OSHA Issues Federal Advisory Regarding Poor Indoor Air Quality, Mold & Importance Of Building Maintenance

Spring 2011 ~ US Dept of Labor, Occupational Safety & Health Administration (OSHA) “INDOOR AIR QUALITY IN COMMERCIAL AND INSTITUTIONAL BUILDINGS” with original reference #15 being Katy’s Exposure Blog, see page 26.

When we updated the link on October 21, 2011 to show how the cases of Kelman & GlobalTox v. Kramer and Kelman v. Kramer in which the California courts framed environmental advocate, Sharon Kramer, for libel over a writing of how it became a scientific fraud in policy that it was proven mold toxins do not harm, ane the cases are aiding to defraud the public over the mold issue, OSHA quietly changed the link for reference #15 to a WHO publication. See page 26 in link below for the quiet change OSHA made.


For anyone having difficulty obtaining proper medical care or coverage, workers’ compensation benefits, and/or property casualty claims adjustment involving illness potentially caused by a water damaged work environment, school or residence; this is an excellent US federal advisory to share with your physician, employer, landlord, property manager, real estate broker, builder, IAQ advisor, legal advisor, and/or insurer. We are extremely appreciative to the folks at OSHA who are working hard to relay accurate scientific information to the private sector regarding illnesses caused by poor IAQ, particularly those caused by Water Damaged Buildings (WDB).

Below is a brief summary of the OSHA advisory as it pertains to potential illnesses caused by excessive exposure to microbial contaminants (mold, bacteria, etc) that are often found in poorly maintained and/or poorly constructed WDB.

Below that, is a summary of industry’s assault on science and why this life saving information is not reaching private sector physicians. This is directly because of the undue political influence of the US Chamber of Commerce over science, medicine, the courts and policy. In conjunction with the American College of Occupational & Environmental Medicine (ACOEM), a fraudulent concept which downplays the potential for illness from poor IAQ and biological contaminants has been mass marketed into policy.

Why the need for this Federal advisory?:
“IAQ has been identified by the EPA as one of the top five most urgent environmental risks to public health (2). The Centers for Disease Control and Prevention (CDC) estimates that the majority of Americans spend approximately 90 percent of their time indoors (3). On average, office workers spend approximately 40 hours a week in office buildings. These workers also study, eat, drink, and, in certain work settings, sleep in enclosed environments where make-up air (i.e., fresh air added to recirculated air) may be compromised. For this reason, some experts believe that more people may suffer from the effects of indoor air pollution than from outdoor air pollution.”

Applicable standards and regulations:
“OSHA does not have a general IAQ standard, but does provide guidelines addressing the most common workplace complaints about IAQ, which are typically related to temperature, humidity, lack of outside air ventilation, or smoking. OSHA standards address potential hazardous conditions leading to serious physical harm or death. Such standards may include those for specific air contaminants, ventilation systems, or the General Duty Clause of the Occupational Safety and Health Act of 1970 (OSH Act). All OSHA regulations, interpretations, and the OSH Act can be found on www.osha.gov.

Section 5(a)(1), often referred to as the General Duty Clause, requires employers to “furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harmto his employees.”

The stated purpose and audience for the advisory:
“This OSHA guidance document on IAQ provides practical recommendations that will help prevent or minimize IAQ problems in commercial and institutional buildings, and help resolve such problems quickly if they do arise. It provides flexible guidance to employers to help them keep their buildings free of pollutants or conditions that lead to poor IAQ. It also provides information on good IAQ management, including control of airborne pollutants, introduction and distribution of adequate make-up air, and maintenance of an acceptable temperature and relative humidity. Temperature and humidity are important because thermal comfort underlies many complaints about “poor air quality.”

“This document is directed primarily at employers, building owners and managers, and others responsible for building maintenance, but may also be used as a basic reference for all those involved in IAQ issues. Furthermore, information presented here can help with the decision of whether or not the services of an outside professional may be needed. The advice of a medical professional should always be sought if there are any immediate health issues. Contractors and other professionals (e.g., industrial hygienists or other environmental health and safety professionals) who respond to IAQ concerns, as well as members of the general public, may also find this information helpful.

Many IAQ complaints are associated with flaws in building design and by inadequate routine preventive maintenance of building enclosures (envelopes), plumbing, and HVAC systems (2, 4, 5). To resolve many IAQ problems, a preventive maintenance program should be established based on the system’s recommended maintenance schedule outlined by the architect or engineer, the manufacturer, or an HVAC professional. Regular preventive maintenance not only ensures that systems are operating properly, but also can result in cost savings, improved operating efficiency, and increased worker productivity (6).”

