart disease deaths, would be prevented over the next 45 years.³

These proposed IAQ regulations are on the back burner in large part because of opposition from smokers and tobacco companies.⁴ The other reason is that OSHA received about 100,000 comments to the proposed regulations and has to review every single one of them before they can go into effect. Though these proposed regulations cannot be enforced, they are a good starting point on things to do in order to have a good IAQ program.

Though OSHA has standards that are supposed to protect workers against individual contaminants such as benzene and formaldehyde, those standards were set for young, healthy workers with limited and controlled exposures in industrial workplaces. These standards are not applicable to the general population consisting of the elderly, children, immunocompromised, or office workers. The general population is exposed to lower levels of pollutants for extended periods. Most people spend approximately 90 percent of their time indoors. In addition, OSHA has no exposure limits for groups of chemicals that researchers believe might act synergistically. As a result, the standards do not usually protect people from the complex mixture of chemicals that might be found in indoor air since health effects are being seen at levels much lower than the OSHA standards. In addition, the health effects of these chemicals reacting together may not be known for many years to come.⁴

To resolve this, some researchers have suggested much lower exposure limits for people working in offices, such as the lower values the EPA uses for their outside air standards. The reason that the EPA outside air standards were set much lower than the OSHA standards was to protect a population ranging from infants to the elderly as well as those with preexisting lung disease or dysfunction such as people with asthma. Generally, industrial workers for whom the OSHA standards were set are healthier than the general population. Whereas usually only workers are found in industrial workplaces, there are people other than workers inside buildings that may have indoor air concerns such as young children in day care facilities or sick people in healthcare facilities. As a default, standards that have been developed for the outdoor air are used for indoor standards such as those for particles, ozone, carbon monoxide, oxides of nitrogen and sulfur. Acceptable values often used for indoor exposures include 50 µg/m³ of respirable particles and 0.08 ppm ozone.

Even though OSHA may not have a standard for indoor air quality, employers are still required to provide a safe and healthy workplace under the General Duty Clause of the Occupational Safety and Health (OSH) Act. Click here to learn more about workers' rights and employers' responsibilities under the OSH Act.  It is also important to know that all workers are covered under federal OSHA. These regulations are enforced at the state level in the 23 states that are recognized by OSHA as being states that have occupational safety and health standards at least as strict as OSHA's federal standards. In addition, many public employees are not covered at all if their state does not cover them. To see if you are covered, go to the OSHA link given above.

Environmental Protection Agency

Other than asbestos and radon, the EPA does not have any statutory role in the enforcement of IAQ. However, there has been legislation presented in Congress that would require the EPA to create a voluntary program to certify indoor air contractors, but this legislation has never passed.⁵

The EPA has established emissions specifications for office furniture and other products for use in its own facilities. The office furniture specification requires that workstations cannot contribute more than 0.5 mg/m³ of total VOCs; 0.05 ppm of formaldehyde, and 0.1 ppm total aldehydes within one week of receiving and unpacking the furniture. Chairs have to meet one-half of these requirements.

In some regional EPA building construction projects, building air clearance levels have been established at less than 200 µg/m³ for TVOC; less than 20 µg/m³ of formaldehyde; less than 3 µg/m³ of 4-phenylcyclohexene; less than 20 µg/m³ of total particles; less than any existing National Ambient Air Quality Standard (NAAQS); and less than five percent of any existing-TWA (time-weighted average). The building air must come down to these levels before occupancy. Studies such as the State of Washington East Campus Plus Program have shown this to be possible if low-emitting materials are used, ventilation meets ASHRAE standards, and IAQ smart construction and commissioning practices are used. Some overall guidance has been issued from the EPA and the state of Washington on acceptable emissions from products to achieve these clearance levels.

Other US Agencies

The Department of Housing and Urban Development (HUD) and the Consumer Product Safety Commission (CPSC) also have been involved in the development of standards to specify maximum rates of emission of air contaminants from various building and household products.  For example, HUD has issued standards for wood products that limit the level of formaldehyde emissions to 0.2 ppm from plywood and 0.3 ppm from particleboard. These air concentrations are measured by a particular chamber test and should not be construed as acceptable indoor air concentrations. These standards were created to control formaldehyde emissions in pre-manufactured housing where large amounts of pressed wood products are used. These emission standards are generally not sufficient to control formaldehyde levels down to 0.05 ppm, as recommended for indoor environments.

