Welcome to the EBC Seminar The IAQ/Mold Assessment – Getting it Right! – Controlling Your Risk

EBC Seminar The IAQ/Mold Assessment – Getting it Right! – Controlling Your Risk Session Chair and Moderator David Scarchilli Occuhealth, Inc.

EBC Seminar The IAQ/Mold Assessment – Getting it Right! – Controlling Your Risk First Speaker Nancy A. Comeau Massachusetts Division of Occupational Safety

IAQ Issues-A Regulatory Perspective Nancy A. Comeau CIH Occupational Hygiene/Indoor Air Quality Program Supervisor Massachusetts Division of Occupational Safety (DOS)

Goal of this talk Explain who the Division of Occupational Safety is and what authority we have in IAQ arena Explain who the Division of Occupational Safety is and what authority we have in IAQ arena Explain what standards/regulations we generally reference Explain what standards/regulations we generally reference Provide some information about standards/guidance documents/ certifications in IAQ field Provide some information about standards/guidance documents/ certifications in IAQ field

Big Questions Big Questions Which agencies deal with indoor air quality in Massachusetts Which agencies deal with indoor air quality in Massachusetts Is there a difference between public and private sector workers in Massachusetts Is there a difference between public and private sector workers in Massachusetts

Private versus Public Sector Workplaces Private sector workplaces in the US are covered by Federal OSHA Standards. Private sector workplaces in the US are covered by Federal OSHA Standards. Public sector workplaces are not specifically covered by OSHA Standards in Massachusetts Public sector workplaces are not specifically covered by OSHA Standards in Massachusetts

Massachusetts Ma General Law Chapter 149 Section 6 gives DOS the authority to make reasonable rules, regulations and orders for the prevention of accidents and occupational diseases Ma General Law Chapter 149 Section 6 gives DOS the authority to make reasonable rules, regulations and orders for the prevention of accidents and occupational diseases

Massachusetts There is not currently an OSHA Standard for indoor air quality so DOS will investigate IAQ in the private sector using Chapter 149 section 6 (OSHA pre-empts DOS where there are existing standards) There is not currently an OSHA Standard for indoor air quality so DOS will investigate IAQ in the private sector using Chapter 149 section 6 (OSHA pre-empts DOS where there are existing standards) Chapter 149 section 6 also covers municipal and county workplaces however, it does NOT cover State workplaces Chapter 149 section 6 also covers municipal and county workplaces however, it does NOT cover State workplaces Dos still investigates State workplaces on request or complaint noting in report that it is the Personnel Administrator who has authority for State employee health and safety Dos still investigates State workplaces on request or complaint noting in report that it is the Personnel Administrator who has authority for State employee health and safety

OSHA and Indoor Air Quality Federal Register 1994 OSHA Proposed Indoor Air Quality Standard Federal Register 1994 OSHA Proposed Indoor Air Quality Standard December 2001 withdrew proposal and terminated rulemaking proceedings December 2001 withdrew proposal and terminated rulemaking proceedings

DOS Indoor Air Quality Investigations -Carbon Dioxide -Carbon Dioxide -Carbon Monoxide -Carbon Monoxide-Temp/Relative-Humidity -VOC Scan -Formaldehyde-Particulates-Ventilation-Housekeeping -Water Damage -ANY OTHER CONTAMINANT THAT MIGHT BE PRESENT!!

Standards Referenced by DOS in IAQ investigations include: OSHA OSHA EPA EPA Mass State Building Codes Mass State Building Codes Mass Plumbing Codes Mass Plumbing Codes Fire Codes Fire Codes ASHRAE ASHRAE State regs-DEP anti-idling, DPH Smoking regs, etc State regs-DEP anti-idling, DPH Smoking regs, etc Other recognized standards as applicable including trade organizations Other recognized standards as applicable including trade organizations

