For Indoor Air Quality Management - GSA · PDF fileFor . Indoor Air Quality Management . Companion to . ... EPA’s “Guidelines for Response to Clean Water Damage” ... complaint

APPENDIX A

Public Buildings Service

Desk Guide For

Indoor Air Quality Management Companion to

GSA Order PBS 1000.8

Office of Facilities Management

Facility Risk Management Division

September 22, 2016

PBS Office of Facilities Management

Page 1

Indoor Air Quality Management Desk Guide

Table of Contents

Introduction ....................................................................................................................................... 2

Definitions .......................................................................................................................................... 2

Responsibilities .................................................................................................................................. 4

Guidance ............................................................................................................................................ 5

IAQ Requirements .............................................................................................................................. 5

Proactive Reduce Common Problems with IAQ ................................................................................ 8

Respond to Incidents, Complaints and Emergencies …………………………………………………..…………….... 8

Appendix A: IAQ Requirements ................................................................................... 10

Attachment 1: Selected Testing Methods ............................................................... 10

Attachment 2: IAQ Resources ................................................................................. 12

Appendix B: Proactive IAQ Assessment ....................................................................... 13

Attachment 1: IAQ Management Plans ................................................................... 13

Attachment 2: Key “IAQ Check” Assessment Elements .......................................... 14

Attachment 3: Maintaining IAQ during Construction/Renovation ......................... 16

Appendix C: Respond to Incidents, Complaints and Emergencies ............................... 17

Attachment 1: EPA’s “Guidelines for Response to Clean Water Damage” ............. 17

Attachment 2: Sample IAQ Interview Form ............................................................ 22

Attachment 3: Comparison of IAQ Conditions & Issues Reported .......................... 23

Attachment 4: Sample Scope of Work for an IAQ Complaint Assessment ............. 24

Attachment 5: Interpretation of Mold Spore Data ................................................. 26

Appendix D: Indoor Air Quality in GSA Leased Facilities (Best Practices) ..................... 28


Page 2

Introduction

This desk guide is a companion document to the Indoor Air Quality Management Order and identifies the processes, roles, responsibilities, technical references, and best practices to support execution and compliance with said Order.

Definitions

Acceptable IAQ. Building conditions in normally occupied areas are maintained so that airborne gasses, vapors, particles, ventilation and thermal conditions meet the PBS-adopted action levels and do not adversely affect the health or comfort of building occupants. Overall, IAQ is considered acceptable when the requirements of the Operational Guidance on Indoor Air Quality (IAQ) Management are maintained and IAQ complaints are promptly evaluated and resolved. Building occupant. A building occupant an individual authorized to be in a building under the jurisdiction, custody or control of GSA. Clean water, gray water and black water. Clean water refers to instances of flooding, water leaks or water intrusion where the water source is free from pathogens or relatively clean. Gray water (also spelled greywater) is wastewater from domestic sources such as washing operations. Black water is wastewater containing sewage from sanitary sources such as restroom toilets. IAQ issues caused by gray or black water infiltration may require additional precautions and cleanup measures due the presence of pathogens and/or hazardous materials.

Chronic versus acute. Acute refers to short-term or immediate whereas chronic refers to long-term. Acute and chronic can apply to either health effects or building conditions.

IAQ threshold values. Airborne contaminant concentrations and building conditions, referenced in the guidance section of this document, differentiate potential problem areas from non-problem areas in a building or workplace.

IAQ problem. Building conditions are such that airborne gasses, vapors, particles, and thermal conditions are outside of established tolerances and may adversely affect comfort of building occupants.

Indoor Environmental Quality (IEQ). IEQ generally applies to a different, larger set of parameters that can affect workplace productivity and/or comfort. IEQ may include lighting, space layout, furniture (ergonomics), and/or noise considerations. Neither the Order or desk guide is intended to address these or similar IEQ parameters.

Mold. A common term used to describe all fungi and associated by-products (spores, hyphae) that may amplify in the presence of optimum substrates and climate conditions (moisture, temperature). A large variety of fungi can grow on different surfaces especially in the presence of persistent moisture in a building. Although mold is ubiquitous indoors and outdoors, identifying atypical types, concentrations and locations of fungi present can help isolate IAQ problems and lead to effective corrective actions.


Page 3

Nuisance dust. A term used to describe relatively inert particulates that are not considered toxic and which do not cause adverse health effects except at very high concentrations. Nuisance dust is of a size range and composition that may cause some low-level discomfort to building occupants. Nuisance dust measured during IAQ evaluations may often consist of drywall dust, paper fibers, skin cells, and street dust from the building’s exterior. High levels of nuisance dust may also indicate other concerns such as atypical exposures to dust mites and allergens. Effective housekeeping is an important control for nuisance dust.

Off-gassing. A process by which chemicals used in the manufacturing of products such as fabrics, woods and coatings slowly emit (or ‘give off’) gas from the product into the air, over time, as the product naturally ages. For example, formaldehyde gas from building materials, adhesives and coatings (e.g., composite wood furniture, insulation, carpet glues, etc.) has been known to build up in the air to detectable concentrations from the materials as they age. In this case, excessive concentrations can be identified by measuring the formaldehyde gas levels in the air near these “off-gassing” materials.

Particulate matter. Particulate matter (also referred to as PM or particle pollution) is a complex mixture of solid and/or liquid particles suspended in air. These particles can vary in size, shape and composition. Most airborne PM of health concern is too small to be seen by the naked eye. Particles ten (10) micrometers in diameter and smaller are inhalable and therefore are a concern. Indoor PM is a mixture of PM that comes in from outdoors and PM that is generated inside.

Testing, adjusting and balancing (TAB). A term used to describe the commissioning or checking of a heating, ventilation and air-conditioning (HVAC) system to determine if it is installed and operating as designed. A TAB is usually performed by engineers or similarly educated and experienced professionals just after completion of a new or modified HVAC installation. A TAB typically consists of physically measuring the amount of air flowing through the system, including at outside air intakes and at all or a representative number of air diffusers. Measurements may also include fan speeds, pressure differentials, temperatures, air ‘throw’ direction and velocities. Adjustments to the system are made in response to the measurements in order to balance the system so it meets design requirements and expected performance parameters.

Vapors, fumes and gases. Terms used to describe airborne chemical substances (i.e., not dust). Fumes are solid particles suspended in air usually resulting from the condensation of heated materials. Metal welding produces fumes which are a mixture of fine particles and gases from the welding operation. Vapors are mostly gaseous. Boiling water produces water vapor in the air. Gases typically refer to substances that exist primarily as a gas at normal room temperature. Oxygen, nitrogen, carbon dioxide are gases. These terms are sometimes used interchangeably and incorrectly by those authoring IAQ evaluation reports.

Volatile organic compounds (VOCs). VOC is a term used to describe a class of chemicals whose boiling points and vapor pressures are sufficiently low and high enough, respectively, that they are volatile and gaseous at room temperature. VOCs are usually low molecular weight chemicals which are often used as carrier solvents or cleaners in household, business and consumer products. VOCs are often present as a complex mixture of individual chemicals in the air.