Other Countries

Some countries have regulations that provide for a more comfortable indoor work environment. For example, a builder of buildings in both Paris and Chicago found that the French regulations required for three times as much ventilation and twice as much soundproofing than the building in Chicago?all while slashing energy consumption to half American levels. By law, each workstation in France needs access to natural light, a scarcity in most US offices.⁶ Since artificial light tires people just as much as artificial air, most European building rules require all workers to have access to a window. Several labeling programs are available for controlling the pollutant emissions from products such as Blue Angel in Germany for laser printers and photocopiers. This program has a limit on the amount of ozone, styrene, and particles that a machine can emit while operating. Other programs control the amount of formaldehyde, VOCs and odor that a product can emit and still be acceptable for the indoor environment.

State and Local Governments

In the absence of any action at the national level, several states have begun taking steps on their own to improve IAQ. Because complaints about sick building syndrome, also called building-related symptoms, have become so common, at least 37 out of 53 states and territories have designated an IAQ contact person.⁵ Because tobacco smoke is such a major indoor air pollutant, 45 states and the District of Columbia have laws restricting smoking in public buildings and 19 states and the District of Columbia limit or restrict smoking in private workplaces.⁷ In addition, local governments are now starting to legitimize these sick building-related illnesses as a condition for social benefits. Nearly a dozen states from New Mexico to Maryland now recognize multiple chemical sensitivity (MCS) as a bona fide claim for workers' compensation. Multiple chemical sensitivity is also covered on a case-by-case basis under the Americans with Disabilities Act, so that employers have to make "reasonable accommodations" for those with MCS.

Just recently, states have been proposing legislation to improve the quality of indoor air in the school environment. Here are some examples:

• West Virginia lawmakers require radon testing for new schools within the first year of occupancy and at least every five years thereafter.

• In Virginia, a 12-member task force has been established to identify guidelines and regulations related to IAQ and make recommendations to improve the air in their public schools.

• In Washington state and California, purchase specifications have been made for interior furnishes and furnishings which allow minimal levels of formaldehyde and VOCs. Products meeting low-emission specifications are tested and listed by the Greenguard Environmental Institute. 

ASHRAE

Although ASHRAE has its ventilation standards for commercial and industrial users, they are mostly voluntary. The only exception is if local governments adopt ASHRAE standards into their local building codes. ASHRAE's initial standard 62-1989, Ventilation for Acceptable Indoor Air Quality, defined acceptable indoor air quality as "air in which there are no known contaminants at harmful concentrations as determined by cognizant authorities and with which a substantial majority (80 percent or more) of the people exposed do not express dissatisfaction." However, this guideline did not, and could not assure that no adverse health effects will occur. The 1989 standard has been replaced by ASHRAE standard 2001, which specifies minimum ventilation rates and acceptable indoor air quality. This standard is intended to minimize the potential for adverse heath effects among building occupants. It is applicable to all occupied spaces except where other standards exist. Physical, chemical, and biological contaminants are considered in the standards. The standard is being split to address low-rise residential buildings and all other buildings, separately.

In general, the ASHRAE standard indicates that carbon dioxide levels less than 800 ppm will indicate that sufficient ventilation is being supplied to the building for the populations. Since people give off carbon dioxide when they breath, the level of it found in buildings is an indicator of whether or not sufficient ventilation is present to dilute it and flush it out of the building. The inference can be made that if carbon dioxide is high in buildings, other pollutants also can be elevated and insufficient outdoor air is being brought into the building. Do not confuse the ASHRAE recommendation for carbon dioxide with the OSHA occupational standard of 10,000 ppm. The OSHA standard is for industrial applications and exposure.

The ASHRAE standard recommends that 15 to 20 cubic feet per minute (CFM) of outdoor air should be supplied for each building occupant. All new construction design and building operation plans should ensure that the ASHRAE Standard 62-2001 is being followed to minimize IAQ concerns and associated discomfort and illness. These specifications should be written into the construction and building operation codes. It is also important to control humidity levels to less than 60 percent to 65 percent to control the growth of indoor mold.

References

1. OSHA. Indoor Air Quality Proposed Regulations: Federal Register 59:15968-16039, April 5, 1994.

2. OSHA. Federal Register 59: 15968-16039, April 5, 1994; part VI(C)(3)(b).

3. OSHA. Federal Register 59: 15968-16039, April 5, 1994; part VI(A).

4. Conlin M, Carey J. "Is Your Office Killing You." Business Week. June 5, 2000;issue #3684:114-128.

5. Slap AJ. The legal aspects of indoor air and health. Occupational Medicine: State of the Art Reviews. 1995;10(1):205-215.

6. Echikson W. "Why the air and light are so much better in Paris." Business Week. June 5, 2000;Issue 3684.

7. OSHA. Indoor Air Quality Proposed Regulations: Federal Register 59:15968-16039, April 5, 1994, VI(B)(8)(a).