Indoor Environmental Quality – Position Statement

ASTHO believes that the current legal and regulatory framework for indoor environmental quality (IEQ) does not adequately protect or promote public health. ASTHO recognizes the complexities of addressing IEQ challenges. In light of these concerns, ASTHO supports a coordinated approach to drive the development of comprehensive and integrated policy and regulation to address IEQ issues.

I.  Within This Context ASTHO Recommends:

State and Territorial Health Agency Approaches to IEQ

• ASTHO urges greater coordination and collaboration across federal, state/territorial and local governmental agencies in addressing IEQ issues. ASTHO asserts that frequent interaction and collaborative planning are necessary to improve the understanding and management of IEQ problems and related health impacts, and to support the newly-emergent healthy places, healthy homes and healthy community design initiatives.
• ASTHO recommends that state/territorial governmental agency IEQ programs employ interdisciplinary approaches to policy development that may impact IEQ. ASTHO urges IEQ programs to utilize diverse expertise and to seek partnerships with other agencies that develop and
• implement housing codes, building codes, policies, and ordinances that will impact IEQ.
• ASTHO recommends the creation of a national web-based data repository of IEQ-related health hazards, health advisories, policies, best practices, programs and services.
• ASTHO recommends development of research programs to determine IEQ exposure guidance levels and that those research programs are adequately funded.
• ASTHO recommends that IEQ-related activities within state/territorial health agencies formulate policy and program activities based upon scientifically sound, evidence-based research and best or promising practices.

Needs Assessment Related to IEQ Capacity

ASTHO encourages the Centers for Disease Control and Prevention (CDC), in conjunction with EPA, the Department of Housing and Urban Development (HUD), and the National Institute of Environmental Health Sciences (NIEHS), to conduct a national needs assessment of IEQ capacity at the state and local level. This needs assessment should include:

• A survey of state and local health and housing departments to identify the resources currently being expended in IEQ-related investigations and enforcement activities.
• An estimate of the gap between current resources and estimated needs.
• A workforce gap analysis to identify training needs for current and future workers who will be responding to IEQ-related problems.
• A comprehensive analysis of the legal and regulatory barriers that affect the ability of state and local agencies to manage and prevent IEQ-related problems.
• An analysis of critical IEQ-related research needs to improve state and local capacity including necessary funding to conduct identified research.

Development of IEQ Policies

ASTHO recommends that organizations and entities involved in developing IEQ policies actively solicit input on the public health implications of their IEQ codes and guidelines from state and territorial health agencies. Such organizations and entities include but are not limited to: the International Code Council (ICC); the American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE); the American National Standards Institute (ANSI); EPA; HUD; the Occupational Safety Health Administration (OSHA); the Department of Education; and other related organizations such as the U.S. Green Building Council’s (USGBC) Leadership in Energy and Environmental Design program (LEED). ASTHO supports the development of model IEQ guidelines that are reasonably protective of public health and can be adopted by state and territorial health agencies. These model guidelines should:

• Be based on the best available scientific evidence to achieve public health benefits or outcomes.
• Be flexible and recognize variability in the IEQ problems of different jurisdictions based on geography, climate, infrastructure, and other factors.
• Take into account disparities in exposures and health outcomes in different social, economic, and racial groups.
• Incorporate a combination of strategies such as: (1) education and awareness; (2) policy development; (3) regulation (e.g., code, law, ordinances, etc.); (4) social marketing and; (5) technical assistance/training.

ASTHO encourages state and territorial health agencies to play a significant role in establishing initiatives that increase public awareness of the potential health risks related to indoor air pollutants and help promote appropriate practices and risk reduction actions by the public and key stakeholders.

Sufficient and Sustained Funding, Coordination and Integration of IEQ Research

ASTHO strongly supports increased federal funding to investigate the causes and potential solutions to IEQ health concerns. ASTHO urges that the Federal Interagency Committee on Indoor Air Quality (CIAQ) take the lead in coordinating and integrating the IEQ research efforts of the various agencies engaged in IEQ activities: the National Institutes of Health, including the NIEHS; CDC; EPA; the Department of Energy; and HUD. ASTHO supports the development of inter-agency research initiatives among these agencies aimed at addressing IEQ challenges, including the evaluation of climate change impacts on IEQ and impacts on human performance and productivity.