Page 4

Responsibilities

Office of Facilities Management (OFM). The OFM is responsible for oversight of the IAQ program within PBS. OFM will provide training on the IAQ Order and this Desk Guide to PBS employees and support regions when addressing IAQ concerns or resolving disputes. Regional Environmental, Safety & Health Program Staff. The regional environmental, health and safety program staff is responsible for ensuring the IAQ Order and operational guidance herein is executed throughout the region. The office supports Facility Managers, Project Managers, and Lease Administration Managers in the following manner:

• Provide technical interpretation of IAQ assessments, including testing data, and offer conclusions and/or recommendations

• Assist evaluating IAQ conditions including IAQ testing) through the use of existing technical consultant contracts

• Assist in communicating with tenant agencies about IAQ concerns, questions or related issues

• Periodically reviews documentation to ensure building HVAC system installation, maintenance and repairs follow existing PBS requirements regarding IAQ

• Assist as needed to ensure IAQ assessments (including testing) are performed as needed • Ensure records associated with HVAC system commissioning, repairs and/or IAQ

assessments/testing are maintained in the NCMMS for GSA owned and operated buildings. • Provide review and input on mitigation and corrective action efforts in buildings where

sources of poor IAQ are identified Facility Managers. Facility Managers are responsible for:

• Ensuring building systems are maintained in accordance with the existing national Operations & Maintenance (O&M) MasterSpec and site specific Building Operating Plan and preventive maintenance program

• Responding to IAQ complaints or concerns in a timely and thorough fashion. The Facility Manager or their representative is usually the first responder to complaints

• Recording all IAQ complaints in GSA owned and operated buildings and the corrective action in the NCMMS system

• Communicating to appropriate stakeholders, including building occupants and visitors, any relevant information about IAQ-related incidents or emergencies

• Taking all feasible and prudent actions to restore acceptable indoor air quality in the wake of any incident that renders a space or the entire building unsuitable for occupancy due to poor IAQ conditions

Lease Administration Managers. Lease Administration Managers are responsible for ensuring lessors comply with the lease contract requirements for IAQ. Lessors should also be encouraged to comply with the best practices outlined in the PBS document, Indoor Air Quality in GSA Leased Facilities.


Page 5

PBS, Office of Design and Construction. The regional office responsible for design and construction is responsible for ensuring all HVAC systems, constructed using the PBS, P-100 “Facilities Standards for the Public Buildings Service,” include system commissioning as specified.

Delegated Buildings. For Federal facilities under GSA’s jurisdiction, custody, or control delegated to other Federal agencies by the Administrator of General Services, those Federal agencies are responsible for:

• Ensuring that HVAC systems are maintained according to the contract Operations & Maintenance (O&M) specifications and applicable preventive maintenance requirements

• Responding to IAQ complaints or concerns in a timely and thorough fashion. The facility manager or their representative is usually the first responder for IAQ complaints

• Maintaining a record of all IAQ complaints • Communicating to appropriate stakeholders, including building occupants and visitors, any relevant

information about IAQ-related incidents or emergencies • Taking all reasonable and prudent actions to promptly restore acceptable indoor air quality

following an incident, complaint or emergency. Guidance Indoor Air Quality (IAQ) requirement. This document outlines existing parameters for elements of IAQ such as temperature, relative humidity, carbon dioxide, carbon monoxide, formaldehyde, airborne asbestos and airborne mold requirements which represent airborne contaminant concentrations and building conditions which have been established to differentiate IAQ problem areas from non-problem areas. As summarized below, each requirement listed in the operational guidance is based on a federal regulatory level and/or industry consensus standard. In some jurisdictions, GSA may be subject to additional state or local regulatory limits. Those listed here are the most common parameters associated with IAQ complaints.

The following values shall be used in interpreting test results or measurements taken in response to IAQ complaints or concerns. Levels above these values shall result in an evaluation of the affected area and/or HVAC systems servicing that area to determine the potential cause(s). As test results above these values can potentially lead to comfort or health issues for occupants and visitors, available corrective actions should be taken to return test results back to acceptable levels.

Space temperatures. Space temperatures shall comply with FMR-102-74.185 which states “Within the limitations of the building systems, Federal agencies must— (a) Operate heating and cooling systems in the most overall energy efficient and economical manner; (b) Maintain temperatures to maximize customer satisfaction by conforming to local commercial equivalent temperature levels and operating practices; (c) Set heating temperatures no higher than 55 degrees Fahrenheit during non-working hours; (d) Not provide air-conditioning during non-working hours, except as necessary to return space temperatures to a suitable level for the beginning of working hours; (e) Not permit reheating, humidification and simultaneous heating and cooling; and (f) Operate building systems as necessary during extreme weather conditions to protect the physical condition of the building.” and in accordance with temperature ranges prescribed in GSA’s national Operation and Maintenance of between 74°F and 78°F in the summer months and between 68°F and 72°F in the winter months. The ranges are


Page 6

prescribed for the building overall and not for individual offices and are applicable only during normal working hours.

Humidity. Relative humidity should be maintained in accordance with, ASHRAE Standard 55 for Thermal Comfort requirements within the limitations of existing facility equipment and extreme local climate conditions. It is important to note the provision of humidification is defined as an above standard service. Carbon dioxide. Maintain carbon dioxide levels in accordance with the National O&M MasterSpec and ASHRAE requirements. Specifically the air exchange rate and outside air intake volume must be sufficient to maintain carbon dioxide (CO2) levels below 700 parts per million (ppm) over outdoor ambient levels. This value is from ASHRAE Standard 62.1-2016 (the standard’s Informative Appendix D), which, based on a set of assumptions calculates that this CO2 level will provide approximately fifteen (15) cubic feet per minute (cfm) of outdoor ventilation air per occupant. Some spaces may require higher ventilation rates, as described in ASHRAE Standard 62.1-2016. Carbon monoxide. Maintain carbon monoxide (CO) levels in accordance with the National O&M MasterSpec. Specifically carbon monoxide levels should not exceed nine (9) parts per million (ppm) as measured instantaneously. This value is based on longstanding consensus guidance originally proposed by EPA, the National Institute for Occupational Safety and Health (NIOSH), and the American Council for Governmental Industrial Hygienists (ACGIH). Formaldehyde. Formaldehyde levels should not exceed 0.016 ppm (16 ppb) in air. This value is based on currently accepted guidance from NIOSH. Airborne asbestos. Maintain airborne asbestos levels below seventy (70) structures/mm2for transmission electron microscopic (TEM) analyses and 0.01 f/cc for phase contrast microscopic (PCM) analysis. The value of 70 structures/mm2 is the longstanding industry consensus ‘clearance’ standard originally adopted by EPA for post-abatement re-occupancy.1 The value of 0.01 f/cc is also longstanding industry consensus standard for cleanliness when PCM is used. TEM specifically identifies asbestos and has no resolution limit, so is the preferred standard. Airborne mold. Maintain levels comparable in quantity and type to that found in outdoor air or in non-problematic building control areas. There is no consensus standard or regulatory limit for airborne mold. Prevailing guidance recommends addressing the source of moisture intrusion promptly including cleaning/removing water damaged materials regardless of whether airborne mold levels have been measured. Mold sampling is not recommended as a general rule. However if a determination is made to measure airborne mold, the current accepted industry practice is to compare the values and type to either outdoor ambient levels or areas in the facility not affected by mold or moisture (i.e., control areas). Since mold is ubiquitous throughout the U.S., it is essential to compare levels by identifying not just the quantity of mold present in both locations, but also identifying the type of mold in such locations.

