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Malaysian ICOP on Indoor Air Quality

Ir Hj Anuar Mohd. Mokhtar DOSH Malaysia

SCOPE
Introduction Indoor air quality (IAQ) issues in Malaysia Background to ICOP ICOP on IAQ Benefits of adopting ICOP

INTRODUCTION
Increased concern regarding indoor air quality
More time spent indoors-up to 90% New building more insulated Levels of certain pollutants significantly higher than outdoor
VOCs, pesticides, by products of combustion

Widespread use of synthetic materials and chemicals Toxicological data on most of them are limited

Good IAQ is not solely about comfort but also about prevention of building related diseases and diseases from environmental tobacco smoke

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WHAT IS INDOOR AIR QUALITY?

IAQ refers to The air quality within and around buildings and structures, especially as it relates to the health and comfort of building occupants

BUILDING RELATED ILLNESSES

SICK BUILDING SYNDROME

CHRONIC DISEASES

SICK BUILDING SYNDROME

A phenomenon that occur when more than 20% of the occupants of a building complain about air quality or have definite symptoms (ILO Encyclopaedia)

BUILDING RELATED ILLNESSES

Less often, but often more serious & are accompanied by very definite clinical signs & clear laboratory findings
Hypersensitivity
Hypersensitivity pneumonitis, Humidifier fever, Asthma, Rhinitis, Dermatitis

Infections
Legionnaires disease and Pontiac fever Tuberculosis (TB), Common cold

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Legionnaires Disease & Pontiac Fever

These diseases of the respiratory system They are result of an infection of legionella bacteria hence disease is described as legionellosis
Legionnaires disease is the more severe form of infection which includes pneumonia Pontiac fever is a milder illness, causing flu-like symptoms without pneumonia

CHRONIC DISEASES
Lung cancer
Radon Environmental tobacco smoke (ETS)

Mesothelioma
Asbestos

INDOOR AIR QUALITY ISSUES

Results of studies by US NIOSH in 1990 (more than 500 buildings investigated)

Inadequate ventilation
Indoor contaminant sources Outdoor contamination Microorganisms Contamination from fabrics/ building materials Unknown sources

52%
16% 10% 5% 4% 13%

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IAQ ISSUES IN MALAYSIA

Mouldy building/offices
High humidity Pipe burst/leakage Flooding

Cold offices
Low temperatures

Chemical emissions
Off-gassing from building materials

Smoking indoors
Offices Restaurants Designated areas

Split unit air-conditioners

Fresh air lacking

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BACKGROUND
Concerns for exposure to secondhand smoke led to a code of practice on indoor air quality in 2005 Compliance with the 2005 COP on Indoor air Quality is voluntary However, the Industry code of practice (ICOP) is a legal instrument provided for under the Occupational Safety & Health Act 1994 (OSHA) Under OSHA, it is the general duty of an employer and also the building owner and management to ensure the safety and without risk to health of employees and anyone at a place of work

GENERAL DUTIES UNDER OSHA

Section15:
Employers to ensure , so far as is practicable, the safety, health and welfare at work of all his employees (includes contractor and his employees)

Section 17:
Employers to ensure that he and other persons, not his employees, are not exposed to safety and health risks

Section 18
Occupier (a person who has the management or control of the place of work) of non-domestic premises to take practicable measures to ensure premises are safe and without risks to health to persons using premises or any plants or substances provided for use there

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BACKGROUND
The COP need to be reviewed
5 years elapsed Limitations of COP

Limitation of the COP

Does not apply to workplace using split air-conditioning system Only cover 5 chemical pollutants Does not include temperature, air flow and humidity Does not address bacteria or mould issues Too dependent on assessors

Malaysian ICOP on Indoor Air Quality 2010

Approved by the Minister of Human Resource on 30th August 2010 Gazetted under subsection 37(4) OSHA as P.U. (B) 29/2011 The 2005 Code of Practice on Indoor Air Quality repealed

CONTENT OF new ICOP ON IAQ 2010

Application of ICOP Dealing with complaints Investigating IAQ Problems Control of IAQ Information, instruction and training Recordkeeping Appendices

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APPLICATION OF ICOP
Any area or part of building where any chemicals hazardous to health are used for analytical, research or preservation purposes

Removal and disposal of asbestos containing materials

Applies to all buildings or any part of building or totally enclosed areas served by MVAC including aircooled split unit where persons work EXCEPT

Domestic buildings

Any area or any part of the building which is constructed, used or intended to be used for domestic or industrial purposes

Complaints Procedure
The Building Owner or Building Management shall

Establish a procedure to deal with complaint from employer and occupants related to signs and symptoms perceived to be due to IAQ

Ensure that an investigation is conducted to ascertain the cause, upon receipt of complaint.

