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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 operation and maintenance of commercial and public buildings can affect their accessibility for people with asthma and multiple chemical and/or electromagnetic sensitivities. The presence of many products or conditions involved in cleaning, maintaining, using, and operating buildings often contributes to poor indoor environmental quality and are access barriers for these individuals.

Problematic substances include, but are not limited to, pesticides, fragrances, disinfectants, many cleaners and new building materials and furnishings, and smoke and other engine exhaust. Inadequate ventilation of a building further contributes to poor indoor environmental quality.

The presence of electromagnetic fields from office equipment and other sources is a barrier for those with electromagnetic sensitivities. Noise and vibration can adversely affect some people with chemical and/or electromagnetic sensitivities and trigger seizures in susceptible individuals.

General Solutions

Measures taken to improve indoor environmental quality, such as reducing air pollutants, noise and electromagnetic fields in buildings, will increase their accessibility for people with asthma and chemical and/or electromagnetic sensitivities, as well as provide a more healthful environment for all building occupants.

While “green” and “environmentally-friendly” practices and products for construction and maintenance of buildings sometimes provide more healthful indoor environments and improves access for those with asthma and multiple chemical sensitivities, this is not always the case. The U.S. EPA notes that there is growing concern that standards being promoted by the green building movement, such as Green Seal and Green Guard standards, are not sufficiently protective of health (1).

For example, some measures recommended to promote energy and water conservation—such as reducing outdoor air supplied and/or reducing time of HVAC usage, using motion sensors that can create electromagnetic fields, using waterless urinals that require continuous chemical treatments, recommending cold water for cleaning, and promoting the use of alcohol hand wipes instead of hand washing—can cause or lead to increased indoor pollution and less healthful and accessible environments.

In addition, “greener cleaners” often promote the use of citrus- and/or pine-based products, which can react with even low levels of oxidants, such as ozone, to produce hazardous byproducts, as well as make buildings inaccesible for many people with chemical sensitivities. The addition of either synthetic or natural fragrances to cleaning and other products is also problematic for chemically sensitive individuals.

Other common green building recommendations, such as building on brownfields, using tuck-under parking, and putting heliports or gardens on roofs can also lead to diminished indoor air quality and create barriers for people with chemical sensitivities.

Lastly, the green building community has yet to provide guidance on the issue of electromagnetic fields.

Barriers & IssuesFragrances

The presence of perfume, cologne, scented cleaners and other scented products contributes to poor indoor air quality and is one of the major access barriers for people with asthma and multiple chemical sensitivities.

“Fragrances” are chemical compounds added to a product to give it a scent. There are approximately 3000 chemicals used in the manufacture of fragrances. Most of these chemicals are synthetic and derived from petroleum. Chemicals found in fragrance formulations include toluene, alcohols, formaldehyde, styrene, benzene, limonene, phthalates, and musk. An individual fragrance formula may contain over 100 chemicals, but their identity is protected as a trade secret. Fragrances do not have to be tested for safety before they are put on the market (2).

Exposure to fragrances can trigger asthma attacks and migraine headaches, and aggravate sinus conditions. In those who are chemically sensitive, fragrance exposures can also cause irregular heartbeat, memory loss, confusion, fatigue, and neurological, vascular, and other problems. In addition, some fragrance chemicals are implicated in causing cancer and/or damaging the liver, kidneys, and central nervous system. Fragrance chemicals can enter the body via inhalation, skin absorption, or nasal passageways.

According to a 1986 U.S. House of Representatives Report:

“In 1986, the National Academy of Sciences targeted fragrances as one of the six categories of chemicals that should be given high priority for neurotoxicity testing. The other groups include insecticides, heavy metals, solvents, food additives and certain air pollutants. The report states that 95 percent of chemicals used in fragrances are synthetic compounds derived from petroleum. They include benzene derivatives, aldehydes, and many other known toxics and sensitizers, which are capable of causing cancer, birth defects, central nervous system disorders and allergic reactions. “ (3)

If a product label lists “fragrance” as an ingredient on the back of the label, it contains added fragrance, even if the front label says the product is “unscented” or “fragrance-free”. If “fragrance” is not listed as an ingredient, it may still contain fragrance chemicals or contain natural fragrances.