1 This is a filter area concentration (not an air concentration) and assumes a requisite air volume is drawn through filter media.


Page 7

When using these requirements to help characterize IAQ conditions, it is important to understand how and when they are to be applied. More specifically, they are intended to apply primarily to office spaces and adult office workers, as follows: • The requirements are intended to establish prudent airborne concentrations above which IAQ may

potentially degrade and possible adverse health effects might be expected among the exposed persons;

• The requirements generally assume exposure at/near the exposed individual’s breathing zone while normally positioned at his/her workstation (desk, etc.) or in commonly occupied areas (lobby, stairwells, etc.). As such, the threshold values are not intended to apply to locations such as crawlspaces, air plenums, mechanical equipment rooms, etc.;

• Unless otherwise stated, threshold values are intended to be used as short term, not to exceed values as opposed to, for example, a repeated, time-weighted average daily exposure over a full 8 to 10 hour work shift.2

• These requirements are not intended to be a rigid dividing line between safe and unsafe but rather constitute target values that are useful in identifying, diagnosing and correcting potential IAQ related problems; and

• The requirements are intended to apply to the majority of healthy, working adults. Hypersensitive, allergic or immune-compromised individuals may react to IAQ conditions even when the requirements are met.

When drawing conclusions from testing data used to determine IAQ, it is important to understand many variables exist that may complicate interpretation. These variables, summarized as follows, should be considered and controlled to the extent possible when developing specific testing strategies. • There is potential for significant variance in air concentrations from day-to-day and hour-to-hour. • There is potential for significant variance in air concentrations based on testing locations. • The need to collect samples or IAQ tests as expediently as possible can result in less statistically

reliable results. When striving for statistically significant results, generally six samples or tests are considered the minimum.

• There is a potential for additive or synergistic effects when exposed to more than one potential IAQ agent.

• Testing methods may not always account for exposure routes other than inhalation, such as contact or ingestion.

Testing methods for each of the requirement is provided in Appendix A, Guidance: IAQ Requirements. Specifically, Appendix A, Attachment 1, Selected Testing Methods, provides a listing of selected sampling and laboratory techniques which may be considered for use, depending on the specific objectives of the IAQ characterization being performed and other factors such as urgency, budget, required detection limits, precision/accuracy, etc. The listing is not all-inclusive and other suitable testing methods/instruments may exist. In all cases, in order to ensure reliable data are obtained which inform defensible conclusions, any methodology utilized must be scientifically validated and the testing in the

2 This applicability is largely based on the practical constraints associated with how GSA responds to IAQ complaints and the need for associated testing to yield rapid results.


Page 8

field properly carried out in accordance with the specified techniques. Attachment 2 of Appendix A provides a list of resources which may be helpful to developing testing strategies, performing the sampling, laboratory analyses, and data interpretation.3

Reduce Common IAQ Problems/Complaints. The operational guidance recognizes existing practices that can be implemented to identify and mitigate common causes of IAQ problems. These practices include:

• Green purchasing and green product requirements • Adoption of ASHRAE standards for new construction and renovations, particularly as regards

ensuring effective ventilation and thermal comfort • Performance of initial and continuous commissioning for new construction and renovations • Utilize P-100,“Facilities Standards for the Public Buildings Service" for design, renovation and new

construction • The incorporation of specific IAQ-related requirements in leases/contracts • Performance of periodic building audits, inspections or surveys to identify potential sources of IAQ

problems

Respond to Incidents, Complaints and Emergencies.

The operating guidance requires that complaints about IAQ be promptly evaluated by the facility manager and that corrective actions to restore degraded IAQ be performed after accidents and emergencies (e.g., fires, water leaks) followed by confirming tests, where applicable.

Evaluating IAQ complaints may entail many of the assessment and testing strategies employed during standard IAQ checks with additional emphasis on gathering all appropriate information to understand the nature of the complaint (symptoms, spacial and temporal considerations, etc.), and then using this information to tailor diagnostic strategies and, ultimately, corrective actions. Special testing may involve characterizing exposures to specific suspect airborne contaminants (e.g., ‘4-PC’ from carpets) or screening for a wider range of parameters to resolve, for example, complaints of unidentified odors. Other exposure routes besides inhalation may also need to be considered such as contact exposures to settled dusts (e.g., dusts containing skin-irritating mineral wool fibers, etc.). While such exposure characterizations (including testing for contaminants) may be helpful during the diagnostic process and provide insight into whether the adopted IAQ requirements are being met, over-reliance on such testing should be avoided. Rather, investigations of IAQ complaints should focus on identifying deficient or atypical building conditions. Such conditions may include a lack of ventilation, un-commissioned building materials and systems, inadequate introduction or distribution of outdoor air, improperly regulated temperatures or air flows, inadequate local exhaust of certain operations (e.g., printing, food service, laboratory) etc. The cost and effort associated with investigating and resolving the aforementioned conditions are usually borne by the property owner and/or manager since they are responsible for basic building operations. However, if the adverse IAQ condition is caused by something beyond the control of the 3 IMPORTANT NOTE: These are the recommended testing methods. Other methods may be used provided they are equivalent and standardized.


Page 9

property owner and/or manager, those associated costs may be appropriately transferred to the occupant agency, contractor or other entity responsible for the condition. Similarly, an agency or entity requesting a specific IAQ test or investigation for a parameter highly unlikely to be present (e.g., radon on an upper floor), may have to bear the associated cost. Determination of these responsibilities and costs can be therefore be complicated and are usually resolved on a case by case basis. Summarized in Appendix C, Incidents, Complaints and Emergencies are information on the following subjects:

• Clean-up following clean water damage. Damage from greywater or black water may require disinfection and personal protective equipment during clean-up to address contamination from bacteria, viruses or other infectious agents.

• Sample IAQ interview form • Comparison of IAQ conditions and health symptoms • Sample scope of work for an IAQ complaint assessment • Interpretation of Mold Spore Data

Appendix D provides PBS’s Indoor Air Quality in GSA Leased Facilities Best Practices which details:

• Background about IAQ in GSA facilities • Responsibilities • Process flowchart for addressing/resolving IAQ problems • Frequently Asked Questions

IAQ related leasing forms and form templates dealing with HVACs, system commissioning, heating and air conditioning, radon and mold.