Appendix 2 - sample of IAQ Complaint Form

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Complaint procedures shall include:

Procedures for receiving and dealing with complaints

Description of the process or processes for response to a complaint Regular reviews of complaints by the occupant Identification of individuals responsible for administering the complaint process Procedures for communicating any remedial action to the complainant; and Follow-up procedures to ensure that the remedial action recommended
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Investigation of IAQ Problem: Duty to investigate..

Renovations are made that involve significant changes to the ventilation system e.g. room without supply or return air

Occupancy in the space exceeds the recommended number of occupancy in the original design

Complaints received

Building Owner or Building Management

IAQ Complaints & Investigation Process (Appendix 3)

Receive indoor air quality complaints Communicate to building owner or building management

Conduct walkthrough inspection

Notify complainant

YES

Is there an obvious solution for the complaints ?

NO

Rectify problem or implement the recommended solution

Conduct IAQ assessment

Present Assessment Report to occupier and/or building owner Follow-up to make sure the problem does not recur Record keeping

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Walkthrough Inspection
Provides basic information on factors affect IAQ Walkthrough may involve these activitiesCollect information about the history of the building and ventilation system; collect previous record of IAQ complaints; notify the building occupants of the upcoming investigation; identify key individuals for access to relevant information as well as relevant locations within the building; and identify potential contaminants and their sources.

To facilitate the walk through inspection, a Checklist is provided in Appendix.

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Assessment of IAQ By IAQ Assessor

The assessment shall carried out during normal business activity and must consider:the sources of indoor air contaminants; an occupants exposure to ETS; an occupants exposure to air contaminants, either from indoor or outdoor sources; the prescribed activities; the adequacy of mechanical ventilation at the place of work; and the necessary actions to be taken to improve the IAQ.

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Prescribed Activities Any activity that could pose health hazard to the occupants, e.g.:
Applying or removing floor coverings including carpeting, floor tiles and other surfaces; Applying wall coverings; Painting; Cleaning carpets.

Assessment of IAQ By IAQ Assessor

The assessment shall include:Measurement of specific physical parameters listed in TABLE 1; Measurement of indoor air contaminants listed in TABLE 2; Walkthrough inspection Symptom survey Sample of symptoms survey questionnaire provided in Appendix.

The IAQ assessor shall present and submit the assessment report to the building owner or building management within 1 month upon completion of the assessment.
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Table 1: Acceptable Range for Specific Physical Parameters

Parameter
(a) Air temperature (b) Relative humidity (c) Air movement

Acceptable range
23 26 oC 40-70% 0.15 0.50 m/s

Reference MS 1525 : 2001 Code of practice on energy efficiency and renewable energy for non-residential buildings
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Table 2: List of Indoor Air Contaminants and ACCEPTABLE Limits

Indoor Air Contaminants Chemical contaminants* 1.Carbon monoxide 2.Formaldehyde 3.Ozone 4.Respirable particulates 5.Total volatile organic compounds(TVOC) Biological contaminants 1.Total bacterial counts 2.Total fungal counts Ventilation performance indicator 1.Carbon dioxide Acceptable Limits ppm 10 0.1 0.05 3 C1000** mg/m3 0.15 cfu/m3 500* 1000* -

*Limits are eight-hour time-weighted average airborne concentrations mg/m3 is milligrams per cubic meter of air at 25 Celsius and one atmosphere pressure ppm is parts of vapour or gas per million parts of contaminated air by volume cfu/m3 is colony forming units per cubic meter **C is the ceiling limit that shall not be exceeded at any time. 26

CARBON MONOXIDE
Combustion product
Automobile exhaust, smoking, unvented combustion appliances

Asphyxiant The standard is set to provide a margin of safety for people with cardiovascular disease

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FORMALDEHYDE
It is a VOC,
used in bonding/laminating agents, adhesives, paper & textile products, and in foam insulation Also used in cosmetics & toiletries as preservative

New buildings, re-carpeting, ETS Levels exceeding 1-3ppm cause mucous membrane irritation Suspected carcinogen Level set for comfortable environment

OZONE
Colourless gas Produced in ambient air during photochemical oxidation of combustion products such as nitrogen oxides and hydrocarbon Ozone concentration set at 0.05ppm to prevent symptoms such as dryness of upper respiratory tract and throat and nose irritation

