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The Public Right-of-Way Accessibility Guidelines (PROWAG) rulemaking has concluded. The PROWAG final rule has been published in the Federal Register. Please visit the Access Board’s PROWAG page for the guidelines.

Indoor Environmental Quality

The O & M Committee identified pesticides (indoors & outdoors), fragrances (especially fragrance-emitting devices/FEDS, air fresheners and deoderizers), and volatile cleaners (including citrus & pine) as the biggest access barriers for people with chemical sensitivities related to operations and maintenance of a building. Cell phone use was identified as a significant barrier for people with electromagnetic sensitivities.

The Committee developed recommendations for making buildings more accessible for people with chemical and/or electromagnetic sensitivities in the areas of pest control, cleaning & disinfecting, mechanical / HVAC, landscape maintenance, and enclosure maintenance. They are listed in bullet form in the Appendix and summarized in the body of the report below.

In addition, recommendations are given for renovation, remodeling, and furnishings and for adoption of polices on smoking, fragrances, cell phone use, notification of building activities, and vehicle idling.

The Committee recognizes that the list of recommendations is long and that few buildings will be able to implement all of them. The recommendations are the ideal goal towards which to strive. Any steps taken to reduce the levels of the problematic substances or conditions listed above will improve access for people with chemical and/or electromagnetic sensitivities and create a healthier building.

Some of the recommendations will not apply to certain types of buildings or geographic areas. The recommendations are given in sufficient detail to help those who need to address a specific issue. Resources from which to obtain more information or guidance are also provided in the Appendix and at the end of the document in Additional Resources.

Recommendations for Pest Control

Adopt an Integrated Pest Management (IPM) program for building interiors and grounds as described in “Healthy Hospitals, Controlling Pests Without Harmful Pesticides” (17). The Los Angeles Unified School District also has an exemplary plan for an IPM program (18).

IPM is a program of prevention, monitoring, record-keeping, and control that eliminates or drastically reduces the use of pesticides. The focus of IPM is to prevent pest problems by reducing or eliminating sources of pest food, water, and shelter and by maintaining healthy lawns (19) and landscapes.

The first approach in controlling a pest outbreak is to improve sanitation, make structural repairs (such as fixing leaky pipes and caulking cracks), and using physical or mechanical controls such as screens, traps, vacuums, and mechanical weed cutters. Increased sanitation measures include more frequent trash removal, restricting eating to designated areas, securing trash container lids, and steam cleaning trash containers. The IPM approach uses knowledge of a pest’s biology, habitat, and needs to time specific interventions to prevent and control pests. A least hazardous chemical is used only when other strategies have failed.

Pesticide use is discouraged in a true IPM program. If pesticides are used indoors or outdoors, however, the following precautions should be taken—notification of applications (even for “spot” or crack & crevice treatments) should be given through posting of signs (before, during, and after applications) and by other means to building occupants, especially those on a pesticide notification registry (20), applications should only be made by a licensed applicator, applications should not be made inside buildings by spraying, fogging, bombing, or tenting, and applications should not be made in occupied areas or areas that may become occupied during the 24 hours (at a minimum) following an application. In buildings that are constantly occupied, pesticide applications should be made when they are least occupied. It is recommended that pesticides be applied when there is the longest time before the area will be re-occupied, such as at the beginning of a weekend or vacation period.

The Committee recommends that certain pesticides, such as organophosphates, carbamates, pyrethroids, and other neurotoxic insecticides; 2,4-D, other phenoxy herbicides, and glyphosate; and fungicides such as mancozeb, chlorothalonil, and maneb, never be used.

Recommendations for Cleaning and Disinfecting

Use fragrance-free, low-VOC cleaning products. Do not use fragrance-emitting devices (FEDS), plug-ins, or sprays; urinal or toilet blocks; or other deodorizer/re-odorizer products. Reduce odors by increasing cleaning and ventilation and/or using baking soda or zeolite to absorb odors. Do not use products containing paradichlorobenzene (21) or naphthalene, which are common ingredients in FEDS.