Page 10

Appendix A: IAQ Requirements Attachment 1, Selected Testing Methods4

Parameter Method

Type Testing Method Notes

Temperature DR Portable IAQ meter Relative Humidity

DR Portable IAQ meter

Carbon Dioxide DR Portable IAQ meter Carbon Monoxide

DR Portable IAQ meter

Formaldehyde DR Formaldehyde Meter

Measurement range is from 20 ppb to 1 ppm, without significant cross-sensitivity from typical background compounds. Display reports down to 10ppb (with actual limits of detection below the display value, down to <5ppb). http://www.wolfsense.com/formaldehyde-monitor.html

Formaldehyde TWA NIOSH Method 2016 (treated silica gel sorbent tube collection and HPLC/UV analysis).

Method can achieve a detection limit of <0.003 ppm based on an air collection volume of 300 liters.

Total Airborne Particulate Matter

DR Portable particle or dust counter with 90o optical light scattering photometer set to report total mass concentrations for particles in the 0.1-10 u aerodynamic range (i.e., “PM10”).

Instruments should be factory calibrated with Arizona road dust (ISO 12103-1; A2 fine test dust) using a flow rate of 1.67 liters of air per minute. The instrument should be set to display particulate mass concentrations over a 5 minute integration period and zeroed immediately prior to testing. The instrument has a range of 0 to 20,000 ug/m3, a display resolution as low as 1 ug/m3 and accuracy /repeatability of +/- 15% at the calibration value.

Total Airborne Particulate Matter

TWA NIOSH Method 600, “PARTICULATES NOT OTHERWISE REGULATED, RESPIRABLE” using a cyclone and filter to capture particles up to 10u diameter. Gravimetric analyses.

Working range: 0.5 to 10 mg/m³ for a 200-L air sample.

Airborne Lead TWA NIOSH Method 7105 using calibrated battery operated pumps and 0.8 u mixed cellulose ester filters held in three stage cassettes.

To achieve a suitable detection limit, a target volume of approximately 960 liters should be collected and samples analyzed using graphite furnace atomic absorption spectrophotometry.

4 The listing is not all-inclusive and other suitable methods may exist. Reference to a particular testing methodology or instrument does not constitute an endorsement or indication of suitability to a particular need.


Page 11

Airborne Asbestos

TWA NIOSH Method 7402 using transmission electron microscope; energy dispersive X-ray system (EDX) analyzer.

Samples collected using a high flow vacuum pump (0.5 to 16 L/min) drawing air through a cassette with a 0.45μm cellulose ester membrane filter. Recommended air volume ranges are 1200 to 1800 liters for 25mm cassettes and 1800 to 2800 liters for 37 mm cassettes. (ref: http://nist.gov/nvlap/upload/EPA-560-5-89-001_AHERA-TEM-Clearance-Test.pdf)

Airborne Mold (Spores)

TWA Zefon Air-o-Cell spore trap methodology using Air-o-Cell cassettes and Zefon Bio-Pump Plus.

Mold sampling is not generally recommended, since there is no consensus and results can be misleading if not performed or interpreted correctly. It is preferable to: visually investigate and cleanup any damaged materials promptly when a water leak or moisture intrusion is apparent.

Airborne Mold (Viable)

TWA Incubation plates (Petri dish) with 2% Malt Extract Agar; N-6 Anderson impactor; SKC Quick Take 30.

DR= “Direct Read” instrument; TWA=”Time Weighted Average”


Page 12

Appendix A Attachment 2: IAQ Resources

Indoor Air Quality guide: Best Practices for Design, Construction, and Commissioning; ASHRAE (ISBN: 978-1-933742-59-5, 2009, 176 pages, David Mudarri-Technical Editor)

Indoor Air Quality Solutions for Stationary Engineers, by American Technical Publishers (ISBN: 978-0-8269-0718-9, International Union of Operating Engineers (IUOE), 2009, 390 pages)

OSHA, Safety and Health Topics: Indoor Air Quality; https://www.osha.gov/SLTC/indoorairquality/index.html.

ASHRAE Standard 62.1-2013, Ventilation for Acceptable Indoor Air Quality.

ASHRAE Standard 55-2013, Thermal Environmental Conditions for Human Occupancy.

ASHRAE Standard 180-2012, Standard Practice for Inspection and Maintenance of Commercial Building HVAC Systems.

Sheet Metal and Air Conditioning Contractors’ National Association, Inc. (SMACNA), “IAQ Guidelines for Occupied Buildings Under Construction” (Second Edition, 2007).

PBS P-100, Facilities Standards for the Public Buildings Service.

Federal Management Regulations (FMR), 41 CFR Part 102.

GSA Child Care Design Guide, PBS-140.

U.S. EPA, Building Air Quality: A Guide for Building Owners and Facility Managers; https://www.epa.gov/indoor-air-quality-iaq/building-air-quality-guide-guide-building-owners-and-facility-managers.

AIHA. Recognition, Evaluation and Control of Indoor Mold; Presant, B; Weekes, D; Miller, D.H.; American Industrial Hygiene Association: Fairfax, VA, 2011.

New York City Department of Health and Mental Hygiene; Bureau of Environmental and Occupational Disease Epidemiology. Guidelines on Assessment and Remediation of Fungi in Indoor Environments; NYCDOH: 2008.

The U.S. Green Building Council, LEED for New Construction and Major Renovations.

What Is the Proper Way to Interpret Mold Reports; Dr. Harriet Burge, EMLab P&K's Director of Aerobiology; https://www.emlab.com/s/sampling/2010-01-Numerical-Interpretation.html.

https://www.emlab.com/s/sampling/2010-01-Numerical-Interpretation.html


Page 13

Appendix B: Proactive IAQ Assessment Attachment 1: IAQ Management Plans

A Building IAQ Management Plan is a tool that can that pro-actively addresses actual/perceived IAQ problems and fosters continuity of operations. Facility managers should consider developing such a plan. Elements of an IAQ Management Plan may typically include:

• Communications mechanisms (e.g., between building occupants, safety staff, building engineers, contractors, etc.);

• Standard operating procedures for various building activities that promote good IAQ (e.g. housekeeping, building maintenance, construction/renovation, HVAC system inspection and maintenance, etc.);

• Education and awareness of occupants (safety committee, training programs, relations); • Responsibilities (e.g., IAQ Manager, oversight, enforcement); • Problem Avoidance (e.g., isolation of work areas, product selection, advance planning and

scheduling, etc.); • Records and Documentation (e.g., logging IAQ complaints, responses, outcomes).


Page 14

Appendix B Attachment 2: Key IAQ Check Assessment Elements for

Common Problems with IAQ • Interview a sampling of representative building occupants and building management personnel to

gain their perspective on any IAQ concerns. • Review pertinent documents (e.g., IAQ-related reports, automated building management work

order system entries, lease agreements, memos, ventilation specifications, safety data sheets, etc.) that may identify IAQ issues and concerns and help with the assessment process.

• Conduct a walk-through of the areas in question (especially ‘focus areas’ such as may have been

identified by the interviews and document reviews). Inspect for evidence of suspect conditions such as evidence of water intrusion, stained ceiling tiles, dust accumulations, inadequate housekeeping, potential pollutant pathways/sources from any special building activities/operations (e.g., laboratories, medical offices, operations involving use of bulk quantities of chemicals, etc.), blocked or ‘short circuited’ supply or return air registers, reconfigured spaces with inadequate ventilation etc. Also, observation of significant use of in-office air cleaners, dehumidifiers, fans, etc., may suggest suspect IAQ conditions.

