Indoor Air Quality Regulations Stalled
by Ian Johnson

UPdate Fall 1999
Indoor Air Quality Regulation as a Guideline, 1999

     I have been frustrated by serving on a joint labour-management working group which has been trying for three years to develop and finalize a first-ever Indoor Air Quality regulation under the Nova Scotia Occupational Health and Safety Act.  The whole process of reviewing draft regulations has been stalled with a crisis over appointments of labour representatives to the Nova Scotia Occupational Health and Safety Advisory Council.

     As far as I can tell, our draft regulation has been on hold with the Advisory Council since last September, and may be for some time to come.  Should we dispair?  It is tempting, but I did recently receive some good news about the draft regulation.   I was advised informally by a staff person with the Department of Labour that it is being used as a guideline with employers even though the regulation (or a revised version of it) is not yet in force.

     While by no means a final solution, this gives me some hope that maybe our efforts were not totally in vain.  To me, this suggests that anyone could try to use the draft regulation as a kind of checklist of what should be considered by any employer, or any owner or operator of a public facility, or what we called in the draft, a "non-industrial workplace" in terms of indoor air quality.

     What could this mean?  To me, a list of possible issues or questions could be used or presented  at any time, drawing from the draft regulation, such as the following:
1)  To what extent is the employer, owner or operator aware of and referring to the ASHRAE 62-1989 standard of ensuring an adequate supply of ventillation air?
2)  To what extent are they aware and referring to ASHRAE 55-1992 standard for thermal conditions?
3)  To what extent are design intent documents, and any functional performance test, prepared and made available?
4)  How accessible are return air ducts and other components of the Heating, Ventilation and Air Conditioning (HVAC) Systems?
5)  How far apart is combustion/heating equipment from air handling systems?
6)  To what extent are there controls over building functions such as an enclosed parking garage, food preparation area or a print shop, to control the spread of airborne hazardous substances to other areas of the workplace?
7)  What prior assessment is done, and by whom, of the potential for airborne hazardous substances from new floor coverings and building materials?
8)  Is there a HVAC owner's manual in existence or that can be developed?
9)  What assessment is done of the potential impacts on air quality of upgrading or renovations of existing buildings?
10)  What written procedures exist for the maintenance of the HVAC system, storage and proper usage of cleaning, products, solvents, paint and related products, and to control microbial contamination?
11)  What written policy exists on the use of scented products and how well is it enforced and reviewed on a regular basis?
12)  What controls are in place to prohibit smoking in the workplace, restrict smoking to designated smoking areas or to provide for equivalent protection?
13)  What complaints procedure exists for indoor air quality problems and how are investigations to be conducted of any potential problems?
14)  What policies are in place for employee and user communication and training?

     Will these various questions guarantee acceptable indoor air quality?  Not necessarily, but if they (and probably, others) became part of our way of thinking about indoor air quality, we might begin to make some real progress.

     Public pressure will probably still be needed to ensure the new regulation is finally approved as well as fully implemented and enforced.  With the new provincial government this might be a good time for people to push for change.  But maybe we can all do what we can in the meantime to get the spirit, if not the content, of the draft regulation to be put in place.

Ian Johnson is a labour representative with the Nova Scotia Working Group on 
Indoor Air Quality.