Do not use cleaner/disinfectant combination products. Avoid or limit the use of products containing chlorine, ammonia, quaternary ammonium, phenol, isopropyl and other alcohols, formaldehyde, and other petroleum distillates. Do not use citrus- or pine-based products. Hydrogen peroxide-based products are the preferred disinfectants, but still should be used with caution and care. Use hot water for cleaning to reduce the need for soaps, detergents, and disinfectants.

Use disinfectants only in areas and at strengths (i.e., levels of disinfection) required by law. Check with local health department to obtain details of all legal requirements. Clean surfaces thoroughly before disinfecting. Leave disinfectants in place for the correct amount of time before wiping surfaces clean.

Audit cleaning chemicals currently in use and develop a plan to replace with safer alternatives.

Vacuum frequently and thoroughly using vacuums with HEPA filters and strong suction. If carpets must be cleaned, use steam or least toxic all-purpose cleaner or carpet cleaner that does not contain petroleum solvents. Spot clean whenever possible. Clean stains while they are fresh to avoid the need for aggressive cleaning later. Dust hard surfaces with a lint-free cloth, or with water only.

Spray cleaning products on to cloths rather than on to surfaces or into the air. Dry all washed surfaces with a dry cloth or mop to reduce chemical residue and chance of mold growth. Minimize the use of floor waxes and buffing.

Ventilate well when using cleaning products. Post signs during cleaning. Make cleaning schedule available to employees or others upon request.

Schedule heavy cleaning, repairs and maintenance during low or no-occupancy periods whenever possible.

Prohibit occupant usage of cleaning chemicals except as authorized. Establish a list of least toxic, low-VOC cleaning products (and/or provide them to employees) which they can use to clean computers, erase felt pen writing on white board, and perform other similar activities.

In decorative building fountains, use the minimum amount of chlorine necessary for disinfection, avoid the use of bromine, use closed ozone water treatment systems to the maximum extent possible, and make use of newer, less-toxic disinfecting technologies as they become available.

Avoid the use of wall-mounted devices, similar to fragrance-emitting devices (FEDS), that operate automatically or by pushing a button to dispense deodorizers, disinfectants, and pesticides.

Recommendations for Mechanical Equipment / HVAC

Adhere to a strict maintenance schedule for HVAC equipment and make sure it is working properly. Use the highest efficiency filters compatible with current HVAC system, and if necessary, consider retrofitting the system to increase filtration capabilities. Maintain relative humidity between 30% and 50%.

Use non-chemical methods to maintain HVAC ducts free of particulate matter, dust, and debris, such as physical removal or use of vacuums. Do not use the HVAC system to disperse fragrances or other materials.

Seal return air openings into HVAC system during remodeling and exhaust directly to the outdoors, by temporarily removing window glazing if necessary.

Use demand controlled ventilation (DCV) that provides liberal amounts of air flow and outdoor air ventilation. Before a building is re-occupied in the morning or after weekends, flush with at least three complete outdoor air exchanges.

Create door and window-opening protocol to maintain proper pressure relationships and air flow in the building. Educate and provide protocol to staff and other building occupants. Policy should include provision that allows chemically sensitive and other individuals to open windows on a temporary or regular basis, as needed because of a health condition. Windows should also be permitted to be opened by occupants when the HVAC system is not working or shut off, such as may occur during nights and weekends.

Make maximum use of economizer cycle. Avoid energy conservation practices that reduce intake of outside air below minimum requirements.

Avoid or minimize the use of humidifiers in the building’s HVAC system. Prohibit the use of personal humidifiers except when an occupant has a medical need for one. Maintain the cleanliness of all humidifier equipment and use the minimum amount of water treatment chemicals necessary to control dissolved solids and pH and prevent antimicrobial contamination. Do not allow the use of portable air “cleaners” that emit ozone.

Repair plumbing with least toxic, low-VOC materials. Use snakes or other mechanical methods to clear clogged drains. Use bacterial enzymes to prevent drain clogs. Inspect floor and other drains, especially those that are infrequently used, to ensure there is water in the P-traps, thereby avoiding sewer gas backup. Treat grease traps daily with bacterial enzymes.