Carbon Monoxide OSHA Standard is 50 ppm over 8 hour day-way too high for general indoor air quality standard OSHA Standard is 50 ppm over 8 hour day-way too high for general indoor air quality standard DOS uses EPA National Ambient Air Quality Standard (NAAQS) standard of 3 ppm over ambient outside levels as indicator of source of CO or no more than 9 ppm for 8 hour day DOS uses EPA National Ambient Air Quality Standard (NAAQS) standard of 3 ppm over ambient outside levels as indicator of source of CO or no more than 9 ppm for 8 hour day

Carbon Dioxide Only used as INDICATOR of adequate ventilation (Must test in normally occupied space) Only used as INDICATOR of adequate ventilation (Must test in normally occupied space) DOS Recommendations DOS Recommendations Less than 800 ppm-considered to be adequate ventilationLess than 800 ppm-considered to be adequate ventilation ppm considered marginal ventilation ppm considered marginal ventilation ASHRAE 62 –700 ppm above background outside (typically 300) ASHRAE 62 –700 ppm above background outside (typically 300)

Diesel Exhaust/Particulates Anti Idling Laws in many states Anti Idling Laws in many states Massachusetts(M.G.L. Chapter 90, Section 16A) and DEP regulations (310 CMR 7.11(1)(b)) limit vehicle idling to no more than five minutes Massachusetts(M.G.L. Chapter 90, Section 16A) and DEP regulations (310 CMR 7.11(1)(b)) limit vehicle idling to no more than five minutesM.G.L. Chapter 90, Section 16A310 CMR 7.11(1)(b)M.G.L. Chapter 90, Section 16A310 CMR 7.11(1)(b)

Temperature and Relative Humidity DOS uses ASHRAE Standard Thermal Environmental Conditions for Human Occupancy DOS uses ASHRAE Standard Thermal Environmental Conditions for Human Occupancy Considered comfortable for about 80% population Considered comfortable for about 80% population Massachusetts General Law Section 113, Chapter 149 requires that adequate heat be provided from October 15 through May 15 Massachusetts General Law Section 113, Chapter 149 requires that adequate heat be provided from October 15 through May htm htm htm htm htm htm

Formaldehyde OSHA Standard is 0.75 ppm. Far too high for indoor air environments. OSHA Standard is 0.75 ppm. Far too high for indoor air environments. ASHRAE standard 0.1 ppm ASHRAE standard 0.1 ppm Irritant effects found at 0.1 ppm Irritant effects found at 0.1 ppm

Ventilation State Building Codes drive ventilation requirements State Building Codes drive ventilation requirements Ventilation is expected to meet the building code that was in existence at the time the facility was built or significantly renovated Ventilation is expected to meet the building code that was in existence at the time the facility was built or significantly renovated While building codes may change over the years, facility generally does not have to upgrade to new code until renovated While building codes may change over the years, facility generally does not have to upgrade to new code until renovated Natural ventilation (openable windows) allowed Natural ventilation (openable windows) allowed

Ventilation Standards Building Codes-In Massachusetts now in 6 th edition of building code. 6 th edition in effect since 1997-adopted the BOCA mechanical code for ventilation requirements in SPECIFIC settings Building Codes-In Massachusetts now in 6 th edition of building code. 6 th edition in effect since 1997-adopted the BOCA mechanical code for ventilation requirements in SPECIFIC settings Ex-Bowling alleys- 25 cfm outdoor air per personEx-Bowling alleys- 25 cfm outdoor air per person -Auditoriums-15 cfm outdoor air per person -Auditoriums-15 cfm outdoor air per person ASHRAE Standard 62 Ventilation for Acceptable Indoor Air Quality-(may be incorporated as parts of some building codes) ASHRAE Standard 62 Ventilation for Acceptable Indoor Air Quality-(may be incorporated as parts of some building codes) Building codes may be at local level as well Building codes may be at local level as well

Natural Ventilation Mass Building Code, 6 th edition allows for openable windows that meet the requirements of 789CMR section 1208 Mass Building Code, 6 th edition allows for openable windows that meet the requirements of 789CMR section 1208 In summary-requires that openable window be at least 4% of floor area (100 ft 2 room needs 4 ft 2 openable window area) In summary-requires that openable window be at least 4% of floor area (100 ft 2 room needs 4 ft 2 openable window area)