II.  Background

Despite the facts that most people spend more than 90% of their time indoors and that indoor levels of some pollutants are significantly higher than outdoor levels, there is currently no national, state, or local framework to adequately regulate or even provide advisories for indoor environmental hazards.¹ State and local governments often lack the legal and regulatory tools necessary to enforce IEQ standards, and regulatory programs are often divided across local, state and federal agencies, and remain inconsistent, partial and incomplete. The United States has made significant progress in monitoring and improving outdoor environmental quality over the past four decades, but there has been substantially less progress in improving indoor environments despite the increase in time spent indoors by all Americans.¹

Comparative risk studies performed by the U.S. Environmental Protection Agency (EPA) and their Science Advisory Board have ranked indoor air pollution among the top five environmental risks to public health in the United States.²

Indoor environmental quality (IEQ) is defined as the cumulative chemical, physical, and biological environment within an enclosed structure. It is created by a complex interaction of the external environment, the building and its contents, and the occupants of the building.³ Some examples of health outcomes (and their associated hazards) related to IEQ problems include: acute injury (carbon monoxide and other asphyxiants from combustion; safety hazards from improper design); cancer (asbestos and radon); infectious disease (Legionnaire’s disease); allergic disorders and asthma (mold and other products of damp indoor environments); non-allergic respiratory conditions (irritant-related effects due to formaldehyde); and neurologic damage (lead).⁴ Research has shown that improvements in home environmental conditions lead to decreased exposures to harmful agents, and that modifying the indoor environment can improve human health.⁵

There is no precise estimate of either the magnitude or cost of IEQ problems nationally, but over the past quarter century the proportion of health hazard evaluations conducted by the National Institute for Occupational Safety and Health (NIOSH) devoted to workplace IEQ complaints has risen from less than 1% to more than 50%.⁶ In addition, state and territorial health agencies report that responding to indoor environmental concerns now consumes substantial agency resources. Some state and territorial health agencies lack any programs to support IEQ-related investigations. It is also significant to note that the burdens of IEQ problems related to housing are not equitably distributed by race or income.⁷

Approval History:

Environmental Health Policy Committee Review and Approval on January 26, 2010

Executive Committee Review and Approval on March 12, 2010

Position Statement Expires on March 12, 2013

Related ASTHO Documents:

• ASTHO General Policy Statement

• Environmental Public Health Policy Statement

Notes

1. Wu F, Jacobs D, Mitchell C, Miller D, Karol MH. “Improving indoor environmental quality for public health: impediments and policy recommendations.” Environ Health Perspect. Jun; 115(6):953-7. Epub 2007 Jan 25.
2. U.S. Environmental Protection Agency. Office of Research and Development, and Office of Air and Radiation. EPA Doc Num 43-F-93-003, Jan 1993. Available:  http://www.epa.gov/smokefree/pubs/etsfs.html Accessed Jan 14, 2010
3. Mitchell CS, Hodgson M. Non-asthma and allergic building-related health effects. In: Report of the Surgeon General’s Workshop on Healthy Indoor Environments. Jan 12-13, 2005. Washington, DC: U.S. DHHS; pp 6-7. Available: http://www.surgeongeneral.gov/topics/indoorenv/pdf/HIEWorkshopBinder.pdf. Accessed Nov 25, 2008.
4. Mitchell CS, et al. “Current state of the science: health effects and indoor environmental quality” Environ Health Perspect. Jun;115(6):958-64. Epub 2007 Jan 25.
5. Wu F, Takaro TK. Childhood asthma and environmental interventions. Environ Health Perspect. Jun; 115(6):971-5. Epub 2007 Jan 25.
6. Carmona RH. “Charge and goals”. In: Report of the Surgeon General’s Workshop on Healthy Indoor Environments. Jan 12-13, 2005. Washington, DC: U.S. Department of Health and Human Services; p 1. Available: http://www.surgeongeneral.gov/topics/indoorenv/pdf/HIEProceedings.pdf. Accessed Nov 26, 2008.
7. Krieger J, Higgins DL. “Housing and health: time again for public health action”. Am J Public Health. 2002 May; 92(5):758-68.