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DRAFT February 5, 1993 INDOOR ENVIRONrSENTAL QUALITY IN NON-INDUSTRIAL WORK ENVIRONM:'P1TS Authority and 8ignatitre This document was prepared under the direction of . Pursuant to sections 6(b) and 8(c): and 8(g)(2)~ of the Act, OSFiAhereby amends 29 CFR part 1910 by adding a new S 1910. as set forth below. List of 8ubjects in 29 C?R Part 1930 Sndoor Environmental Quality, Occupational Safety and Health. is hereby amended as follo-as: pA1RT 1. The authority citation for is amended by adding the following citation at the end. (Cit-' ation which precedes asterisk indicates .) i+tldorliY 2. . 5 1910. Indoor Enviroamental Quality. [a) ScoFe =and anoLication. (1) This sectiorn shall apply to all employers and gmployees under oSry:A jurisdiction. :'his standar3 applies to all building owners and employers with non- industrial work environments. This includes public and private buildings, schools, healthcare facilities, offices and commercial establishsents. The scope of this standard includes non- 'industrial vork environments that are part of industrial worksites (i.e., an office, cafeteria, or break room located at a manufacturing facility). [Adopted in part from Washington State FAQ draft]. DRAFT: DO NOT CITE OR QUOTE i 7

DRAFT sbl Def_initions -- February 5, 1993 Merican Society of Hea ~~j'r g. Retriaeratina and Air- ccnditioninc Envineers iASH'RAE) means the corisensus standard of the society which is a professional organization composed of national and international members, associated societies, and public views. The standard concerning the ventilation for acceptable indoor air quality is ASIRAE 62-1989 and the standard concerning environmental conditions for human occupancy is A*1SIjASHRAE 55-1981. AuthorizedPersae means any person authorized by the building owner and required by work duties to be present in a non-industrial work environment. ga~ means the employer creating a smokefree work environment by banning all indoor smoking of tobacco products. guildina otmer means the person(s) who has legal rights and obligations for any public or private building. The building owner may delegate responsibility•for building operation and maintenance activities, in writing, to an agent (e.g., property manager, facility manager), lease holder, or other person(s) who have control of the worksite. Desia ated smflkina azea means an area separated from common work and congregation areas that has dedicated exhaust ventilation. High-efficiency particulate air (AEPA!. filter means a filter capable of trapping and retaining at least 99.97 percent of 0.3 DRAFT: DO NOT CITE OR QUOTE N 2 C W . '".~

DgAYT February 5, 1993 micrometer diameter mono-disperse particles. RyAE system means the collective components of t.he heating, ventilation and air-conditioning system. Mainstream smoke means the smoke breathed in by a person actively smoking a tobacco product. Non•industria vork environment means an indoor or enclosed occupied space such as, but not limited to, offices, educational facilities, commercial establishments, and heaithcare facilities. It does not include areas such as manufacturing and product'.on facilities, residences, vehicles, building construction worY.sites (where the building is not occupied by employees covered under this standard), agricultural operations, and offices where employees are directly involved in production or manufacturing processes (e.g., small quality control office where employees move frequently in and out to production areas). oif ice areas, cafeterias, and break rooms located at a manufacturinq or production facility where employees are nct directly involved in production or manufacturing processes are included in the scope of this standard. gassive tobacco smoke means the product of tobacco combustion, including sidestrean smoke, exhaled mainstream smoke, vapors that escape through the cigarette or eiqar wrapping, and exhaled mainstream smoke. Zt is commonly referred to as environmental tobacco smoke, secondary smoks, or.involuntary smoke. ~ DRAFT: DO NOT CITE OR QUOTE ~ 3 C4

DRAFI, Februaz'X 5, 1993 si'de tream smoke means the smoke emitted from the burning end of the tobacco product. DRAFT: DO NOT CITE OR QUOTE (0

DRAFT February 5, 1993 (Preliminary gross provisions for IAQ standard: ] (c). System Do umentation. The building owner shall provide the following HVAC system information upon request to the employer or the (1). The latest HVAC design, operation and maintenance documentation if available, including dates of building construction, HVAe system installation, commissioning, or most recent HVAC modification. (2). A description of the HVAC system including type of HVAC system (VAV, dual duct, multi-zone, heat pump, etc...), major components, current total air capacity (in C:M), current and minimum outside air supply rates to occupied areas (in CFM), design occupant density loads, air filter system, filter efficiency, temperature and humidity design criteria, operation and m3intenance procedure, and any mechanical systems desiqned for local exhaust. [d1 Svstetn Oceration. (1) The HVAC system shall be maintaiaed and operated to provide at +east the outdoor air ventilation rate (based on actual occupancy) required by the applicable building code, mechanical code, or ventilation and indoor air quality code in effect at the time the permit covering the building AvAC system was issued. (2) Heating systems shall be operated to maintain the following conditions: DRAFT: DO NOT CITE OR QUOTE O 5 0 W 0