RESPIRABLE PARTICULATES
Less than 10 micron in diameter Sources are ETS, aerosols from air fresheners or cleaning material Other sources
dirt from carpets or dirt carried in from outdoor Outdoor sources such as from haze

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VOCs
Human bioeffluents, personal care products, cleaning materials, paints, lacquer, varnishes, pesticides, pressed wood products, and insulation Accumulation of VOCs play a major role in SBS Some VOC such as benzene is carcinogenic Level to prevent discomfort

CARBON DIOXIDE
Product of combustion
Human respiration & ETS

It is an asphyxiant At concentrations (>30,000ppm) may cause headache, loss of judgment, dizziness, drowsiness, and rapid breathing Level set to indicate adequacy of ventilation rates or indicative of inadequate mixing.

IAQ ACCEPTABLE LIMITS vs OTHER EXPOSURE LIMITS

Outside Air* Resp. Particulate Matter Ozone Formaldehyde TVOC Carbon monoxide 0.15mg/m3 0.075ppm 9ppm Indoor Air Occupational Exposure** 3mg/m3 0.05 to 0.2ppm 0.3ppm(ceiling) 25ppm Ratio Occupational : Indoor 20x 1-4x 3x 2.5x

0.15mg/m3 0.05ppm 0.1ppm 3ppm 10ppm

*USEPA ** Malaysian Permissible Exposure Limits (USECHH 2000)

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MOULD, TEMPERATURE & HUMIDITY

Moulds are fungi that grow on dead organic matter and their presence is only visible to the unaided eye when mould colonies grow, commonly seen as a downy or furry coating growing on surfaces. Moulds reproduce through tiny spores, that are invisible to naked eye and float through outdoor and indoor air. Mould may begin growing indoors when mould spores land on surfaces that are wet, fostering the growth of mould colonies. Mould growth can lead to a variety of health issues, such as causing allergic reactions, irritations, and in some cases, toxic actions (e.g. mycotoxins). Allergic responses include hay fever-type symptoms, such as sneezing, runny nose, red eyes, and skin rash (dermatitis). The standard set for humidity and temperature is for comfort and to prevent mould growth

BACTERIA
Bacteria are microscopic organisms found in indoor environments typically come from human sources (skin and respiration) or from the outdoors. Bacteria found in the air in buildings are saprobes (grow on dead organic matter) and the primary concern is about bacteria colonies that may grow in damp areas.

Legionella Pneumophila

Duty To Control Exposure

Building owner /management shall:
maintain working environment conforming to the acceptable range as specified in Table 1.

Where assessment report indicates that IAQ is unacceptable, building owner/management shall initiate to implement any of the measures within 1 month after receiving report. For any air conditioning system including air-cooled split unit, building owner/management or employer shall ensure the provision for adequate fresh air ventilation such as:the use of Demand Control Ventilation (DCV); extractor; or by other suitable means.

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Microbial contamination
Building owner or building management shall regularly inspect:
ductwork, dehumidifiers, cooling coils, filters, internal building surfaces, and and any other MVAC system components.

Inspect every 6 month where there is reasonably likely that standing water will unintentionally accumulate and which could reasonably cause microbial growth. Where there are reasonably cause microbial growth, the building owner or building management shall promptly remove the water; and make necessary repairs to prevent further accumulation.

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Inspection & Maintenance of MVAC

Maintenance schedule for MVAC system as per manufacturer's recommendations to ensure that the equipment operate efficiently. If not specified, follow these frequencies and activities: At all time Ensure filters perform properly and do not become clogged. Regularly check cooling coils, condensate pipes & water trays for sign of sludge, algae, rust, blockage & leak.
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At least 1 every month Clean the trays to ensure that no contaminants build up.

At least every 6 months Inspect the building and its MVAC system. Clean components of air-handling units such as fans and dampers. Clean coils and condensate pipes.

Continue..
MVAC system to be checked and adjusted to ensure correct air flow, temperature and humidity. After the 1st year of operation and at least every 2 years any renovations or changes in floor layout that might affect air distribution. Building owner/management is recommended to use nonchemical water treatment for cooling tower. If biocides are used, the dosing shall carried out as per manufacturer recommendation. Records shall be kept of all maintenance.