Recommendations for Landscape Maintenance

Maintain lawns and gardens organically. Use integrated pest management (IPM) to eliminate or minimize the use of herbicides, fungicides, insecticides, and other pesticides. Maintain soil health. Avoid the use of synthetic fertilizers.

Pull, mow, or use mechanical weed cutters to remove weeds. Vinegar can be used to kill weeds along fence lines and other hard to reach places.

Avoid dust-blowing equipment like leaf blowers. Sweeping, raking, and use of vacuums are the preferred methods for removing debris.

Avoid diesel-powered and 2-cycle engine equipment. Use electric lawn and landscape equipment whenever possible.

Use rock, gravel, flat stones, or pavers for mulch, and/or use typar landscape barrier to suppress weeds. Avoid organic mulches, like cocoa beans, peat moss, wood chips, and bark, especially near operable windows and doors of buildings. These mulches usually emit volatile fumes and may produce or harbor mold.

Avoid the use of CCA wood or wood chips because they contain arsenic and other toxic chemicals which can leach into the environment. Do not use railroad ties because they contain creosote.

Apply pesticide, fertilizers, and lime only when there is little or no wind and apply them in a manner that prevents drift. Post signs and provide advance notification to building occupants before starting these applications.

Use least toxic, low-VOC paints, stains, and finishes on outside equipment, like benches, poles, decks, and porches.

Recommendations for Enclosure Maintenance

It is important to properly maintain the building envelop in order to prevent mold problems and block pest entry.

Routinely inspect and clean roof and gutters to make sure they are draining properly. Promptly repair roof or plumbing leaks. Regularly inspect walls and foundations, especially all utility entrance seals (e.g., phone, water, electric, and cable) for cracks and repair promptly if found. Insulate cold pipes to prevent condensation.

Promptly remove wet ceiling tiles and wall panels.

Remove excess water from carpeting damaged by clean water and quickly dry it to avoid mold buildup. Do not use disinfectants or moldicides (other than hydrogen peroxide-based ones). Instead, utilize a steam extraction carpet cleaning system with a hydrogen peroxide-based cleaner/disinfectant. Inspect carpet after it is completely dried to ensure there is no mold or mildew. Those with asthma or chemical sensitivities should be removed from areas where there is wet carpeting. Remove carpeting if it has been wet longer than 24 hours.

Immediately remove and do not re-use any wet carpeting that has been contaminated with sewer water, heavy dirt and soils, or toxic chemicals.

Seal rusted surfaces with a least toxic low VOC sealant to minimize emissions of airborne particles.

Recommendations for Renovation/Remodeling/Furnishings

It is recommended that buildings and furnishings be well maintained to reduce the need for renovation and remodeling. Chemically sensitive individuals often tolerate older building materials and furnishings better than new ones because older materials have usually outgassed and emit lower levels of VOCs.

If renovation and remodeling is done, however, efforts should be made to limit activities to select areas, rather than being done on a wide scale. They should be performed when the areas are unoccupied (or the least occupied in buildings that are in constant use).

If new materials and finishes are applied (especially wet-applied products such as paints, sealants, caulks, and adhesives), maximum outdoor air ventilation with no recirculation should be employed during and for a reasonable period of time after the application.

When possible, new furnishings should be thoroughly aired out before being brought into the occupied space.

Indoor Air & Environmental Quality Program

The O&M Committee recommends that facilities adopt an Indoor Air & Environmental Quality Program (IAQ/IEQ) to promote practices that prevent or reduce the contamination of indoor air, thereby contributing to a safe, healthy, productive and comfortable environment for building occupants. Benefits of good IAQ/IEQ may include improved health of occupants, decrease in the spread of infectious disease, protection of susceptible populations, increased productivity of occupants, improved relationships/fewer complaints, reduction in potential building closures (due to unhealthful conditions), less deterioration of buildings and equipment, reduced maintenance costs, and decreased liability and risk (22).

An IAQ/IEQ Program should include the maintenance of a log that records building problems and health complaints reported by building occupants.