DRAFT February 5, 1993 i) Temperatures no lower than 68°F and tio higher than 74°F in winter. ii) Where mechanical cooling is provide, these systems shall be oped ated to maintain temperatures no higher than 8o°F and no lower than 73°F in summer. iii) Relative humidity shall be maintained below so8 in buildings with mechanical cooling systems to prevent growth of biological contamihants. • (3) The KVAC system must be operated continuously during all scheduled work shifts (except during emergency reprirs) and during scheduled naintenance and calibration. (4) HVAC operation specifications and detailed maintenance guidance shall be provide to the HVAC operation and maintenance personnel or contractor by the building os,rner. IIp-to-date HvAC system operation procedures shall be posted cn or near the equipment, or in a procedural manual/central record located at the facility. ' (5)~ Buildings without AvAC systems shall maintain proper operation of operable exterior openirg areas (if allowed.ir. lieu of mechanical ventilation) required by the applicable building code in effect at the time the building permit was issued. (6) Zmployers shall maintain physical equipment-rooms in clean condition, especially if rooms are part of the air exchange plenum of the HV'A:C system. i) No storage of chemicals or other aqents that could, if DRAFT: Do NOT CITE OR QUOTE © 6 . N tt

DRAPT February 5, _993 spilled, be taken up by the air system and transported to the rest of the building. ii) Asbestos, if friable, should be encapsulated so as not to be taken up by the air stream and-distributed to the of f ices down stream. (7) Carbon dioxide (CO=) levels i+ill be kept below 6S0 ppm (e.g., used as an indicator of adequate ventilation). (8) When the supply of air is reduccd during times the space is occupied (e.g., in variable air volume systens), provision shall be made to maintain acceptable indoor air quality throughout the occupied zone through: Source reduction, ii) Maintenance of CO2 levels at or below 6SO ppm, and iii) Expeditious use of maintenance and housekeeping chemicals. ' (9) i) Fuel-burning appliances, including fireplaces located indoors, shall be provided with suyficient air for combustion and adequate removal of combustion products. ii) when infiltration supplies all or part of the . combustion air, the supply rate of air shall be demonstrable. iii) The operatiors of clothes dryers and exhaust fans may require introduction of additional makeup air to avoid interference with fuel-burning appliances. iv) Combustion system, kitchen, bathroom, and clothes dryer DRA!'T: DO NOT CITE OR QUOTE 7

DRAFT February 5, 1993 vents shall not be exhausted into attics, crawlspaces, or basements. (10) To remove particulate contaminants, air filters or dust collectors shall be used. i) Dust collec~tors, not air filters, should be used where the dust loading equals or exceeds 10 mg/ms (4 qrains/l000 ft=) . ii) Air filters and dust collectors shall be selected for the particle size and loading encountered. iii) When utilized, these filters must be maintained acccrdinq to manufacturer's specifications. (1].) Relative humidity in habitable spaces preferably should be maintained between 30% and 60% relative humidity to minimize growth of allergenic or pathogenic organisms. (12) Air-handling unit conder.sata pans shall be maintained for self-drainage to preclude the buildup of microbial slime. 'i) Periodic in-situ cleaning of cooling coils and condensate pans shall be conducted. ii): Air-handlinq and fan coil units shall be easily accessible for inspection and preventive mainter.ance. (sh ?SR~'~ ANCE. a (1) The building owner shall identify a person(s) (e.g., individual, contractor, company, aqency, or department) to be responsible for the operation and maintenance of.the AVAC system. The person(s) identified for these tasks shall be knowledgeable DRAFT: DO NOT CITE OR QUOTE . ~ N W ~ N . ~ 8