The main sources of fragrances in buildings are from 1) fragrance-emitting devices (FEDS), sprays, and deodorizers, 2) other scented cleaning and maintenance products, 3) perfume; cologne; essential oils; and scented skin and hair products, cosmetics, and other personal care products, 4) clothing that has been laundered with scented detergents, fabric softeners, or dryer sheets, and 5) potpourri, incense and scented candles (even when incense or scented candles are not burning). Sometimes fragrance is added to and dispersed by a building’s ventilation system.


Pesticides are hazardous chemicals designed to kill or repel insects, plants, and other pests. The term pesticide applies to insecticides, herbicides (weed-killers), fungicides, rodenticides, disinfectants, and other substances used to control pests. Many pesticides contain volatile and/or semi-volatile chemicals that contribute to poor indoor air and environmental quality (IAQ/IEQ).

A pesticide product consists of the active ingredient(s) and “inert” ingredients. Active ingredients are the chemicals that kill or repel the pest. The rest of the product is composed of “inert” ingredients, which often comprise over 95% of the pesticide product. “Inert” ingredients are commonly solvents and may be as, or more, toxic than the active ingredient(s).

Individuals exposed to pesticides are at risk for both acute and chronic health effects (4, 5, 6, 7). Pesticide exposures can exacerbate asthma and cause nausea, headaches, rashes, dizziness, fatigue and memory loss. Many pesticides are also linked with causing cancer, birth defects, neurological and reproductive disorders, and the onset and exacerbation of chemical sensitivities. Pesticide exposure can occur long after its application because pesticide products are often designed to be persistent in the environment.

For people who are chemically sensitive, exposure to even minute amounts of pesticides from, for example, pesticide drift from neighborhood lawn treatments, driving on a road where herbicides have been sprayed weeks earlier, or being in a building that was treated with pesticides even several years earlier, can cause severe, sometimes, life-threatening and/or prolonged illness (8). Thus the presence of pesticides is one of the greatest access barriers for people with chemical sensitivities.

The use of pesticides can be eliminated or significantly reduced through implementation of Integrated Pest Management (IPM) programs. 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 and landscapes. The first approach to 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 and mechanical weed cutters. A least hazardous chemical is used only when other strategies have failed.

IPM strategies are being increasingly implemented in schools, parks, government facilities, and hospitals nationwide. One needs to be aware, however, that the term IPM is sometimes inappropriately used for pest management programs that use or recommend the use of significant amounts of pesticides.

Cleaning Products and Disinfectants

Many toxic chemicals are found in janitorial cleaning supplies used in industrial and commercial facilities. They often emit volatile organic compounds (VOC’s) (9), contribute to poor indoor air quality (IAQ), and create access barriers for people with asthma, allergies, and/or chemical sensitivities. Some of these chemicals are associated with human health effects, including cancer, damage to major organs, interference with normal reproduction and development, and even death. (10).

Even “greener cleaners” may contain volatile substances, like citrus or pine, that can cause adverse health effects in building occupants.

There is a wide range of cleaning and maintenance products that include, but are not limited to, air fresheners, deodorizers, bathroom and tile cleaners, dusting aids, engine and other degreasers, lubricants, fabric protectants, floor polishes and waxes, furniture polish, general purpose cleaners, glass cleaners, laundry products, oven cleaners, carpet and upholstery cleaners, graffiti remover, and floor strippers. One of the most hazardous cleaning operations for workers and building occupants is the stripping and refinishing of floors.

Some cleaning products also contain disinfectants. The U.S. EPA notes that one major concern from a health standpoint is the increased incorporation of antimicrobial agents and fragrances in cleaners and air fresheners marketed to reduce indoor air contamination (1).