Known potential health effects of poor IAQ in general:
“Symptoms related to poor IAQ are varied depending on the type of contaminant. They can easily be mistaken for symptoms of other illnesses such as allergies, stress, colds, and influenza. The usual clue is that people feel ill while inside the building, and the symptoms go away shortly after leaving the building, or when away from the building for a period of time (such as on weekends or a vacation).

Health or symptom surveys, such as the one included in Appendix D, have been used to help ascertain the existence of IAQ problems. Failure of building owners and operators to respond quickly and effectively to IAQ problems can lead to numerous adverse health consequences. Health effects from indoor air pollutants may be experienced soon after exposure or, possibly, years later (8, 9, 10).

Symptoms may include irritation of the eyes, nose, and throat; headaches; dizziness; rashes; and muscle pain and fatigue (11, 12, 13, 14). Diseases linked to poor IAQ include asthma and hypersensitivity pneumonitis (11, 13). The specific pollutant, the concentration of exposure, and the frequency and duration of exposure are all important factors in the type and severity of health effects resulting from poor IAQ.

Age and preexisting medical conditions such as asthma and allergies may also influence the severity of the effects. Long term effects due to indoor air pollutants may include respiratory diseases, heart disease, and cancer, all of which can be severely debilitating or fatal (8, 11, 13).”

Known causes of potential illness from excessive exposure to biological contaminants in WDB:
“Although there are numerous indoor air pollutants that can be spread through a building, they typically fall into three basic categories: biological, chemical, and particle (1).

Biological: Excessive concentrations of bacteria, viruses, fungi, dust mites, animal dander, and pollen may result from inadequate maintenance and housekeeping, water spills, inadequate humidity control, condensation, or water intrusion through leaks in the building envelope or flooding.”

“Building Design: Design and construction flaws may contribute to indoor air pollution. Poor foundations, roofs, facades, and window and door openings may allow pollutant or water intrusion.”

“Building Systems Design and Maintenance: When the HVAC system is not functioning properly for any reason, the building is often placed under negative pressure. In such cases, there may be infiltration of outdoor pollutants such as particulates,..humid air,…contaminants, etc. Also, when spaces are redesigned or renovated, the HVAC system may not be updated to accommodate the changes. For example, one floor of a building that housed computer services may be renovated for offices. The HVAC system would need to be modified for office employee occupancy (i.e., modifying temperature, relative humidity, and air flow).”

“Animals, plants, and microbes are sources of air pollutants. Dander from animals, pollens from plants, and microbes, may act as allergens when they are inhaled. These biological contaminants are usually attached to dust particles of various sizes. Small dust particles may remain airborne for long periods, while large particles settle more quickly. However, particles that have settled may be easily resuspended in the ambient air by currents of air or other disturbances.

Drapery, carpet and other places where dust collects can harbor these contaminants; dirty cooling coils, humidifiers, condensate drains, and ductwork can incubate bacteria and molds. Areas with high humidity can accelerate their growth. The most common sources of biological air contaminants are moisture-laden areas that support the growth of mold and bacteria present in the air (8, 16, 19, 44).

Also, wet surfaces can provide a breeding ground for insects such as dust mites. Moisture-induced microbial growth can result from water leaks and/or by condensation due to high humidity. Common sources of moisture in buildings include: plumbing; roof and window leaks; flooding; condensation on cold surfaces, e.g., pipe sweating; poorly maintained drain pans; and wet foundations caused by landscaping or gutters that direct water into or under the building.Water vapor from unvented or poorly vented kitchens, showers, combustion appliances,or steam pipes can also create conditions that promote microbial growth.

The most effective means to prevent or minimize adverse health effects is to determine the sources of persistent dampness in the workplace and eliminate them…Also, strict adherence to a housekeeping schedule and use of HEPA-filtered vacuum cleaners will help reduce ambient levels of allergens.”

Known potential symptoms of excessive exposure to biological contaminants in WDB:
“Persistent dampness and microbial growth on interior surfaces and in building structures should be avoided or minimized as they may lead to adverse health effects (15)”. “Numerous species of bacteria and fungi, in particular filamentous fungi (mold), can contribute significantly to indoor air pollution (4, 15-20).”

“Damp Indoor Environments have been associated with many serious health effects, including asthma, hypersensitivity, and sinusitis. Moisture incursion leading to dampness can result from water leaks and/or by condensation due to high humidity.”

Heath Effects From Biological Contaminants: via linked EPA document:
“Some biological contaminants trigger allergic reactions, including hypersensitivity pneumonitis, allergic rhinitis, and some types of asthma. Infectious illnesses, such as influenza, measles, and chicken pox are transmitted through the air.

Molds and mildews release disease-causing toxins. Symptoms of health problems caused by biological pollutants include sneezing, watery eyes, coughing, shortness of breath, dizziness, lethargy, fever, and digestive problems.