DRAFT February 5, 1993 in the principles of HvAC system operation and maintenance, HVAC testing procedures, the requirements of this standard, and the specific xVAC system service the building or office. [nonmandatory appendix outlining levels of knowledqe required, - courses available.] (2) The building owner shall cause (ensure that) the HVAC system components (are) to be inspected, adjnsted, cleaned, calibrated, or replaced as ipecified in the guidance required in section d4. These components include, but are not limited to, air filters and f ilter seals, drip pans and drainage piping, heatin,q and cooling coils, supply/exhaust vents and louvers, dampers and damper actuators, fan motor belts, humidifiers, air cleaners, thermostats, control devices, and scnsors. i) In addition, the employer shall cause (ensure that) adequate ventilation system inspection and subsequent maintenance shall include system balancing once a year and semiannual RvAC inspection and cleaning. (3) The building owner shall ensure that inspections and maintenance of the HVAC system are performed by the designated person(s) as specified in sections ei and e2. i) The building owner shall ensure that maintenance system inspections and repairs are documentsd in a log and retained for at least three •years. ii) The inspection and maintenance log shall include the specific actions taken, the name and affiliation of the DRAFT: DO NOT CITF OR QUOTE 9 9

DRAFT February 5, 1993 individual performing the work, and the date of the inspection or maintenance activity. iii) The inspection and maintenance log shall be available on request to -the employer, employee representative, and the (4) Personal Protective Equipment required to safely perform maintenance procedures [Construction Industry 1926; Subpart E--Personal Protective and Life Saving Equipment]: i) Head Protection (1926.100 Read Protection) Employees working in areas where there is a possible danger of head injury from impact, or from falling or flying objects, or from electrical shock and burns, shall be protected by protective helmets. (a) Helmets for the protection of employees against impact and penetration of falling and flying objects shall meet the specifications contained in American Nation4l Standards Instituto, Z89.1-1969, Safety Requir aments for Industrial Health Protection. (b) Helmets for the head protection of employees exposed to high voltage electrical shock and burns ; shall meet the specifications contained in American Itational Standards Institute, Z89.2-1971. ii) Hearing Protection. Wherever it is not feasible to reduce the noise levels or duration of exposures to those specified in Table D-2, Permissible Noise Exposures, i~S O DRA,FT : DO NOT CITE OR QUOTE 2V' W 10 9

DRAFT February 5,.199] 1926.52, ear protective devices shall be provided and used. (a) Ear protective devices inserted in the ear shall be fitted or determined individaally by competent persons. (b) Plain cotton is not an acceptable device. iii) Eye and Face Protection: General: Employees shall be provided with eye and face protection equipment when machines or operations present- potential eye or face injury from physical, chemical, or radidtion agents. (a) Eye and face protection equipment required by this Part shall meet the requirements specified in American National Standards Institute, Z87.1-1968, Practice for Occupational and Educational Eye and Face Protection. (b) Employees whose vision requires the use of corrective lenses in spectacles when required by this regulation to wear eye protection, shall be protected by goggles or spectacles of one of the following types: (1) Specttcles whose protective lenses provide optical correction; (2) Goggles that can be worn over corrective spectacles without disturbing the adjustment of the spectacles; , (3) Goggles that incorporate corrective lenses mounted behind the protective lenses. (c) Face and eye protection equipment shall be kept DRAYT: DO NOT CITE oR @L1oTE 11

DRAF'T February clean and in good repair. The use of this type 1993 equipment with structural or optical defects shall be prohibited. iv) Respiratory Protection: General: In normal maintenance activity, appropriate respiratory protective devices shall be provided by the employer and shall be used. (a) Respiratory protective devices shall be approved by the Centers for Disease Control or acceptable to the U.S. Department of Labor for the specific contaminantls) to which the employee may be exposed. (b) The nature and extent of the hazard, work re4v.irements, and conditions, as well as the limitations*and characteristics of the available respirators, shall also be factors considered in taking the proper selection. (c) The group of respirators required are one of the folloWing: O ~ •(1): Dust mist, W ~ (2) Dust-mist fume, ~ (3) Air-purifyinq, half-mask or mouthpiece N N respirator with chemical cartridge filter. (d) protective equipment shall be instructed in the• and appropriateJ Selection, issuance, use and care of respirators. (1) Ebployees required to use respiratory DRAFT: DO NOT CITE OR QUOTE 12

