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Indoor Air Quality by OHSL Alberta
- 1. Indoor Air Quality and Occupational Health and Safety Legislation in Alberta
- 2. Background • Workers desire healthy and comfortable working conditions. When these conditions are not met, job satisfaction, productivity and health may be compromised. Indoor Air Quality (IAQ) considers the indoor environment, including the makeup of the air and comfort factors such as temperature and relative humidity.
- 3. Background • Alberta’s Occupational Health and Safety (OHS) legislation requires that workplaces be safe and healthy, but does not require that workplaces be comfortable; however, there are good reasons, such as enhanced staff morale and productivity, to exceed the minimum legislated requirements.
- 4. Background When we think of IAQ issues we often just think of the chemical hazards; • CO • CO2 • Ozone • PMs • Voc’s • but other factors may be at play……..
- 5. Legislation Does the Alberta Occupational Health and Safety Code apply to Indoor Air Quality? • Is it a work site ? • Are workers involved ? • What legislative recourse do we have?
- 6. Legislation The Act; Alberta’s OHS Act requires employers to ensure the health and safety of workers at the work site. The OHS Regulation and Code under this Act have been established to define standards for protection from specific hazards. Obligations of employers, workers, etc. 2(1)
- 7. Legislation Part 2 Hazard Assessment, Elimination and Control • Are IAQ issues considered a workplace hazard? • If an existing or potential hazard to workers is identified during a hazard assessment, an employer must take measures in accordance with this section. • What action?
- 8. Legislation Part 4 16(1) Chemical Hazards, Biological Hazards and Harmful Substances • An employer must ensure that a worker’s exposure to any substance listed in Schedule 1, Table 2 is kept as low as reasonably achievable. • What is Schedule 1 Table 2 ?
- 9. Legislation
- 10. Legislation What are OEL’s? • Based on the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLV’s)
- 11. Legislation Oel’s continued….. • Reviewed by a committee • Based on existing peer reviewed literature, from toxicology, epidemiology, occupational medicine, and industrial hygiene. • Level of exposure a typical worker can be exposed to without developing adverse health effects. • Not fine lines between safe and dangerous exposures • Adopted as the legal limits for exposure • Based on 8 hour work day for 40 years
- 12. Legislation Scenario • Alberta OEL for CO=25 ppm – Ok for children? – Individuals with pre-existing respiratory issues? – Other factors? • This is the legal limit for office environments/work sites. • Best practice vs legal minimum. – 1/10th of the OEL typically with CO we concede 5 ppm as it is pervasive. • http://capitalairshed.ca/edmonton-centre
- 13. Legislation What are IAQ parameters for indoor air quality? • Regulations • Standards • Guidelines We do not mandate in law what is and what is not acceptable for substances other than the limits required by the OEL’s We do make recommendations; • 1/10th of the OEL • Other substance specific guidelines
- 14. Legislation
- 15. Legislation
- 16. Legislation What if there is no OEL? Part 4 16(3) If no occupational exposure limit is established for a harmful substance present at a work site, an employer must ensure that a worker’s exposure to that substance is kept as low as reasonably achievable. • What is as low as reasonably achievable ? • Do most IAQ chemicals of concern have OELs?
- 17. Legislation What is as low as reasonably practicable ? • At first glance “reasonably practicable” looks like a pretty subjective way of determining someone’s guilt or innocence. However, “reasonably practicable” is a legally defined term that is assessed using the “reasonable person test”.
- 18. Legislation • What would a dozen of your peers consider reasonable in a similar set of circumstances? • Your peers would likely review what you did and compare it against what they do in their own operations. Some of them might do more, others less. • The result would be a balanced and wise judgment that could be defended to others.
- 19. Legislation Part 4 • Potential worker exposure • 21(1) If a worker may be exposed to a harmful substance at a work site, an employer must identify the health hazards associated with the exposure and assess the worker’s exposure. • Define harmful substance………………
- 20. Legislation Other parts; Part 29, WHMIS; • Training and documentation for controlled products, cleaners, disinfectants. • improperly stored controlled products? Part 35, Biological Hazards; • ALARP exposure, policies and procedures
- 21. Best Practice Indoor Air Quality Tool Kit • The goal of the Tool Kit is to help you understand typical indoor air quality (IAQ) issues, and to suggest reasonable solutions to common problems.
- 22. Scenario • A yoga studio has recently opened up in an industrial multi-unit complex with a host of other tenants including an auto body shop. • The employees are complaining about the smell of paint, and report cold like symptoms associated with the onset of the odour.
- 23. Scenario What do you think can be done? • Inspect the auto body shop and ensure they are in compliance with schedule 1. • Inspect the yoga studio and ensure there are no confounders. • Attempt to identify the source of entrainment, (not our mandate). • Assess the workers? (not physicians).
- 24. Scenario Where things get confusing; • The auto body shop is in compliance, workers are wearing respiratory protective equipment when required and the paint booth is compliant with the code. They are not exposed to any chemicals above the OEL’s. • The workers at the yoga studio continue to complain of health effects associated with the odour. • The responsibility for ensuring the health and safety of the workers falls on the employer, in this case the yoga studio.