ASHRAE Ventilation Standard (ASHRAE ) ASHRAE standard- if properly executed 80% of people will NOT express dissatisfaction! ASHRAE standard- if properly executed 80% of people will NOT express dissatisfaction! CO2 levels no more than 700 above background levels CO2 levels no more than 700 above background levels

Ventilation Inspection and Cleanup National Air Duct Cleaners Association National Air Duct Cleaners Association( Certified Air System Cleaning SpecialistCertified Air System Cleaning Specialist Certified Ventilation InspectorsCertified Ventilation Inspectors Ventilation System Mold RemediatorVentilation System Mold Remediator

Mold and Water Damage Premise is that all water damage can lead to microbial growth if not dried within hours Premise is that all water damage can lead to microbial growth if not dried within hours If water leaks, must find and eliminate source If water leaks, must find and eliminate source Remove and replace water damaged materials that are porous Remove and replace water damaged materials that are porous Clean and decontaminate non- porous surfaces Clean and decontaminate non- porous surfaces Reference EPA Mold Remediation Guide Reference EPA Mold Remediation Guide

Mold Surveys New ASTM Standards E Standard Guide for Readily Observable Mold and Conditions Conducive to Mold in Commercial Buildings:Baseline Survey Process New ASTM Standards E Standard Guide for Readily Observable Mold and Conditions Conducive to Mold in Commercial Buildings:Baseline Survey Process Goal is to improve quality and consistency of mold surveys Goal is to improve quality and consistency of mold surveys

Analysis/Assessment of Molds Most agencies, including DOS recommend visual, olfactory observation along with detailed history of water damage-Most do not recommend air sampling Most agencies, including DOS recommend visual, olfactory observation along with detailed history of water damage-Most do not recommend air sampling If sampling is done- Use AIHA accredited laboratory- Environmental Microbiology Proficiency Analytical Testing Lab (EMPAT) Use AIHA accredited laboratory- Environmental Microbiology Proficiency Analytical Testing Lab (EMPAT) ( ( Sample methods in accordance with ACGIH, NIOSH, AIHA Sample methods in accordance with ACGIH, NIOSH, AIHA

Mold Standards Currently there are no Federal or professional limits established for molds, spores, mycotoxins or other bioaerosols with which to compare air samples Currently there are no Federal or professional limits established for molds, spores, mycotoxins or other bioaerosols with which to compare air samples

Mold Remediation IICRC S520 Mold Remediation Standard IICRC S520 Mold Remediation Standard IICRC 500 Water Damage Restoration Standard ( IICRC 500 Water Damage Restoration Standard ( EPA Mold Remediation in Schools and Commercial Buildings EPA Mold Remediation in Schools and Commercial Buildings ( (

Construction/Renovation PREVENTING INDOOR AIR QUALITY PROBLEMS DURING CONSTRUCTION AND RENOVATIONPREVENTING INDOOR AIR QUALITY PROBLEMS DURING CONSTRUCTION AND RENOVATION ( ( School construction regs under Dept of Ed in Mass require compliance with SMACNASchool construction regs under Dept of Ed in Mass require compliance with SMACNA "IAQ Guidelines for Occupied Buildings Under Construction" published by the Sheet Metal and Air Conditioning Contractors National Association, Inc. (SMACNA). ( Guidelines for Occupied Buildings Under Construction" published by the Sheet Metal and Air Conditioning Contractors National Association, Inc. (SMACNA). (

Indoor Air Quality Management Plan Always recommend an IAQ Management plan based on: Always recommend an IAQ Management plan based on: Tools for SchoolsTools for Schools OSHA Proposed IAQ StandardOSHA Proposed IAQ Standard EPA/NIOSH Building Air Quality PlanEPA/NIOSH Building Air Quality Plan

Further Information-General IAQ Division of Occupational Safety Division of Occupational Safety Environmental Protection Agency Environmental Protection Agency OSHA OSHA Healthy Schools Website mphaweb.org/pol_schools.html Healthy Schools Website mphaweb.org/pol_schools.html Environmentally Preferable Products Environmentally Preferable Products Department of Public Health Department of Public Health Environmental Law Institute-IAQ Laws Environmental Law Institute-IAQ Lawswww.elistore.org