DRAFT February 5, 1993 use and limitations of such equipment, with special emphasis on the importance of proper fit. (2) Respiratory protective equipment shall be inspected regularly and maintained in good condition. chemical cartridges shall be replaced as necessary so as to provide complete protection. Mechanical filters shall be cleaned or replaced as necessary so as to avoid undue resistance to breathing. (3) Respiratory protective equipment which has been previously used shall be cleaned and 3isintected before it is issued by the employer to another employee. (v) occupational foot protection. Safety-toe footwear for employees shall meet the requirements and specifications in American National Standard for Ments Safety-Toe Footwear, 241.1-1967 (1910.136). (5) The employer (lessee) shall be notified at time of lease what the design occupancy level is for the space being leased. : i) The employer (lessee) shall notify the building owner to have the RYAC system evaluated when design occupancy levels are exceeded. ii) Alterations of the HVAG system (e.g., increase of outdoor air supply, exhaust air, change of air distribution DRAFT: DO NOT CITE OR QQOTE V 13 k V

DRArT February 5, 1993 patterns, rebalancing, or addition of local exhaust systems) shall be made to meet the minimum requirements specif ied in sections dl and d2. (6) ventilatinq ducts and plenums shall be maintained to minimize the opportuhity for growth and dissemination of microorganisms through the ventilation system. ffl CONTROLS FCR SPECIFIC A R CONTAMIN7ANT SOURCES. (1) Smoking. smokinq'shall either be prohibited or permitted only in designated smoking break roosns. i) Designated smoking rooms shall be prohibited in common areas such as rest rooms, wash rooms, hallways, and stairways and cafeterias or snack rooms; as vell as in private offices. ii) Rooms designated as smoking areas shall have a ventilation system exhausted directly outside, to prevent smoke-contaminated air from being recirculated through the work envir.onment. iii) Designated smoking rooms shall be clearly posted and operated at a negative pressure compared to surrounding spaces including ceiling plenums and/'or cavities. iv) All the air•trom the dedicated smokirq area shall be exhausted directly to the outside. (2) Other indoor air contaminants. i) Air contaminants from specitic outdoor sources such as cooling towers, sanitary vents, vehicular exhaust from DRAFTs DO NOT CITE OR QUOTE 14

DRAFT February 5, 1993 parking garages, loading docks, and street traffic vehicle or odors from trash storage shall, insofar as is feasible, be prevented from entering the building through air intakes, entryways, or other openings. ii) Indoor levels of combustion products (especially in areas of high combustion product production, such as parking garages) not exceed National Primary Ambient-Air Quality Standards for Outdoor Air? (3) HvAC systems shall incorporate a minimum air filtration efficiency of 30% (by the ASHRAE atmospheric dust spot test, ASHRAE 52-76) if the system capacity allovs it. (4) The employer shall ensure that the operation and maintenance of equipment and processes that have the potential to produce indoor air pollutants are b~inq operated and maintained according to manufacturers recommendations. (5) Reduction of factors that can lead to Bioaerosoi Generation. i) The building owner and employer shall control biological contamination in the building by repairing known water leaks as soon as is feasible. ii) The building owner and employer shall control bioloqical contamination in the building by drying, replacing, removing, or cleaning porous materials (e.g. carpet, upholstery, ceiling tiles, etc.)•that have become wet within two vorking days-. DRAFT: 'DO NOT CITr OR QUOTE 0 15 i

DRAFT February 5, 1993 In addition, visible moss, mold, or algae shall be prevented from growing in ductwork, humidifiers, other HVAC system components, or on building surfaces within conditioned spaces. (6) Use of cleaning and maintenance chemicals, pesticides, and other hazardous chemicals in the workplace: i) Use and application of pesticides shall be used according to manufacturers' recommendations. ii) Persons working in areas to be treated shall be informed of the type of chemicals intended to be applied within 48 hours of application. (7) Contaminants from stationary local sources within the space shall be controlled by collection and removal as close to the source as practicable. (See "Industrial ventilation--2ianual of Recommended Practice".) Sgl ENVIRONMENTAL OUALSTY II1 RENOYATED BUILDINGS AND ItEXODELED OFFICES ._ (1) The buildinq owner and employer shall ensure that procedures, engineering controls and other appropriate controls are utilized to prevent degradation of indoor environmental .quality for building occupants during remodeling, reroofing, painting and similar activities. (2) Modification of HvAC system. iy The building owner or employer shall ensure that the HVAC system is evaluated as. an integral part of remodeling DRAFT: DO NOT CITE OR QIIOTE