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Control For Prescribed Activities

Building owner/management or employer to ensure that adequate work procedures and control are used during prescribed activities which may includesuse of approved personal protective equipment; sealing of the area where prescribed activities is carried out; displaying signage to warn about hazard associated with prescribed activities; safe work procedures; using portable exhaust system; or administrative control measures such as carry out prescribed activities not during working hours.
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Prevention & Control For Renovation Work

Building owner/management not to use materials containing toxic substances. Highly recommended to use low VOC emission materials. For occupied buildings undergoing partial renovation: spaces to be renovated should be effectively isolated from occupied zones; supply air should be separated so that acceptable IAQ for occupants is maintained. Any major renovation to the building where the airconditioning system has been affected (e.g. by partitioning of office space): rebalancing of the air distribution shall be required.
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Pest Control
Minimise use of pesticides in non-commercial buildings, as far as practicable. Pesticide spraying shall be carried out:
by licensed pest control operator as stipulated under Pesticides (Pest Control Operator) Rules 2004; and outside normal working hours, and preferably during the weekends.

Occupants in areas to be sprayed shall be notified in advance to avoid any unnecessary exposure.

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Pest Control
Pesticides shall be applied in targeted locations, with minimum treatment of exposed surfaces. If hydrogen cyanide is used, building owner/ management to comply with Hydrogen Cyanide (Fumigation) Act 1953 (Revised-1981) [Act 260]. Building management or anyone who organises pest control activities should have information on chemical identities and potential health hazards that are available from Safety Data Sheets (SDS)

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Housekeeping & Cleaning

Housekeeping keeps dust levels down and removes dirt which could otherwise become sources of contamination. Cleaning schedule to be arranged with reference to occupancy patterns and activity levels. Daily cleaning of surfaces and steam vacuuming of floors is advisable for areas with high traffic or which are in constant use during the day. When chemical based cleaning agents are used, SDSs on the cleaning agents should be available to the building manager and other occupants.

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Environment Tobacco Smoking (ETS)

Tobacco smoking is prohibited in many public area as stipulated under:
Control of Tobacco Product Regulations 2004 [P.U.(A)324/2004]; Control of Tobacco Product Regulations (Amendment) 2008; and Control of Tobacco Product Regulations (Amendment) 2009;

In all indoor areas which are not covered by the Tobacco Product Regulations 2004, smoking should also be prohibited as far as practicable in order to achieve good indoor air quality standard.

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Information

Ensure that all employees are informed on:

causes of poor indoor air quality and the adverse effects to health arising from it; complaints procedure; detrimental effects from ETS and its contribution to the overall indoor air quality; modification or improvement to the poor ventilation system at the work station, if any; and findings of the assessment.

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Instruction
Employer to give instructions but not limited to the followingprohibition of smoking except at designated area(s); not to tamper with MVAC system; not to store material/chemical or equipment inside AHU room or ducting; ensure fresh air intake is not blocked at any time or contaminated with undesirable and hazardous elements; and to inform the employer of any discomfort related to indoor air quality.
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Training
Employees to be trained on-

contents of this ICOP; identification of sign and symptoms associated with the illnesses commonly associated with poor IAQ; and identification of poor ventilation conditions and signs of deterioration in the air-conditioned or mechanical ventilation system.
The training programme shall be reviewed and conducted at least once in two years.
The training programme shall be documented and kept for inspection.

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Recordkeeping
All records shall be kept for not less than 5 years. Assessment report shall be kept not less than 30 years. Records to be kept include complaint records; investigation reports; assessment reports including the results of indoor air contaminant measurement; and training records.

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Qualifications, experience & training as a registered IAQ Assessor

a registered assessor or hygiene technician I under USECHH who has attended training in IAQ assessment conducted by recognised training providers and passed examination conducted by NIOSH; or a person with at least a Diploma in pure or applied sciences and has 1 year experience in occupational hygiene and has attended training in IAQ assessment conducted by recognised training providers and passed examination conducted by NIOSH; or any other person with equivalent IAQ competency as recognised by the relevant authority.
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APPENDICES
Appendix 1 GENERAL INFORMATION ON INDOOR AIR QUALITY Appendix 2 INDOOR AIR QUALITY COMPLAINT FORM Appendix 3 IAQ COMPLAINTS AND INVESTIGATION PROCESS Appendix 3-A CHECKLIST FOR WALKTHROUGH INSPECTION Appendix 3-B QUESTIONNAIRE FOR BUILDING OCCUPANTS Appendix 4 MEASUREMENT & ANALYSIS OF IAQ PARAMETERS

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BENEFITS OF COMPLIANCE WITH ICOP

Improved staff efficiency Less absenteeism Less staff turnover Willingness to work overtime? Less complaints on indoor air quality Good image of employer among employees

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