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IAQ Reference Guide
Appendix C - Codes and Regulations
IAQ TfS Action Kit
Contents
Pollutant-Related Regulations
The Federal government has a long history of regulating outdoor air quality and the concentrations of airborne contaminants in industrial settings. In an industrial environment, specific chemicals released by industrial processes can be present in high concentrations. It has been possible to study the health effects of industrial exposures and establish regulations to limit those exposures.
Some states have established regulations regarding specific pollutants in schools, such as testing for radon and lead. Various States have also established anti-idling policies that establish maximum idling times for school buses and other vehicles.
Indoor air quality (IAQ) in schools, however, presents a different problem. A large variety of chemicals used in classrooms, offices, grounds maintenance, and kitchen and cleaning applications exist at levels that are almost always lower than the concentrations found in industry. The individual and combined effects of these chemicals are very difficult to study, and the people exposed may include pregnant women, children, and others who are more susceptible to health problems than the adult typically present in regulated industrial settings.
There is still much to learn about the effects of both acute (short-term) and chronic (long-term) exposure to low levels of multiple indoor air contaminants. At this time, there are few Federal regulations for airborne contaminants in non-industrial settings. The Occupational Safety and Health Administration (OSHA) is the Federal agency responsible for workplace safety and health. In the past, OSHA focused primarily on industrial worksites, but most recently has broadened its efforts to address other worksite hazards. In spring 1994, OSHA introduced a proposed rule regarding IAQ in non-industrial environments, although the proposal was withdrawn in December 2001. School employees may be able to obtain advice (in the form of training and information) from their state OSHA office on how to reduce their exposure to potential air contaminants. In states without OSHA organizations, the regional OSHA contact may be able to provide information or assistance (see Appendix L: " Resources").
Ventilation-Related Regulations
Ventilation is the other major influence on IAQ that is subject to regulation. The Federal government does not regulate ventilation in non-industrial settings. However, many state and local governments do regulate ventilation system capacity through their building codes. Building codes have been developed to promote good construction practices and prevent health and safety hazards. Professional associations, such as the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) and the National Fire Protection Association (NFPA), develop recommendations for appropriate building and equipment design and installation (e.g., ASHRAE Standard 62-2001, "Ventilation for Acceptable Indoor Air Quality"). Those recommendations acquire the force of law when adopted by state or local regulatory bodies. There is generally a time lag between the adoption of new standards by consensus organizations such as ASHRAE and the incorporation of those new standards as code requirements. Contact your local code enforcement official, your State’s Education Department, or a consulting engineer to learn about the code requirements that apply to your school.
In general, building code requirements are only enforceable during construction and renovation. When code requirements change over time (as code organizations adapt to new information and technologies), buildings are usually not required to modify their structure or operation to conform to the new codes. Indeed, many buildings do not operate in conformance with current codes, or with the codes they had to meet at the time of construction. For example, the outdoor air flows that ASHRAE’s Standard 62 recommends for classrooms were reduced from 30 cubic foot per minute (cfm)/person to 10 cfm/person in the 1930s, and reduced again to 5 cfm/person in 1973 in response to higher heating fuel costs resulting from the oil embargo. Concern about IAQ stimulated reconsideration of the standard, so that its most recent version, Standard 62-2001, calls for a minimum of 15 cfm/person in classrooms. However, many schools that reduced outdoor air flow during the energy crisis continue to operate at ventilation rates of 5 cfm/person or less. This under ventilation is contrary to current engineering recommendations, but, in most jurisdictions, it is not against the law.