• Use a direct reading instrument to screen for key IAQ indicators (temperature, relative humidity,

carbon monoxide, carbon dioxide). Collect measurements preferably throughout a one day period in various building locations, and outside, and compare data to recognized IAQ guidelines. Of particular importance is identifying whether carbon dioxide is elevated (i.e., an “indoor-outdoor CO2 concentration differential greater than 700 ppm” which might suggest that ‘stale air’ is building up and that, in general, the HVAC system may not be providing adequate amounts of outdoor air for control of normal office respiration gasses and air contaminants). Measure the amount of outdoor air being provided for ventilation, preferably at the air handler’s outdoor air intake, and adjust as needed to provide the required amount of outdoor ventilation air.

• Perform a qualitative check of supply and return ducts to include visual inspections above drop

ceilings. Is air movement evident? Are ducts connected? • Qualitatively assess pressure differentials at the suite-hallway boundary and other locations using

ventilation smoke tubes. Generally, offices and suites should be at a positive pressure with respect to adjacent hallways, etc., so that contaminant incursion is minimized.

• Examine HVAC units for readily apparent deficiencies and discuss operations and maintenance with

building engineers. Inspect air intakes for sources of potential contamination which could significantly impact the quality of the incoming air (e.g., stagnant water, decaying vegetation, bird droppings, bulk chemicals, etc.). Check to see that preventive maintenance is occurring on schedule, to include checks to see if coils are relatively clean, condensate pans are not blocked and have biocide added, quality air filters are in place and well seated (filters with a MERV 8 rating or above are preferable but FM/LAM should verify O&M contract or lease contract requirement). Check plenums and duct interiors (where possible) for evidence of moist or delaminating insulation


Page 15

liners which may generate contaminants (e.g., mineral fibers, mold spores). Are VAV boxes working as intended with required filters in place and minimum set points maintained?

• Perform any additional screening evaluations or testing necessary to resolve suspicions of

inadequate conditions. Such additional screening may include testing for TVOCs using a direct reading photo-ionization detector, testing for airborne particulate matter (PM) using a direct reading dust monitor, assessing airflow (e.g., using a balometer) at the air-supply diffusers in the suite to compare with available building specifications and TAB reports, etc. Depending on the results of the screening assessment, more in-depth “phase 2” IAQ characterizations may be recommended.


Page 16

Appendix B Attachment 3: Maintaining IAQ during Construction/Renovation

Valuable techniques for proactively maintaining acceptable IAQ in occupied buildings during construction/renovations are discussed in the Sheet Metal and Air Conditioning Contractors’ National Association, Inc. (SMACNA) publication entitled, “IAQ Guidelines for Occupied Buildings Under Construction” (Second Edition, 2007). The SMACNA guidelines address subjects like protecting old and new HVAC systems/ducting, establishing suitable containments to limit fugitive emissions, surveillance of work practices and conditions, moisture and mold control, commissioning and re occupancy criteria, etc. For example, under HVAC Protection, Return Side: "When the system must remain operational during construction, temporary filters can be added on return air grilles. Suggested minimum efficiency for such filters is 30% atmospheric dust spot or a MERV Rating of 6 or higher where feasible." Under Depressurization of work area: "as a general rule, the work site should be exhausted at a rate of at least 10% greater than the rate of supply in order to maintain an effective negative pressure". Enacting these exhaust and/or filtration changes during construction may require modification to the existing facility Operations and Maintenance (O&M) contract, or at least coordination with the O&M staff.

Similarly, the LEED® Green Building Certification Program’s Indoor Environmental Quality Rating System, recognizes SMACNA and has incorporated two notable criteria in its credit system5, as follows:

Credit 3.1: Construction Indoor Air Quality Management Plan—During Construction

• Develop and implement an IAQ management plan for the construction and preoccupancy phases of the building.

• During construction, meet or exceed the recommended control measures of the Sheet SMACNA IAQ Guidelines for Occupied Buildings Under Construction.

• Protect stored on-site and installed absorptive materials from moisture damage. • If permanently installed air handlers are used during construction, filtration media with a

minimum efficiency reporting value (MERV) of 8 must be used at each return air grille, as determined by ASHRAE Standard 52.2-1999.

• Replace all filtration media immediately prior to occupancy.

Credit 3.2: Construction Indoor Air Quality Management Plan—Before Occupancy

• Develop an IAQ management plan and implement it after all finishes have been installed and the building has been completely cleaned before occupancy.

• Flush-out areas or perform air testing to demonstrate that the specified contaminant maximum concentration levels are not exceeded.

5 Reference: “LEED 2009 for New Construction and Major Renovations,” The U.S. Green Building Council.


Page 17

Appendix C, Respond to Incidents, Complaints and Emergencies Attachment 1, EPA Guidelines for Response to Clean Water Damage*

Table 1: Water Damage – Cleanup and Mold Prevention

*EPA Mold Remediation in Schools and Commercial Buildings, EPA-402-K-001, September 2008.


Page 18


Page 19


Page 20


Page 21

Table 2 (continued):


Page 22

Appendix C Attachment 2: Sample IAQ Interview Form

Indoor Air Quality Interview Form An interview form is a tool to assist those evaluating IAQ complaints. The details of a complaint, including location, timing and perceptions or symptoms, will often narrow the search for potential IAQ sources. Professionals conducting interviews should only collect information critical to the evaluation and avoid questions or collection of personal identifiable information. Interviewer must coordinate with Facility Manager to obtain the approval of the occupant’s supervisor prior to conducting an interview.

Date of Interview: ___________________ Interviewer Name/Title: _____________________________

Building Number/Name: ________________________ Address: _______________________________

Interviewee Name/Agency: _________________________ Phone/Email: _________ (optional)

Room Number/Location: ____________________________

Nature of the IAQ Complaint

What are your concerns? ______________________________________________________________

Are you experiencing any of the following?

Eye irritation Skin rash Headache Odors

Do you know if there are others in your office or the building who are experiencing the same concerns?

Yes No If yes, roughly how many and where? ________________________________ Do you have any particular condition or sensitivities (e.g. allergies, etc.) you would like to share?

Yes No If yes, please describe ____________________________________________ Spatial and Timing Patterns Where do the problems occur in the building? ______________________________________________

Are the problems worse at certain times, days, or seasons? ___________________________________

Do the problems dissipate at some point? __________________________________________________

Do you have any observations about the building conditions that might need attention or might help

explain the IAQ problems?


Page 23

___________________________________________________________________________________

Appendix C

Attachment 3: Comparison of IAQ Conditions and Issues Reported

Thousands of IAQ evaluations conducted over several decades has demonstrated a link between some health issues or symptoms and their corresponding IAQ sources. While issues may not always be caused by changes in the indoor air quality, some of the more common associations are listed below.

Issues Reported Potential IAQ Condition Burning or irritated eyes, skin irritation (itching or burning)

Excessive dust from inadequate cleaning (especially dusts containing mineral fibers). Very low humidity conditions.

