3 danger." We do not believe an emergency temporary standard for environmental tobacco smoke is justified. OSHA has a number of regulations in place that can be used to address indoor air quality. The agency has established permissible exposure limits for more than 600 air contaminants, including substances such as acetic acid, chlorine, carbon monoxide, and nitrogen dioxide, which are prominent indoor air contaminants. OSHA updated the permissible exposure limits for many of these contaminants in 1989 in order to increase worker protection. For 25 of these toxic substances, OSHA has also issued comprehensive standards that specify additional protective measures such as engineering controls, personal protective equipment, work practices, workplace monitoring, medical surveillance and training. The comprehensive standards address substances such as asbestos, benzene, formaldehyde and lead, all of which are sources of indoor air pollution. OSHA also has ventilation standards applicable to particular work situations. Ventilation regulations are important because NIOSH has found that inadequate ventilation was the primary type of problem found in more than half of all the indoor air quality investigations it has conducted in the past decade. The ventilation requirements mandate that employers use engineering controls, such as exhaust systems, when exposures exceed limits permitted by OSHA. In industrial settings where large concentrations of pollutants exceed the permissible limits, OSHA requires personal protective equipment, such as respirators, when engineering controls cannot be used. Another very significant regulation that enhances indoor air protection for employees is OSHA's Hazard Communication Standard. The standard requires that employers provide employees with information about the hazards of the chemical substances used in It also requires that training and education their workplaces. be provided to workers so that they can take precautions to minimize the hazards. The standard applies to all workplaces, including office buildings, where employees may be exposed to hazardous chemicals. Instead of being restricted to specific substances, the regulation addresses a half million or more hazardous substances used in America's workplaces. enforcement of the standard is designed to ensure that workers know of the dangers from these substances. OSHA's As we learn more about the problem of indoor air pollutants, OSHA may determine that a specific standard is necessary to address this problem. OSHA is now preparing a Federal Register Notice which will ask for additional information on indoor air quality issues such as health effects, the performance of ventilation systems, building maintenance programs in use, and the hazards of specific contaminants such as environmental tobacco smoke and radon. It will also ask whether current Federal, State and local regulations and programs are protective enough and what additional OSHA activities are needed. Enforcement OSHA conducts inspections from eighty-eight offices located. throughout the Nation. Last fall, OSHA issued a compliance directive to all field offices listing specific procedures for field 5 conducting indoor air inspections. At that time, the agency also added a new chapter on indoor air to its Technical Manual, which is the agency's technical guide for conducting inspections. The When OSHA's compliance officers arrive at the workplace to examine possible indoor air problems, they first seek information from both employers and employees concerning the extent of any illnesses or discomfort suffered in the work environment. compliance officer examines the design and operation of the heating, air conditioning, and ventilation systems. The compliance officer also looks at the kind of machinery that is operating in the workplace and the frequency of its use and maintenance. During an inspection, OSHA normally conducts monitoring for air contaminants in the workplace. OSHA'S Technical Center in Salt Lake City has advanced equipment to perform air contaminant analyses, tests, and studies. The Technical Center has also validated a number of sampling procedures that can determine employees' exposure to low concentrations of toxic materials such as those which may be found indoors. During or following the inspection, OSHA may make recommendations to the employer concerning ways to improve ventilation efficiency, remove contaminants, or otherwise minimize employee exposure. In order to ensure that OSHA's compliance officers are knowledgeable about the variety of indoor air hazards which they may find at the workplaces they inspect, OSHA's Training Institute, which instructs Federal and State inspectors, provides training and instruction on indoor air quality. The training which compliance officers receive was developed in coordination T 6 with NIOSH and EPA and covers subjects such as local building codes, health effects of indoor air pollutants, ventilation concepts for office buildings, and strategies for investigating indoor air complaints. The course is offered at the Training Institute twice a year and is open to the private sector. OSHA's Health Response Team, located in Salt Lake City, is another source of assistance on indoor air quality. The Health Response Team provides industrial hygiene expertise and support in cases of special health hazards or emergencies. The Team is equipped with specialized sampling equipment such as that used for indoor air microbiological contamination evaluations. The Team responds to requests for assistance in evaluation of indoor air quality in Federal and State buildings as well as in private sector workplaces. The Health Response Team is currently preparing a videotape on how to conduct an indoor air quality investigation; this tape will be used by OSHA's Training Institute in its indoor air instruction. Technical Assistance and Consultative Services OSHA encourages compliance with its regulations through a variety of methods in addition to the enforcement program. For instance, OSHA's field offices offer technical assistance on occupational safety and health to employers and employees. is written information available to the public at OSA's Area Offices. There OSHA's consultation service provides assistance on all aspects of occupational safety and health. The consultants will provide advice either at the employer's establishment or off 7 site. Priority for consultative visits is given to small The health impact of indoor air pollution is a problem that demands the attention of more than a single Federal agency. We are actively working with other agencies to address this problem. OSHA is a member of the Interagency Committee on Indoor Air Quality, which coordinates the efforts of the Federal Government. Through the Committee, we review research and guidance documents developed by other agencies and present for their review products which OSHA has developed. In addition, we are involved in a number of other interagency committees that are addressing specific contaminants such as asbestos, lead, and gases from carpets. Many agencies have a role in various aspects of indoor air quality including OSHA, EPA, the Department of Health and Human Services, the Department of Energy, the Consumer Product Safety Commission, and the General Services Administration. look forward to continuing our work on indoor air quality in order to ensure that Americans are working in a healthful environment. I Comments on H.R. 1066 Regarding H.R. 1066, we believe that OSHA has sufficient statutory authority to protect workers from indoor air hazards. 45-967 - 91 - 2 |