IEQ Indoor Environmental Quality Project

The Architectural and Transportation Barriers Compliance Board (Access Board) is an independent federal agency devoted to accessibility for people with disabilities. The Access Board is responsible for developing and maintaining accessibility guidelines to ensure that newly constructed and altered buildings and facilities covered by the Americans with Disabilities Act and the Architectural Barriers Act are accessible to and usable by people with disabilities. In November 1999, the Access Board issued a proposed rule to revise and update its accessibility guidelines. During the public comment period on the proposed rule, the Access Board received approximately 600 comments from individuals with multiple chemical sensitivities (MCS) and electromagnetic sensitivities (EMS). They reported that chemicals released from products and materials used in construction, renovation, and maintenance of buildings, electromagnetic fields, and inadequate ventilation are barriers that deny them access to most buildings.

Americans spend about 90 percent of their time indoors, where concentrations of air pollutants are often much higher than those outside. According to the U.S. EPA Healthy Buildings, Healthy People: A Vision for the 21st Century, "Known health effects of indoor pollutants include asthma; cancer; developmental defects and delays, including effects on vision, hearing, growth, intelligence, and learning; and effects on the cardiovascular system (heart and lungs). Pollutants found in the indoor environment may also contribute to other health effects, including those of the reproductive and immune systems." (p. 4). The report further notes that "Most chemicals in commercial use have not been tested for possible health effects. (p. 8).

There are a significant number of people who are sensitive to chemicals and electromagnetic fields. Surveys conducted by the California and New Mexico Departments of Health and by medical researchers in North Carolina found 16 to 33 percent of the people interviewed reported that they are unusually sensitive to chemicals, and in the California and New Mexico health departments' surveys 2 percent to 6 percent reported that they have been diagnosed as having multiple chemical sensitivities C. Miller and N. Ashford, "Multiple Chemical Intolerance and Indoor Air Quality," in Indoor Air Quality Handbook Chapter 27.8 (McGraw-Hill 2001). Another California Department of Health Services survey has found that 3 percent of the people interviewed reported that they are unusually sensitive to electric appliances or power lines. P. LeVallois, et al., "Prevalence and Risk Factors of Self-Reported Hypersensitivity to Electromagnetic Fields in California," in California EMF Program, "An Evaluation of the Possible Risks From Electric and Magnetic Fields (EMFs From Power Lines, Internal Wiring, Electrical Occupations and Appliances, Draft 3 for Public Comment, April 2001" Appendix 3.

Individuals with multiple chemical sensitivities and electromagnetic sensitivities who submitted written comments and/or attended the public information meetings on the draft final rule, requested that the Access Board include provisions in the final rule to make buildings and facilities accessible for them.

The Board has not included such provisions in their rules, but they have taken the commentary very seriously and acted upon it. As stated in the Background for its Final Rule Americans with Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities; Recreation Facilities

"The Board recognizes that multiple chemical sensitivities and electromagnetic sensitivities may be considered disabilities under the ADA if they so severely impair the neurological, respiratory or other functions of an individual that it substantially limits one or more of the individual's major life activities. The Board plans to closely examine the needs of this population, and undertake activities that address accessibility issues for these individuals.

The Board plans to develop technical assistance materials on best practices for accommodating individuals with multiple chemical sensitivities and electromagnetic sensitivities. The Board also plans to sponsor a project on indoor environmental quality. In this project, the Board will bring together building owners, architects, building product manufacturers, model code and standard-setting organizations, individuals with multiple chemical sensitivities and electromagnetic sensitivities, and other individuals. This group will examine building design and construction issues that affect the indoor environment, and develop an action plan that can be used to reduce the level of chemicals and electromagnetic fields in the built environment."

This report and the recommendations included within are a direct outgrowth from that public comment process. The Access Board contracted with the National Institute of Building Sciences (NIBS) to establish this Indoor Environmental Quality Project as a first step in implementing that action plan.

A broad and distinguished Steering Committee was established and met in January 2004 in Bethesda, Maryland, to review the project objectives. Subsequently four task teams (committees) were established to address specific issues in buildings related to Operations & Maintenance, Cleaner Air Rooms, Design and Construction, and Products and Materials. The following reports from these four committees offer recommendations for improving IEQ in buildings. They also list valuable resources and references to allow readers to investigate the pertinent issues in greater depth. The focus of the project was on commercial and public buildings, but many of the issues addressed and recommendations offered are applicable in residential settings.

Many volunteers worked diligently to create the recommendations in this report. These individuals are listed in the separate committee sections of the report, but special thanks go to the committee chairs: respectively Hal Levin, Building Ecology Research Group; Michael Mankin, California Division of the State Architect; Roger Morse, Morse-Zentner Associates; and Brent Kynoch, Kynoch Environmental Management, Inc. Lastly, an enormous debt of gratitude is owed to four amazing individuals who made significant contributions to the work of all four committees: Mary Lamielle, National Center for Environmental Health Strategies; Ann McCampbell, MD, Multiple Chemical Sensitivities Task Force of New Mexico; Susan Molloy, National Coalition for the Chemically Injured; and Toni Temple, Ohio Network for the Chemically Injured.

The overall objectives of this project were to establish a collaborative process among a range of stakeholders to recommend practical, implementable actions to both improve access to buildings for people with MCS and EMS while at the same time raising the bar and improving indoor environmental quality to create healthier buildings for the entire population.

This IEQ project supports and helps achieve the goals of the Healthy Buildings, Healthy People project, which acknowledges that "We will create indoor environments that are healthier for everyone by making indoor environments safer for the most vulnerable among us, especially children." (p.17)

Summary Recommendations

The recommendations in this report are only a first step toward the action plan envisioned by the Access Board.

The NIBS IEQ committee offers several recommendations for further action. It is recommended that a follow-on project organize and convene one, or more, workshops to deliberate the issues and recommendations in this report. It is also recommended that a project be organized to develop a single guidelines document. Such guidelines would be built on refinement and coordination of the recommendations of the Design & Construction and Products & Materials committees in this report. This same, or a separate project, should develop new building code provisions to accelerate the implementation of improved IEQ. Lastly, it is recommended that a project be organized to develop guidelines for the design of an "ideal space" for people with MCS and EMS. The recommended follow-up projects should involve collaborative effort and funding from a range of organizations across the building community; e.g., American Institute of Architects (AIA), Associated General Contractors of America (AGC), Building Owners & Managers Association International (BOMA), American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), Environmental Protection Agency (EPA), and, of course, the Access Board.

Steering Committee

Nicolas Ashford, Massachusetts Institute of Technology
Kathy Barcus, Clarke Construction Company, Inc.
Marilyn Golden, Disability Rights Education and Defense Fund (DREDF)
Harry Gordon, Burt Hill Kosar and Rittelmann Associates
Mark Jackson, Lennox Industries, Inc.
Brent Kynoch, Kynoch Environmental Management, Inc.
Mary Lamielle, National Center for Environmental Health Strategies
Ann McCampbell, Multiple Chemical Sensitivities Task Force of New Mexico
Claudia Miller, University of Texas Health Sciences Center - San Antonio
Susan Molloy, National Coalition for the Chemically Injured
Roger Morse, Morse Zentner Associates
Larry Perry, Building Owners and Managers Association
Bruce Small, Building Inspections
Toni Temple, Ohio Network for the Chemically Injured
James Wasley, University of Wisconsin-Milwaukee

James Raggio, Access Board
Alexander Shaw, National Institute of Building Sciences