Burning or irritated eyes, skin irritation, metallic smell in air

Metallic dust in air from burned bearing in HVAC fan motor.

Red, itching dots or blotches on skin Insects or skin contact allergy from contaminants such as mineral wool/fiber glass.

Headaches, dizziness, musty odor Water damaged materials and mold. Headaches, dizziness, no odor Elevated CO2 or CO. Odors and related symptoms/discomfort Chemical fumes, vapors or gasses causing

odor and symptoms. Musty odors may be the result of water damage and resulting microbial VOCs. Dry drain traps commonly result in sewage-type odors.

Headaches, dizziness, sleepiness, irritability Elevated CO2 due to insufficient introduction of outside or fresh air.

Allergy symptoms Dust, mold, irritants such as formaldehyde


Page 24

Appendix C Attachment 4: Sample Scope of Work for an IAQ Complaint Assessment

Purpose

[AGENCY] requests that [VENDOR] provide a Certified Industrial Hygienist (or an experienced industrial hygienist well versed in indoor air quality investigations) to perform an Indoor Environmental Assessment in Suite XX at [AGENCY], located XX XXXX to investigate employee complaints reported by [AGENCY] staff.

Background

Suite XX on the Xrd Floor of [AGENCY] was recently renovated and employees re-occupied the space in October of 20XX. The renovated area includes new carpet, paint and furniture. Additional furniture (storage hutches) was added to the area in November. Since returning to the area, a number of employees (at least five) have complained of the odors that they associate with the new furniture and carpet, or “dust.” Reportedly, two employees have visited the onsite FOH nurse due to their complaint. Reported complaints so far include, but may not be limited to, itchy and watery eyes, itchy skin, and changes in breathing (cough and wheezing).

Scope

[AGENCY] requests that [VENDOR] provide a Certified Industrial Hygienist (or an experienced industrial hygienist well versed in indoor air quality investigations) to perform an Indoor Environmental Assessment in Suite XX at [AGENCY], located XX to investigate employee complaints reported by [AGENCY] staff. The assessment shall include, at a minimum, an onsite inspection of the affected area, evaluation of the heating, ventilation and air-conditioning (HVAC) system, interviews with management and employees, and any necessary sampling based on industry standards. Specifically, if determined to be warranted, the assessment should determine (but not limited to): sources of possible indoor air quality concerns, potential contaminants present in the area, quantification of potential contaminants that are relevant to employees’ complaints, potential for other occupant health hazards, recommendations on corrective actions, and other recommendations for prevention of similar situations in future renovations. Ensure all related costs for onsite activities, travel, sampling supplies, expedited laboratory analysis, etc. are included in the cost estimate proposal. Requirement

a) Perform an Indoor Environmental Assessment in accordance with standard industry guidelines focusing on identified employee concerns including effects of recent renovation, new carpet, new furniture and any other potential source identified during the assessment. Utilize standard procedures and methodologies including but not limited to: Environmental Protection Agency (EPA) guidelines or similar industry guidelines.

b) Advise [AGENCY] of any immediate concerns or health/safety hazards. c) Utilizing documented qualitative or quantitative techniques including but not limited to air,

wipe, and bulk sampling and analysis, identify and verify the levels of appropriate indoor air


Page 25

quality contaminants of concern, and if present, the potential contributing factors. Acquire a representative amount of samples.

d) Utilizing documented qualitative or quantitative techniques including indoor air quality direct reading instruments, determine all appropriate indoor air quality parameters for the area (list the specific testing parameters required here such as temperature, relative humidity, carbon dioxide, outdoor air ventilation rate, etc.).

e) Utilizing documented qualitative and quantitative techniques, identify and assess any other indoor air quality concerns perceived or otherwise, identified at the time of the site visit.

f) Perform outdoor baseline ambient sampling representative to the indoor sampling, if appropriate. Acquire baseline ambient temperature, relative humidity, and carbon dioxide levels for comparison with indoor levels.

g) Analyze samples by certified laboratories including but not limited to AIHA, EMLAP, etc. with current proficiency tests in place. Include blank samples as determined to be appropriate. Expedite turnaround time for all laboratory analysis.

h) Provide [AGENCY] with a preliminary assessment report at the conclusion of the onsite assessment, to include but not be limited to, observations, initial findings, intermediate recommendations or corrective actions, etc. This may be verbal or in email format.

i) Provide [AGENCY] a copy of laboratory reports when received. j) Provide [AGENCY] with a written Draft Report for [AGENCY] review and comment within 5

business days from receipt of laboratory results and/or 5 days after onsite assessment if no laboratory analysis is needed.

k) The written Draft Report shall include: i. A description of the employed assessment methods and protocols to include general

survey methodology, sampling strategy, protocol for selecting sample locations, sample collection protocol, and industry standards applicable to sample collection and analysis.

ii. Field data sheets including appropriate ambient conditions, calibration information, etc. iii. Identified health concerns. iv. Findings and Observations. v. Results, to include laboratory analysis results, if applicable.

vi. Identify the assessment criteria used, with reference made to applicable standards, and discuss relevance of results and observations to said criteria and standards.

vii. Identify potential sources of indoor air quality contaminants. viii. Corrective action recommendations.

ix. Recommendations (preventive) for future office renovation projects, to include but not limited to, recommendations related to general ventilation, area exhaust ventilation, project timing, employee occupancy, etc., as appropriate. These recommendations should be presented in a separate attachment to the report. Include cost estimate for such recommendations.

x. Representative photographs. xi. Other information as deemed necessary during the assessment


Page 26

Appendix C Attachment 5: Interpretation of Mold Spore Data

In general, spores are ubiquitous in the indoor and outdoor environments and their presence does not necessarily signify an indoor air quality problem or that adverse health effects may result. However, many indoor air quality professionals currently use spore trap testing as a quick and cost-effective way to characterize suspected mold-related IAQ problems.

Typical testing involves the use of Zefon Air-o-Cell spore trap methodology using Air-o-Cell cassettes and Zefon Bio-Pump Plus. Both quantitative (concentrations) and qualitative (fungal taxa) information are important in the interpretation of the results although it should be noted that the etiology and characterization of mold as an IAQ parameter is a rapidly evolving science and that no widely accepted quantitative exposure standards or limits currently exist. Currently, there are no U.S. governmental regulations which define specific “acceptable” or “unacceptable” indoor airborne fungal or spore levels.

When evaluating spore trap testing results, rather than comparing to a specific numerical ‘standard’ or ‘action level’, laboratory data is typically evaluated by comparing the types (genus) of mold spores identified, quantities found in the sample (i.e., airborne concentrations), and relative proportions of spores from one area to another and in comparison to outdoor samples or ‘control areas’ where no suspect IAQ conditions or complaints are apparent. Significant differences from one sampling location to another might signify a localized mold ‘reservoir’ and possible ongoing amplification such as from water damaged materials. Also, comparing spore data from indoor tests to samples collected outdoors is generally believed to provide some insight into the general nature of the geographic region’s bioaerosol assemblage and the effectiveness of building HVAC filters to remove excessive contaminants (e.g., spores) from air entering occupied spaces.