IAQ Issues-A Regulatory Perspective Nancy A. Comeau CIH Occupational Hygiene/Indoor Air Quality Program Supervisor Massachusetts Division of Occupational Safety (DOS)

Goal of this talk Explain who the Division of Occupational Safety is and what authority we have in IAQ arena Explain who the Division of Occupational Safety is and what authority we have in IAQ arena Explain what standards/regulations we generally reference Explain what standards/regulations we generally reference Provide some information about standards/guidance documents/ certifications in IAQ field Provide some information about standards/guidance documents/ certifications in IAQ field

Big Questions Big Questions Which agencies deal with indoor air quality in Massachusetts Which agencies deal with indoor air quality in Massachusetts Is there a difference between public and private sector workers in Massachusetts Is there a difference between public and private sector workers in Massachusetts

Private versus Public Sector Workplaces Private sector workplaces in the US are covered by Federal OSHA Standards. Private sector workplaces in the US are covered by Federal OSHA Standards. Public sector workplaces are not specifically covered by OSHA Standards in Massachusetts Public sector workplaces are not specifically covered by OSHA Standards in Massachusetts

Massachusetts Ma General Law Chapter 149 Section 6 gives DOS the authority to make reasonable rules, regulations and orders for the prevention of accidents and occupational diseases Ma General Law Chapter 149 Section 6 gives DOS the authority to make reasonable rules, regulations and orders for the prevention of accidents and occupational diseases

Massachusetts There is not currently an OSHA Standard for indoor air quality so DOS will investigate IAQ in the private sector using Chapter 149 section 6 (OSHA pre-empts DOS where there are existing standards) There is not currently an OSHA Standard for indoor air quality so DOS will investigate IAQ in the private sector using Chapter 149 section 6 (OSHA pre-empts DOS where there are existing standards) Chapter 149 section 6 also covers municipal and county workplaces however, it does NOT cover State workplaces Chapter 149 section 6 also covers municipal and county workplaces however, it does NOT cover State workplaces Dos still investigates State workplaces on request or complaint noting in report that it is the Personnel Administrator who has authority for State employee health and safety Dos still investigates State workplaces on request or complaint noting in report that it is the Personnel Administrator who has authority for State employee health and safety

OSHA and Indoor Air Quality Federal Register 1994 OSHA Proposed Indoor Air Quality Standard Federal Register 1994 OSHA Proposed Indoor Air Quality Standard December 2001 withdrew proposal and terminated rulemaking proceedings December 2001 withdrew proposal and terminated rulemaking proceedings

DOS Indoor Air Quality Investigations -Carbon Dioxide -Carbon Dioxide -Carbon Monoxide -Carbon Monoxide-Temp/Relative-Humidity -VOC Scan -Formaldehyde-Particulates-Ventilation-Housekeeping -Water Damage -ANY OTHER CONTAMINANT THAT MIGHT BE PRESENT!!

Standards Referenced by DOS in IAQ investigations include: OSHA OSHA EPA EPA Mass State Building Codes Mass State Building Codes Mass Plumbing Codes Mass Plumbing Codes Fire Codes Fire Codes ASHRAE ASHRAE State regs-DEP anti-idling, DPH Smoking regs, etc State regs-DEP anti-idling, DPH Smoking regs, etc Other recognized standards as applicable including trade organizations Other recognized standards as applicable including trade organizations

Carbon Monoxide OSHA Standard is 50 ppm over 8 hour day-way too high for general indoor air quality standard OSHA Standard is 50 ppm over 8 hour day-way too high for general indoor air quality standard DOS uses EPA National Ambient Air Quality Standard (NAAQS) standard of 3 ppm over ambient outside levels as indicator of source of CO or no more than 9 ppm for 8 hour day DOS uses EPA National Ambient Air Quality Standard (NAAQS) standard of 3 ppm over ambient outside levels as indicator of source of CO or no more than 9 ppm for 8 hour day