DRAFT February 5, 1993 activities involving changes to the HVAC system or changes affecting air distribution from the RoAC systent (e.g., new Walls) . ii) Alterations of the H'VAC system (e.g., increase out outdoor air supply, exhaust air, change of air distribution patterns, rebalancing, or addition of local exhaust systems)~ shall be made to meet the minimum requirements specified in section dl and d2. (3) Work plan development. i) Before remodeling or similar activities are begun, the contractor or individual(s) performing the work shall meet with the.building owner, or the employer representative and shall agree to a vork plan designed to prevent degradation of indoor environmental quality durinq and after the work. ii) The work plan shall consider all of the follovinq where applicable: 1) Requirements of this standard. 2): Curtailment, and/or supplemental, or auxiliary workplace ventilation as necessary to.control contaminants, odors, Qte...during remodeling and to control residual contaminants, odors, etc...after remodeling. 3) Isolation of Trork areas and appropriate pressure containment. 4) Fume, dust, and odor suppression and/or auxiliary DRAF'T : DO NOT CITE OR QUOTE f ~ 17 N W ;2 ~ N Is 0

DRAFT February 5, 1993 air filtration/cleaning. 5) Preventing contaminant entry into KVAC system, including outside air intakes, return/recirculation air streams or plenums. (4) Prior notification of employees. i) The building owner or employer shall notify employees at least 2.4 hours in advance, when feasible, of work to be performed on the building (in their workarea]. ii) Notification shall also include anticipated adverse impacts on indoor air quality or workplace conditions. (h) Eanlovee infoz,~nation and traininqi The employer shall provide maintenance employees with information and training to ensure that they are aware of this standard. (1) Training of maintenance workers in AvAC system operation and maintenance. i) The availability and training in the use of personal protective'equipment (PPE) needed in operating and maintaining HVAC systems (e.g., cleaning out air handlers and ducts that are seriously contaminated aith mold and other potentially dangerous substances), as vell as in regular maintenance of the building (e.g., painting, application of pesticides, ete.). ii) During building cleaning and maintenance maintain adequate ventilation to exhaust fvmes. iii) Train maintenance personnel in the use and disposal of DRAFT: DO NOT CITE OR QUOTE O' 18 N Cj ~ ~ N . W

DRAFT February 5, 1993 chemicals and other agents used to maintain the interior and exterior of the building (e.g., paints, floor stripping chemicals, carpet cleaning, regular cleaning--vacuuming causes an increase in particulates). (2) Employees_shall be informed of: (i) The contents of this standard and its appendices which shall be made available to employees; (ii) The location and'availability of the system documentation '(section c) and system operation (section d), (iii) Signs and symptoms associated with poor indoor environmental quality; (iv) The location and availability of known re=erence- ' material on the health hazards and remediation for exposure; and (v) The disciplinary actions taken by the company in situations of noncompliance. (3) Employee training shall include: (i) Methods and observations that may be used to detect the presence of poor indoor air quality; (ii) The measures employees can take to protect themselves' from this hazard, including speaific procedures the employer has implemented to protect employeei from poor indoor air qua2.ity, such as appropriate work practices, designation of smoking areas, etc.; and (iii) The employee shall be trained on the applicable DRAFT: DO'NOT CITE OR QUOTE ry 19 . ~. N Ca ~ ~ ~ . ~

DRAFT February 5, 1993 details of the employer's indoor environmental program. (i) Area Desi ~~q,~ati_on. (1) With respect to siqr:s and dEsiqnated smoking areas: . (i) Employers shall provide and place signs in appropriate locations identifying designated smoking areas. (ii) Employers shall ensure that signs are clearly legible. (i) Recordkeepina_._ (1) Requirements under this provision. i) The 'employer•shall establish, maintain, and make ~. . ~•. , available to all employees an accurate record of operation and maintenance schedules, as well as any investigations pertaining to poor indoor environmental quality. ii) The inspection and maintenance record or log shall include the specific actions taken, the name and affiliation of the individual performing the work, and the date of the inspection or maintenance activity. iii) The inspection and maintenance log shall be available on request to the employer, employee representative, and the (2) The employer shall assure that such records are kept, transferred, and made available in accordance with 29 CFR 1910.20. Ski Dates--(i1 Effective date. This section shall become effective LTaruary 1. 199?. 2. Start-uD*dates. (i) Employers shall have developed and implemented an 20 NDR#FT: DO NOT CITE OR QVOTE N

