Roanoke Times
Copyright (c) 1995, Landmark Communications, Inc.
DATE: THURSDAY, September 1, 1994 TAG: 9410130003
SECTION: EDITORIAL PAGE: A19 EDITION: METRO
SOURCE: STEPHEN J. CALDEIRA
DATELINE: LENGTH: Long
Eighteen years later, indoor air quality, or IAQ, continues to draw national attention, with studies linking contaminants in indoor air to an array of health symptoms ranging from headaches to dizziness and nausea. Offices, schools, homes and other buildings contain thousands of different chemicals, from carpet adhesives to paint to emissions from copiers.
The effects are compounded in energy-efficient buildings constructed since the 1970s. These ``tight'' buildings often have sealed windows and central ventilation systems that let in minimal amounts of outside air, often leading to more air pollution indoors than outdoors. Because Americans spend an estimated 90 percent of their time indoors, IAQ has the potential to affect more people than perhaps any other environmental problem.
As a sign of intensified concern over indoor air quality, 1994 has seen unprecedented legislative activity. At the federal level, Congress and more than 30 agencies are searching for sound approaches to improve the air indoors - witness last month's approval by the House Energy and Commerce Committee of a bill that would require the Environmental Protection Agency to devise a strategy to reduce indoor air pollution.
Likewise, state legislators have addressed issues including radon, environmental tobacco smoke, electromagnetic fields, and building design, maintenance and ventilation. This fall, the federal Occupational Safety and Health Administration will open the most significant debate yet on the indoor environment, with implications for millions of businesses nationwide.
Those concerned about the workplace environment should proceed with caution. In recent years, public policy frequently has moved ahead of sound science to address perceived threats. Issues from global warming to the Alar apple scare have gained national attention, often resulting in costly and unnecessary measures that achieved no actual environmental or public-health improvement. Swift legislative and regulatory action on indoor air quality would only repeat these mistakes because, even though the knowledge base is growing, the science surrounding the issue remains incomplete.
With that truth in mind, it is essential that we judge how efficient and how effective OSHA's IAQ regulation will be in achieving its stated goals. To OSHA's credit, some provisions in the regulation are a step in the right direction. For example, OSHA's building system approach calls for the routine maintenance of heating, ventilating and air conditioning, or HVAC, systems to ensure proper ventilation and adequate fresh air. According to the EPA, such maintenance can alleviate roughly 80 percent of indoor air-quality problems. This and other practical management steps endorsed by the Total Indoor Environmental Quality Coalition can go a long way toward improving indoor air.
Still, many provisions fail the efficiency and effectiveness tests, given the compliance costs that OSHA's one-size-fits-all approach will impose, particularly on small business. The major flaws are these:
The rule places the responsibility for implementation on employers, despite the fact that they frequently have no control over the HVAC system and building-management practices, the cause of most IAQ complaints.
The required paperwork and record keeping will prove onerous to businesses. The IAQ compliance program requires extensive documentation of a building's engineering, history and use. These records are often difficult and costly to produce, and sometimes impossible to find.
The rule requires employers to notify employees at least 24 hours in advance of the use of potentially hazardous chemicals. This requirement is neither efficient nor effective. Taken literally, it could mean that employers would have to alert their employees every day to nightly cleaning of floors and rest rooms.
OSHA's decision to use the rule as a means to launch a regulatory crackdown on a specific substance, environmental tobacco smoke, is a cause for concern. By not establishing a permissible exposure level based on sound scientific data and analysis, OSHA deviated from its own internal policies and procedures for regulatory action. This is an ominous precedent that, with regard to environmental tobacco smoke or many other substances, smacks of bureaucratic heavy-handedness and denies business owners or office managers the flexibility they ought to have to implement cost-effective IAQ policies.
Overall, in its zeal to ``do something'' about indoor air, OSHA has created an overly burdensome rule that is impractical to implement. Continued work by scientists and engineers specializing in heating, air conditioning and ventilation will bring the answers to the remaining questions about the indoor environment. Those scientific answers, and nothing short of them, should drive sound public policy. Until then, the appropriate response is to rely on those measures that we know will bring results. Sooner or later policymakers must realize that ``just doing something'' is not the same as doing it right.
Stephen J. Caldeira is executive director of the Total Indoor Environmental Quality Coalition, formed in 1991 to educate the public and policy-makers of the need for science-based, practical solutions to indoor environmental problems.
Knight-Ridder/Tribune News Service
by CNB