Carbon Dioxide Only used as INDICATOR of adequate ventilation (Must test in normally occupied space) Only used as INDICATOR of adequate ventilation (Must test in normally occupied space) DOS Recommendations DOS Recommendations Less than 800 ppm-considered to be adequate ventilationLess than 800 ppm-considered to be adequate ventilation ppm considered marginal ventilation ppm considered marginal ventilation ASHRAE 62 –700 ppm above background outside (typically 300) ASHRAE 62 –700 ppm above background outside (typically 300)

Diesel Exhaust/Particulates Anti Idling Laws in many states Anti Idling Laws in many states Massachusetts(M.G.L. Chapter 90, Section 16A) and DEP regulations (310 CMR 7.11(1)(b)) limit vehicle idling to no more than five minutes Massachusetts(M.G.L. Chapter 90, Section 16A) and DEP regulations (310 CMR 7.11(1)(b)) limit vehicle idling to no more than five minutesM.G.L. Chapter 90, Section 16A310 CMR 7.11(1)(b)M.G.L. Chapter 90, Section 16A310 CMR 7.11(1)(b)

Temperature and Relative Humidity DOS uses ASHRAE Standard Thermal Environmental Conditions for Human Occupancy DOS uses ASHRAE Standard Thermal Environmental Conditions for Human Occupancy Considered comfortable for about 80% population Considered comfortable for about 80% population Massachusetts General Law Section 113, Chapter 149 requires that adequate heat be provided from October 15 through May 15 Massachusetts General Law Section 113, Chapter 149 requires that adequate heat be provided from October 15 through May htm htm htm htm htm htm

Formaldehyde OSHA Standard is 0.75 ppm. Far too high for indoor air environments. OSHA Standard is 0.75 ppm. Far too high for indoor air environments. ASHRAE standard 0.1 ppm ASHRAE standard 0.1 ppm Irritant effects found at 0.1 ppm Irritant effects found at 0.1 ppm

Ventilation State Building Codes drive ventilation requirements State Building Codes drive ventilation requirements Ventilation is expected to meet the building code that was in existence at the time the facility was built or significantly renovated Ventilation is expected to meet the building code that was in existence at the time the facility was built or significantly renovated While building codes may change over the years, facility generally does not have to upgrade to new code until renovated While building codes may change over the years, facility generally does not have to upgrade to new code until renovated Natural ventilation (openable windows) allowed Natural ventilation (openable windows) allowed

Ventilation Standards Building Codes-In Massachusetts now in 6 th edition of building code. 6 th edition in effect since 1997-adopted the BOCA mechanical code for ventilation requirements in SPECIFIC settings Building Codes-In Massachusetts now in 6 th edition of building code. 6 th edition in effect since 1997-adopted the BOCA mechanical code for ventilation requirements in SPECIFIC settings Ex-Bowling alleys- 25 cfm outdoor air per personEx-Bowling alleys- 25 cfm outdoor air per person -Auditoriums-15 cfm outdoor air per person -Auditoriums-15 cfm outdoor air per person ASHRAE Standard 62 Ventilation for Acceptable Indoor Air Quality-(may be incorporated as parts of some building codes) ASHRAE Standard 62 Ventilation for Acceptable Indoor Air Quality-(may be incorporated as parts of some building codes) Building codes may be at local level as well Building codes may be at local level as well

Natural Ventilation Mass Building Code, 6 th edition allows for openable windows that meet the requirements of 789CMR section 1208 Mass Building Code, 6 th edition allows for openable windows that meet the requirements of 789CMR section 1208 In summary-requires that openable window be at least 4% of floor area (100 ft 2 room needs 4 ft 2 openable window area) In summary-requires that openable window be at least 4% of floor area (100 ft 2 room needs 4 ft 2 openable window area)

ASHRAE Ventilation Standard (ASHRAE ) ASHRAE standard- if properly executed 80% of people will NOT express dissatisfaction! ASHRAE standard- if properly executed 80% of people will NOT express dissatisfaction! CO2 levels no more than 700 above background levels CO2 levels no more than 700 above background levels