More specifically, indoor airborne fungal levels in a mechanically ventilated building, where no fungal proliferation is occurring would be expected to be lower than those levels outdoors. Such data would suggest that a mold-related IAQ problem is not apparent. Moreover, fungal species found indoors should be generally representative of those found outdoors. Fungi such as: Cladosporium spp., Alternaria spp., Epicoccum spp., and basidiomycetes spp., are examples of fungi frequently detected in outdoor air samples on a seasonal basis. In a mechanically ventilated building with air filtration, the apparent concentrations of these genera should not be greater than those found outdoors (e.g., at air intakes). Similarly, elevated concentrations of fungi such as Stachybotrys spp. and Aspergillus spp. are often considered indicative of indoor mold amplification due to water damage. Although comparison of indoor to outdoor mold is often done, it may be more defensible to draw conclusions from comparing mold test data from ‘suspect’ indoor locations to ‘control’ indoor locations. Even testing inside wall cavities can provide insight into where mold problems may be originating.

While significant debate is on-going dealing with the relative harmful effects of different types of mold exposure, some have reported that common fungi which are particularly toxigenic include:

• Aspergillus flavus • Aspergillus fumigatus • Aspergillus versicolor • Fusarium spp • Stachybotrys spp


Page 27

Laboratory reports should be reviewed especially for the presence of these fungi types.

When interpreting mold spore data, it should be noted that oftentimes a direct link between the presence of airborne spores and adverse health effects cannot be definitively established or ruled out by testing. At present, based on published, evidence-based statements and U.S. government publications, it is generally (but not universally) accepted that:

• Exposure to mold may adversely affect human health through three processes: 1) allergy, 2) infections, and 3) toxicity. While the causative agents of adverse health effects have not been conclusively identified, an excess of any of the agents resulting from mold growth (spores, cell fragments, allergens, mycotoxins, B-glucans, VOCs) is considered a potential health hazard.

• Symptoms from exposure may occur in some people consistent with a cold, flu, asthma, and, rarely, the more serious hypersensitivity pneumonitis (HP) and other illnesses. Others have no adverse health effects at all;

• Immune-compromised individuals may be particularly susceptible to respiratory illness from elevated mold spore concentrations;

• Approximately 10% of the population have allergic antibodies to fungal antigens while only about half of these, 5%, would be expected to show clinical illness;

• Individuals who are known to be allergic to molds and those with asthma may have a higher risk of allergic reactions and should take extra precautions to avoid exposures;

• In general, there is little evidence of long term or permanent health effects from exposure to mold once the occupant is removed from the exposure source; and,

• Other factors relating to high moisture or water incursion conditions in buildings (not related to mold per se) may also be of concern from a health and safety perspective (bacteriological, sanitation, electrical safety, etc.).

Overall, professional judgment is crucial to assessing mold in light of the many genera and species which may be identified, variance in outdoor levels, geographical and seasonal considerations, data obtained from ‘control’ or ‘non-problem areas’, etc. In this light, perhaps a better predictor of related health effects and IAQ problems is the presence of dampness and water damaged materials and therefore emphasis should be placed on identifying and resolving moisture problems in buildings.


Page 28

Appendix D: Indoor Air Quality in GSA Leased Facilities (Best Practices)

Introduction. Indoor air quality (IAQ) concerns in GSA leased facilities require clear communication and a coordinated response because of the varying responsibilities of the parties involved. The occupant agency is responsible for providing a safe and healthful workplace for their employees and the impact of their operations on IAQ. The lessor, as property owner, is responsible for the overall operations of the facility. GSA, as lease contract administrator, is responsible for supporting the mission of the occupant agency and enforcement of the lease requirements.

The purpose of this document is to provide an outline of GSA responsibilities and approach when dealing with IAQ issues in leased facilities. This is accomplished through a consistent method of communication and coordination among GSA associates responding to IAQ concerns or requests in leases.

Background. IAQ refers to broad range of workplace conditions that can adversely affect the actual or perceived health and productivity of workplace occupants or visitors. Conditions affecting the IAQ in GSA leased workplaces typically involve:

● air temperature and relative humidity ● carbon dioxide and air exchange ● dust ● odors ● mold ● hazardous materials

○ asbestos ○ lead-based paint ○ radon gas ○ volatile organic compounds

Some conditions, such as hazardous materials, are strictly regulated with regard to permissible IAQ levels. Other conditions (odors, temperature, and relative humidity) rely on consensus standards for determining acceptable ranges. The ranges typically represent values within which most individuals will not experience discomfort or ill health. Some individuals may be sensitive to certain conditions and experience ill effects in workplaces that lie within a consensus range.

Responsibilities. The following describes the role each party involved in GSA leased facilities plays when responding to an IAQ concern.

GSA. As the lease management agency, GSA is responsible for enforcing the terms of the lease contract and serving as representative to the occupant agency in matters affecting the lease. This role is reflected in the Occupational Safety & Health Administration (OSHA) regulations, 29 CFR 1960.1, which states:

The role of the General Services Administration in this area stems from its duties as the Government's principal landlord and from its specific safety and health responsibilities under 41 CFR Part 101, Subchapter D, Federal Management Regulation (FMR).


Page 29

The responsibility for correcting hazards in leases ultimately rests with the owner or lessor, depending on the terms of the lease.

GSA is therefore responsible for investigating any IAQ concern that falls outside the responsibilities of both the lessor and occupant agency but within the regulatory requirements or common consensus standards applicable to the given occupancy. For example, sandblasting of a nearby structure could result in airborne dust containing lead paint being drawn into the leased facility. The work is clearly beyond the lessor’s responsibility to control, but there are regulatory limits for airborne lead. Conditions found through GSA investigation may require negotiation with the lessor and/or occupant agency to fund and execute any necessary mitigation actions.

Lease Contracting Officer. The contracting officer through their appointment in accordance with applicable regulations has the authority and responsibility to bind GSA to the leasing contract. They are primarily responsible for enforcing the terms of the lease contract, including all provisions or requirements involving indoor air quality.

Lease Administration Manager (LAM). The LAM responsible for the lease shall serve as contact for communication among all parties involved in any IAQ concern. They are responsible for elevating to the GSA regional office responsible for IAQ program management any IAQ concern that requires GSA investigation or technical interpretation. They have delegated authority from the Contracting Officer to enforce the terms of the lease contract whenever those terms have led to conditions causing an IAQ concern.

Regional Environmental, Safety & Health Program Staff. The regional Environmental, Safety and Health program staff responsible for managing the IAQ program shall provide investigative support to the LAM, and occupant agency for IAQ concerns that fall outside the lessor and occupant agency responsibilities. When needed, the office is responsible for providing their IAQ expertise in support of communication, interpretation, and recommendations on any IAQ concern.