DRAFT February 5, 1993 Indoor Environmental Quality Policy no later than July 1, 199?. Provisions of such a policy shall include one of the following a) establishment of separately ventilated designated smoking areas or b) the banning of -smoking in all indoor work areas. Em) ADAendices_ The information contained in the appendices is not intended, by itself, to create any additional obligations not otherwise imposed or to detract- from any existing obligation. Appendiz A to S 1s1o~. ---Carbon Dioxide xeasurement Protocol (Non-Kandatory) • Carbon dioxide measurements are surrogate measurements for outdoor air ventilation rates in buildings. Elevated carbon dioxide levels, a byproduct of huznan respiration, are indicative of an inadequate supply of fresh outdoor air. Carbon dioxide concentrations below 8o0 ppm in the occupant's breathing zone generally indichte that the ventilation is adequate. However, in some cases, indoor air problems could still occur in buildings where measured carbon dioxide concentrations are below 800 ppm. ,,• . Examples would include situations where a strong source of air contaminant is present. Use colorometric detector tubes or a calibrated direct-reading instrnffient according to manufacturer's instructions for operation DRAFT: DO NOT CITE OR QUOTE rJ 21 ~

DRAFT February 5, 1993 and calibration. If detector tubes are used to obtain carbon dioxide measurements, at least two measurements at each location should be performed and their results av4raged to reduce the uncertainty associated With this measurement technique. Measure carbon dioxide late in the morning before people go to lung (e.g., 11 am.) and late in the afternoon before people leave for home (e.g., 3:30 g.m.). At these times carbon dioxide levels should generally be closest to the equilibrium value and best indicate outdoor air ventilation rates. Measure 4-5 feet above floor and vithin the occupant's breathing zone, but away from an individuals exhaled breath which could directly influence the reading. Measure during normal building and NVAC system operating conditions. .::Measure outdoor carbon dioxide level for comparison to indoor levels. (Average carbon dioxide level outdoor is 300-500 ppm). Measure during normal building and NVAC system operating conditions. DRAFT: DO NOT CITE OR QUOTE CN 22 N ~ ~A FP~ ~

DRAFT February 5, 1993 Appendiz B to 5 1910- --smoking-Control Policies that vili Result in a Smoke-pree Workplace (Non-Handatory) ----------------------------------- ------------- ---------------- (Questions Related to ventilation provisions that may be included in Options Memorandum: 1) Renovation and maintenance: During these procedures increased ventilation will be provided (Question: Is negative pressure needed, especially in renovation, tio prohibit the movement of particulates and fumes from the renovation area to ' surrounding office space?; If so, is any CFX appropriate? Can ventilation systems, in general, provide increased air to sections of floors that are undergoing routine maintenance, such as carpet cleaning and painting? If so,'is any CFM appropriate; or is it dependent upon the maintenance that is being done? It is necessary, and if so, is it sufficient to reference related standards in protection renovation workers under our existi:zq standards, i.e.; construction and asbestos standards. 2) Air Exchange versus Air Delivery: Is there an acceptable; feasible, procedure for assuring that air, whether recirculated or fresh, is getting to the Breathing zone of the workers? This question has to do with buildings that are run on nearly 100% DRAFT: DO NOT CITE OR QVOTE r= 23 0

DRAFT February 5, 1993 recirculated air. Did ASHRAE assume in 62-1989 that there was 100t outside air coming into a building to determine their cfm requirements (Table 2 and Section 6.1.3.2)? 3) Balancing of Ventilation System: Is it necessary and feasible to balance a system every so many years...tor example, every 3 or 5 years? what.would happen if the building could not be balanced? 4) Maintenance of HVAC system: How often should the system be inspected? How'often should filters be checked, and if needed, replaced? Quarterly, yearly? Is there any Personal Protective' Equipment required to insure the safety of workers entering air handlers and other parts of the system to protect them from bioaerosols and other contaminants? Should the workers who actually work on the system, or just building managers receive training in maintaining the•system? What should this training consist of? [Are there set procedures that could be followed by most of the buildings in this country to assure adequate maintenance of the HVAC system, regardless of system makeup and ' climatic conditions?] Are there any procedures that should not be allowed, not matter what? For example, I am aware that ozone air cleaners ate not well thought of, especially by our comrades at NIOSH, are there some procedures that are bogus, covering up or making problems worse, instead of curing them? DRAFT: DO NOT CITE OR QUOTE 24

D?ZAF2+ Februa_-y 5, 1993 5) Temperature/humidity ranges: Control of temperature of summer/ ainter ranges (76/68). Zs this feasible? Is the range of humidity attainable in all regions of the country (30-601) ? DRAFT: IDO NOT CITE OR 4VCTE 25