Ventilation Inspection and Cleanup National Air Duct Cleaners Association National Air Duct Cleaners Association( Certified Air System Cleaning SpecialistCertified Air System Cleaning Specialist Certified Ventilation InspectorsCertified Ventilation Inspectors Ventilation System Mold RemediatorVentilation System Mold Remediator

Mold and Water Damage Premise is that all water damage can lead to microbial growth if not dried within hours If water leaks, must find and eliminate source Remove and replace water damaged materials that are porous Clean and decontaminate non- porous surfaces Reference EPA Mold Remediation Guide

Mold Surveys New ASTM Standards E Standard Guide for Readily Observable Mold and Conditions Conducive to Mold in Commercial Buildings:Baseline Survey Process New ASTM Standards E Standard Guide for Readily Observable Mold and Conditions Conducive to Mold in Commercial Buildings:Baseline Survey Process Goal is to improve quality and consistency of mold surveys Goal is to improve quality and consistency of mold surveys

Analysis/Assessment of Molds Most agencies, including DOS recommend visual, olfactory observation along with detailed history of water damage-Most do not recommend air sampling Most agencies, including DOS recommend visual, olfactory observation along with detailed history of water damage-Most do not recommend air sampling If sampling is done- Use AIHA accredited laboratory- Environmental Microbiology Proficiency Analytical Testing Lab (EMPAT) Use AIHA accredited laboratory- Environmental Microbiology Proficiency Analytical Testing Lab (EMPAT) ( ( Sample methods in accordance with ACGIH, NIOSH, AIHA Sample methods in accordance with ACGIH, NIOSH, AIHA

Mold Standards Currently there are no Federal or professional limits established for molds, spores, mycotoxins or other bioaerosols with which to compare air samples Currently there are no Federal or professional limits established for molds, spores, mycotoxins or other bioaerosols with which to compare air samples

Mold Remediation IICRC S520 Mold Remediation Standard IICRC S520 Mold Remediation Standard IICRC 500 Water Damage Restoration Standard ( IICRC 500 Water Damage Restoration Standard ( EPA Mold Remediation in Schools and Commercial Buildings EPA Mold Remediation in Schools and Commercial Buildings ( (

Construction/Renovation PREVENTING INDOOR AIR QUALITY PROBLEMS DURING CONSTRUCTION AND RENOVATIONPREVENTING INDOOR AIR QUALITY PROBLEMS DURING CONSTRUCTION AND RENOVATION ( ( School construction regs under Dept of Ed in Mass require compliance with SMACNASchool construction regs under Dept of Ed in Mass require compliance with SMACNA "IAQ Guidelines for Occupied Buildings Under Construction" published by the Sheet Metal and Air Conditioning Contractors National Association, Inc. (SMACNA). ( Guidelines for Occupied Buildings Under Construction" published by the Sheet Metal and Air Conditioning Contractors National Association, Inc. (SMACNA). (

Indoor Air Quality Management Plan Always recommend an IAQ Management plan based on: Always recommend an IAQ Management plan based on: Tools for SchoolsTools for Schools OSHA Proposed IAQ StandardOSHA Proposed IAQ Standard EPA/NIOSH Building Air Quality PlanEPA/NIOSH Building Air Quality Plan

Further Information-General IAQ Division of Occupational Safety Division of Occupational Safety Environmental Protection Agency Environmental Protection Agency OSHA OSHA Healthy Schools Website mphaweb.org/pol_schools.html Healthy Schools Website mphaweb.org/pol_schools.html Environmentally Preferable Products Environmentally Preferable Products Department of Public Health Department of Public Health Environmental Law Institute-IAQ Laws Environmental Law Institute-IAQ Lawswww.elistore.org

EBC Seminar The IAQ/Mold Assessment – Getting it Right! – Controlling Your Risk Next Speaker Wagdy A.Y. Anis, AIA, LEED, AP Shepley Bulfinch Richardson & Abbott

EBC Seminar The IAQ/Mold Assessment – Getting it Right! – Controlling Your Risk Thanks to all our Speakers And Program Chair David Scarchilli