Occupant agency: Federal Management Regulations (41 CFR 102-80.10) require occupant agencies to provide for a safe and healthful work environment for Federal employees and the visiting public. When an IAQ concern originates from the occupant agency, they are responsible for notifying the GSA Lease Administration Manager (LAM). An agency employee originating an IAQ concern must also notify their direct supervisor, in accordance with requirements in 29 CFR 1910, Occupational Safety & Health Administration (OSHA) work-place regulations. Upon notification, the supervisor is responsible for investigating the extent to which the IAQ concern may be due to agency operations. If confirmed to be a result of agency operations, the occupant agency is responsible for mitigating the IAQ concern through control of their internal operations. When an IAQ concern or related request is beyond the responsibility of both the lessor and GSA (see FAQ 1 below), the agency is at minimum responsible for funding any additional investigation or testing they deem necessary to address the concern or request. Lessor. The lessor may be responsible for all facility operations that could adversely impact IAQ for the occupant agency including, but not necessarily limited to: heating ventilation and air-conditioning (HVAC), demolition and construction work, custodial and maintenance operations, and radon levels. The degree of lessor responsibility is determined by the type of lease and specific requirements in the contract.


Page 30

The lessor is responsible for adhering to the lease contract requirements, with particular attention to the IAQ provisions addressing air conditioning standards, radon, mold and asbestos management.

The lessor is responsible for initial investigation of any occupant agency IAQ concern, to determine whether the concern may be due to conditions within lessor responsibilities. The lessor is responsible for correcting any IAQ concerns due to building conditions which they control or deviations from the contract requirements. The lessor is responsible for notifying GSA of all IAQ concerns, their resulting response, and the outcome of that response, as soon as feasible. Routine complaints such as HVAC adjustments, temperature and relative humidity do not require notification.

Communication. Effective and timely communication is essential from the receipt of the IAQ complaint through the investigation and determination of finding/result. The nature and complexity of the issue will determine the nature and level of GSA involvement. It is desirable to include the GSA EHS expert on complex issues to provide technical expertise and support the LAM in discussions with the lessor and/or occupant agency representative.

Reports generated from technical IAQ evaluations that involve testing or the use of professional consultants shall be reviewed by GSA before recommendations are carried out. This is needed to ensure the conclusions are correct and the recommended actions appear appropriate from a technical standpoint. The GSA regional office responsible for IAQ should be solicited to review such reports where feasible. Following a review, the GSA regional office responsible for IAQ shall communicate their response back to the LAM, who shall then share that information with the tenant and lessor as appropriate. This would not apply to routine IAQ issues involving temperature, relative humidity, and general ventilation.

When an investigation into an IAQ concern results in no adverse condition or demonstrates unique sensitivity among one or more agency employees, GSA shall include in their communication to the agency the following:

• the agency’s right to conduct their own investigation, at their own expense; ● any relevant limitation of the lease contract requirements; ● recognition that the IAQ concern may be the result of a case of hypersensitivity; ● results of any testing performed;

While GSA’s communications are with the lessor and occupant agency representative, GSA should encourage the occupant agency representative to communicate activity and results associated with an IAQ issue with the complainant.


Page 31

Process: The following flowchart illustrates the steps recommended upon notification of an IAQ concern in GSA leased facilities.


Page 32

Frequently Asked Questions (FAQs)

1. What are some examples of instances where an IAQ concern or related request is beyond the responsibility of both GSA and the lessor? A. An occupant agency employee has an unusual or unique sensitivity to something in the office

environment such as: formaldehyde, mold, or dust. B. The lessor and/or GSA have evaluated the space and found that levels of IAQ parameters are all

within normal or acceptable ranges. For example, a tenant employee reports a skin rash and potential causes in the office are limited to particles (dust) or chemical vapors and gases. But testing by the lessor or GSA show dust, vapor and common gas levels are normal or within acceptable ranges.

C. An occupant agency requests an IAQ evaluation for a substance that could clearly not be found in the lease space, such as unusual chemicals or dusts.

D. A occupant agency requests an IAQ evaluation for a substance that could not cause an acute health problem or whose effects do not match the concerns, such as:

i. physical symptoms from radon gas ii. breathing, coughing or nasal irritation symptoms from asbestos

iii. headaches from lead-paint

NOTE: Any subsequent investigation or assessment done by the agency should be performed by a professional experienced in IAQ such as an industrial hygienist. The result of such effort needs to be sufficiently detailed and explicit to permit GSA and/or the lessor to correct any resulting findings.

2. What are the most common and basic IAQ elements every lessor should be responsible for?

A. Temperature B. Relative humidity C. Ventilation that meets the ASHRAE 62 standard

Dust and odor control during construction and maintenance work D. Expedient cleanup of any water and associated repairs

(within 48-72 hours to avoid mold growth) E. Asbestos Management Plan F. Radon testing and maintaining levels to within acceptable limits

3. What are the most common IAQ concerns or requests in GSA leased facilities? A. Mold from plumbing problems or water leaks B. Odors and/or dust from nearby construction or maintenance work C. Asbestos or lead-paint dust in the air D. Formaldehyde from furniture or finishes E. Radon

4. When GSA regional environmental health and safety (EHS) staff should be called in to consult on an IAQ concern or request in leased facilities?


Page 33

EHS may be needed to review the resulting report to interpret IAQ information or offer any recommendations that appear reasonably feasible. Regional EHS staff may also be requested by the LAM to translate technical IAQ information into lay-terms, or offer recommendation for IAQ testing, evaluation or mitigation. Routine IAQ concerns involving common service call issues such as temperature, relative humidity or general ventilation should almost never require the involvement of EHS staff. Likewise, EHS staff should not be needed once an IAQ concern is resolved. 5. What is the proper response when a water leak or other moisture intrusion has been discovered in a

leased facility? In the event of moisture intrusion, the LAM should ensure appropriate measures are being taken to avoid mold growth. The Environmental Protection Agency recommends those responsible for taking measures, follow their Mold Remediation for Schools and Commercial Buildings (EPA 402-K-01-001, 2008) guidelines, which stress the following: A. Clean up the water and moisture damage as soon as possible B. Keep the relative humidity below 60% throughout the process C. Remove water damaged materials that cannot be completely dried or cleaned (for example:

drywall and ceiling tiles). D. Take precautions during cleanup to minimize kicking mold spores into the surrounding air. E. Air sample for mold, to assist in determining that cleanup is complete.

(Note: air sampling or testing is often requested by the occupant agency to assist them in assuring their employees the space is sufficiently clean. Beyond that, air sampling should not be relied upon as the sole indicator of successful mold remediation. Some water intrusion or mold presence can avoid air sampling detection.)

6. What needs to be done, if anything, with a newly constructed, build-to-suit lease? New finishes, coatings, and fabrics can off-gas odors due to chemicals used in their construction. To minimize IAQ concerns from the odors or ill effects from the chemicals, new leased facilities should be ventilated with fresh air for three days or more prior to occupancy.

http://www.epa.gov/mold/mold_remediation.html

http://www.epa.gov/mold/mold_remediation.html

Documents

For Indoor Air Quality Management - GSA · PDF fileFor . Indoor Air Quality Management . Companion to . ... EPA’s “Guidelines for Response to Clean Water Damage” ... complaint