Allergic reactions occur only after repeated exposure to a specific biological allergen. However, that reaction may occur immediately upon re-exposure or after multiple exposures over time. As a result, people who have noticed only mild allergic reactions, or no reactions at all, may suddenly find themselves very sensitive to particular allergens.

Some diseases, like humidifier fever, are associated with exposure to toxins from microorganisms that can grow in large building ventilation systems. However, these diseases can also be traced to microorganisms that grow in home heating and cooling systems and humidifiers.

Children, elderly people, and people with breathing problems, allergies, and lung diseases are particularly susceptible to disease-causing biological agents in the indoor air.”

Identification and assessment of possible IAQ problems:
“Methods used in an IAQ investigation may include identifying pollutant sources, evaluating the HVAC system performance, observing production processes and work practices, measuring contamination levels and employee exposures, providing medical testing or physical examinations, conducting employee interviews, and reviewing records of medical tests, job histories, and injuries and illnesses. The Appendices provide resources and checklists that building owners, managers, and occupants can use to investigate IAQ complaints, document walkthrough inspections..”

“To prevent IAQ problems effectively and efficiently, building managers should know and understand the history of the building (construction, uses, maintenance, etc.). If possible, owners and managers should maintain blueprints and construction documents, including information about any renovations of the building.”

Some important practices include:
“Inspect and assess the building envelope, including the roof, walls, and foundation, and promptly respond to identified problems. Routinely check the building for water leaks, seals around doors and windows, and any visible damp or moist parts of the building. Clean and dry any damp or wet building materials and furnishings within 24 to 48 hours after detection to prevent the growth of mold.

• Ensure and validate that the building is maintained under a slight positive pressure (i.e., air comes out of the building when exterior doors are opened).

• Check whether the temperature and humidity are maintained in a recommended comfort range (temperature: 68 to 78 degrees and relative humidity: 30% to 60%) (25).

• Ensure that routine maintenance of the HVAC system is being performed, including the performance of the system bringing outdoor air into the building. (1).

• Monitor carbon dioxide (CO2) levels. The carbon dioxide levels can be used as a rough indicator of the effectiveness of ventilation (5, 26), and excessive population density (e.g., overcrowding).

• Ensure that good housekeeping practices are being applied.

• Ensure that routine preventive maintenance and upkeep of buildings is being performed. A preventive maintenance program provides the care to all building systems and components that keeps them operating at peak performance according to manufacturer’s specifications, and also allows for early detection of problems
(1, 18).

• Ensure that scheduled renovations are isolated from the building’s general dilution ventilation system when occupants are in the building.


Fall 2008 ~ Federal GAO “Indoor Mold: Better Coordination of Research on Health Effects and More Consistent Guidance Would Improve Federal Efforts”

GAO ~ Indoor Mold: Ongoing and Recently Completed Federal Research Activities

2009 ~ World Health Organization (WHO) Dampness & Mould

So where is the BOTTLENECK? Why aren’t US private sector pediatricians, occupational and other physicians being made aware of what OSHA, EPA, CDC, NIOSH, GAO and WHO know of the potential for serious illnesses caused by microbes found in WDB?

ANSWER: Politics in Medicine, the Courts and US Public Health Policy Dissemination of Misinformation by the US Chamber and ACOEM.

July 2003 ~ US Chamber Institute for Legal Reform (ILR) & Manhattan Institute Center for Legal Policy (CL) “A Scientific View of the Health Effects of Mold”, which is: “Thus, the notion that ‘toxic mold’ is an insidious, secret ‘killer,’ as so many media reports and trial lawyers would claim, is ‘junk science’ unsupported by actual scientific study.”

Jan 2007 Wall Street Journal, “Court of Opinion, Amid Suits Over Mold Experts Wear Two Hats Authors of Science Papers Also Serve The Defense In Mold Litigation”

Dec 2010 ~ WorkCompCentral Group Petitions American College of Occupational and Environmental Medicine “ACOEM” for Review of Iffy Based Medicine, Position Statement on the Science of Mold. (ACOEM’s authors of their position statement also authored the US Chamber’s “Scientific View”. No response was received from ACOEM’s BOD)

Jan 2011 ~ Request for Transparency & Oversight of Federal Funds Used to Educate US Pediatricians of Children’s Illnesses Caused by Water Damaged Buildings

March 2011 ~ Physician Critique of ACOEM’s Iffy Based Medicine, Position Statement on Mold ACOEM 2011 should be retracted. It is an insult to the hard-working members of ACOEM who actually do try to practice good medicine. It is an insult to those sickened by exposure to the interior environment of WDB. It is an insult to science itself.”

About Sharon Kramer

Hi, I'm an advocate for integrity in health marketing and in the courts.
This entry was posted in Environmental Health Threats, Health - Medical - Science, Mold and Politics, Toxic Mold and tagged , , , , , , , , . Bookmark the permalink.

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