Many commonly used disinfectant or sanitizer products contain chlorine, phenol, quaternary ammonium compounds, and isopropyl and other alcohols. These produce hazardous fumes and present access barriers for people with chemical sensitivities.

Electromagnetic Fields

For people who are electromagnetically sensitive, the presence of cell phones and towers, portable telephones, computers, fluorescent lighting, unshielded transformers and wiring, battery re-chargers, wireless devices, security and scanning equipment, microwave ovens, electric ranges and numerous other electrical appliances can make a building inaccessible.

The National Institute for Occupational Safety and Health (NIOSH) notes that scientific studies have raised questions about the possible health effects of EMF’s. NIOSH recommends the following measures for those wanting to reduce EMF exposure—informing workers and employers about possible hazards of magnetic fields, increasing workers’ distance from EMF sources, using low-EMF designs wherever possible (e.g., for layout of office power supplies), and reducing EMF exposure times (11).


Many new building materials, such as paints, adhesives, wallboard, carpet, and insulation, as well as upholstered furniture, particleboard cabinets, and other furnishings emit hazardous volatile organic compounds (VOC’s), contribute to poor indoor air quality (IAQ) and create significant access barriers for people with asthma and/or chemical sensitivities. These materials often outgas and are problematic for prolonged periods of time.

Smoke & Combustion

Many people with asthma and most people with chemical sensitivities are made sick by exposure to: 1) smoke, such as that from tobacco, fireplaces, candles, incense, and barbeques, and other outdoor fires, 2) vehicle and other engine exhaust, especially exhaust from vehicles using diesel or oxygenated fuel, and 3) combustion appliances burning kerosene, propane, or natural gas (natural gas usually being better tolerated than kerosene or propane). If combustion appliances are used, they should be directly vented to the outdoors. Electrical appliances are preferred by people with chemical sensitivities.

Noise & Vibration

Noise and vibration from HVAC systems, vacuums, pumps, helicopters and other sources can trigger severe symptoms, including seizures, in susceptible individuals.

Synergistic Effects of Indoor Air Pollutants

Indoor air is a “chemical soup” made up of a variety of chemicals emitted by building materials, cleaning products, pesticides, personal care and consumer products, emissions from building equipment and activities, etc. While individual chemicals may be hazardous, combinations of chemicals can be even more hazardous through additive or synergistic effects. Synergistic effects occur when the health impacts of a chemical combination is greater than the sum of the impacts of the individual chemicals.

Indoor Air Chemistry

In indoor air, chemicals can react with one another to form other compounds that are more hazardous than the original chemicals. Increasing evidence has shown that ozone and hydroxyl radicals formed by other oxidants can react with alkenes (such as limonene found in citrus and fragrance formulations, as well as terpenes emitted by many wood products) to generate secondary pollutants, including formaldehyde, as well as hydroxy radicals that can react with organics to form other potentially toxic air pollutants. The toxicity of many of these secondary pollutants is well-established while for others it has yet to be evaluated (12, 13, 14, 15, 16). These reactions can be limited by employing carbon-based filters in locations where outdoor ozone concentrations commonly approach or exceed the National Ambient Air Quality Standards (NAAQS) promulgated by the U.S. EPA.

Persistence of Indoor Air Pollutants

Many porous building materials and furnishings, such as carpeting, couches, drapes, and wallboard, absorb cleaning chemicals, fragrances, pesticides, and other air pollutants. Chemicals adsorb to virtually all indoor surfaces but more strongly to rough rather than smooth surfaces. These processes are known as the “sink effect”. These chemicals can be re-emitted into the air for long periods of time leading to prolonged air pollution. For example, it is not uncommon for a building to retain the odor of a fragrance-emitting device (FED) months after it has been removed. Similarly, residual tobacco smoke can still be detected in buildings long after a no-smoking policy is implemented. Air pollutants clear more readily from buildings that contain a higher percentage of hard impermeable surfaces.