- 25. Scenario The great conundrum, • How can the yoga studio as the employer minimize their workers exposure when they are not the source of the hazard? • What tools are available from a compliance perspective? These cases can spiral into a dark place!!
- 26. Moral • When options are limited and the health effects are real the situation can become emotional. • The best medicine is prevention, – Address worker concerns surrounding IAQ issues earlier instead of later. – Even is exposures are below the OEL’s there may be resulting health effects. – The OEL’s are only one tool for addressing chemical hazards • Hazard assessment • ALARA – Explore your tools for rectifying the situation!!
- 27. Resources Indoor Air Quality (IAQ) • http://work.alberta.ca/documents/WHS- PUB_GH014.pdf Indoor Air Quality Tool Kit • https://work.alberta.ca/documents/WHS- PUB_gh015.pdf
Editor's Notes
- Feelings of discomfort and illness may be related to a number of issues in the total indoor environment. Other common causes may include: Noise Thermal Comfort (Temperature) Humidity / moisture Lighting We will focus on the chemical approach.
- “work site” means a location where a worker is, or is likely to be, engaged in any occupation and includes any vehicle or mobile equipment used by a worker in an occupation. There are some sections of the code that may be applied to IAQ issues. Talk about the various employers on a typical office building site
- Every employer shall ensure, as far as it is reasonably practicable for the employer to do so, (a) the health and safety of (i) workers engaged in the work of that employer, and (ii) those workers not engaged in the work of that employer but present at the work site at which that work is being carried out
- It all depends ……..Hazard is defined as; “A situation, condition, or thing that may be dangerous to the health or safety of workers.” Action; (a) eliminate the hazards, or (b) if elimination is not reasonably practicable, control the hazard.
- Which IAQ contaminants are addressed in Schedule 1 table 2? CO CO2 VOC, organic compounds that have boiling points roughly in the range of 50 to 250 °C (122 to 482 °F).--BTEX (benzene, toluene, ethylbenzene, xylene), hexane, acetone, ethyl alcohol, formaldehyde, isopropyl alcohol, methacrylates
- Epidemiology is the science that studies the patterns, causes, and effects of health and disease conditions in defined populations. It is the cornerstone of public health, and shapes policy decisions and evidence-based practice by identifying risk factors for disease and targets for preventive healthcare. We take them and they are reviewed by a working group and are either included or excluded in table 2 depending on a number of factors the group is mandated to consider; are their analytical methods capable of assessing worker exposure would employers be able to meet the requirements if they were adopted what are other jurisdictions doing in regards to the substance
- Susceptibility to the substance, age, gender, genetic factors, lifestyle factors, medications, sensitization…… Can you foresee any issues with 5ppm?
- Regulations cite values that must be complied with under the law. In Alberta, the regulatory limits are called occupational exposure limits (OELs). OELs are established for health-based reasons. Standards are set by special organizations with expertise but are not legally binding unless cited within a regulation. The IAQ values cited in standards are useful as a guide for workplaces where IAQ and comfort is a concern. Guidelines are recommended approaches or values that are useful but not mandatory
- How efficient are building HVAC systems at filtering out gas? Not very, gas cannot be filtered it can be scrubbed or reacted.
- How achievable is 0? 100ppb=0.1 ppm These concentrations were measured by the Measurements Of Pollution In The Troposphere (MOPITT) instrument on NASA's Terra satellite. The image shows the average amounts and geographic sources of CO from April, May and June for the years 2000 through 2004. Blue areas have little or no atmospheric CO, while progressively higher levels are show in green, yellow, orange, and red.
- Understanding of the term reasonably achievable comes from the Canadian Nuclear Safety Commission Regulatory Guide (2004), for “Keeping Radiation Exposures and Doses as Low as Reasonably Achievable (ALARA)”. Though the term reasonably achievable has not been given definite meaning by the Canadian Court system, it is generally accepted in industry and by regulators to encompass the same considerations as the concept of “reasonably practicable” Most do with the exception of mould and other biological hazards; however, there are between 7,700 and 85,000 chemicals produced today we address 793 in table 2.
- CO2 Oel=5000 ppm CO2 Outdoor 300-400 Complaints usually begin when carbon dioxide concentrations reach about 800 ppm and become more common when carbon dioxide exceeds 1000 ppm
- Other employer responsibilities? 21(2) The employer must ensure that a worker who may be exposed to a harmful substance at a work site (a) is informed of the health hazards associated with exposure to that substance, (b) is informed of measurements made of airborne concentrations of harmful substances at the work site, and (c) is trained in procedures developed by the employer to minimize the worker’s exposure to harmful substances, and understands the procedures. “harmful substance” means a substance that, because of its properties, application or presence, creates or could create a danger, including a chemical or biological hazard, to the health and safety of a worker exposed to it;
- Are the vapours from the booth once exhausted becoming entrained in the air of the yoga studio?
- The yoga studio must engineer out the hazard, additional ventilation? All yoga instructors must wear ½ masks with P-100 & OV cartridges?