Children’s Environmental Health in Michigan
Respiratory Health and Asthma: Mold, VOCs, and Cleaning Products
Air contaminants in the indoor environment, can result in human health effects, particularly in children. School-age children typically spend 80% to 90% of their time indoors (mostly at home and at school), and the concentration of pollutants indoors is typically higher than outdoors, sometimes by as much as 10 or even 100 times (Kats 2006). Indoor air quality studies in school buildings have shown that the indoor air contaminants most commonly associated with asthma in children include formaldehyde (a type of VOC), other VOCs, and microbiological contaminants (including fungi, bacteria, and allergens) (Daisey et al. 2003). This section provides background information and policy analysis for common indoor air pollutants that have been linked to asthma symptoms in children, including mold, volatile organic compounds (VOCs), and cleaning products. The policy areas that will be discussed in this section include Green Building requirements, mold (remediation, reporting, and programs), and the use of less-toxic materials or cleaning products. Michigan policies will be analyzed for effectiveness in protecting children’s health, particularly through exposure prevention mechanisms. Best practices from other states will be noted, and recommendations to improve children’s protection from these exposures in Michigan will be provided.
- 1 Background Information
- 2 II. Policy Summary and Analysis
- 3 Evaluation and Recommendations
- 3.1 Indoor Air Quality (General)
- 3.2 Indoor Air Quality in Schools
- 3.3 Volatile Organic Compounds (VOCs): Indoor Pollution
- 3.4 Use of Less-toxic Cleaning Products
- 4 III. Summary of Recommendations for Michigan
- 5 References
Sources and Types
Molds belong to the fungi biological kingdom and can be found almost anywhere; molds can grow on almost any substance as long as moisture is present (EPA 2009a). Molds use spores to reproduce, and these spores can be found in outdoor and indoor air, and can also settle on surfaces. When a mold spore lands on a damp surface, it can grow (EPA 2001). It is these spores that are common indoor respiratory irritants. Common indoor surfaces that are prone to mold growth include leaky roofs, walls, and plant pots. Molds can enter homes through windows, doors, and ventilation systems; and then proliferate in damp environments. The most common indoor molds belong to the genuses Cladosporium, Penicillium, Aspergillus, and Alternaria, all of which have been associated with human allergic responses (AAP 2003). Increased sensitivity to these molds in individuals has been associated with increased severity of asthma symptoms (Black et al. 2011; Agarwal et al. 2011; Lyons et al. 2011, Ward et al. 2010).
In a review of available data, the Institutes of Medicine evaluated the association between mold, damp indoor environments and asthma, and classified them by the strength of the evidence. The report concluded there was good evidence linking damp indoor environments and mold to asthma symptoms in people with asthma (IOM, 2000).
Volatile organic compounds (VOCs) are a group of chemicals emitted as gases from certain solids or liquids. Many have adverse health or environmental impacts. VOCs can be emitted indoors by a wide array of household and commercial products such as paints and lacquers, cleaning supplies, building materials and furnishings, office equipment, correction fluids and carbonless copy paper, and craft materials such as glues and adhesives (EPA 2007). The concentration of VOCs in indoor air is consistently higher than concentrations in outdoor air, and can be up to ten times higher indoors than outdoors (EPA 2007). Concentrations of VOC’s are typically higher in newly constructed or newly renovated buildings than in older buildings (AAP 2003, Yang et al. 2009).
Formaldehyde is a common VOC, and is considered to be one of the most ubiquitous pollutants found in indoor air. It is found in many building material and home furnishing products including laminated wood products, particle board, textiles, paper products, and floor coverings. New furniture increases formaldehyde levels in a home, and is of particular concern in mobile homes due to the more limited space, low air exchange, and large number of particle board furnishings (AAP 2003).
While some chemical disinfectants and sanitizers are essential to controlling germs and preventing communicable diseases in schools, childcare centers, and homes, some cleaning products can also be potentially hazardous, particularly in concentrated forms (AAP 2003). Cleaning products can contain many ingredients that are potentially hazardous, including monoethanolamine surfactants and ammonium quaternary compounds used as disinfectants (Quirce and Barranco 2010; Savonius et al. 1994; Nielsen et al. 2007). Traditional cleaning products can also contain carcinogens, asthmagens and substances associated with reproductive organ damage, birth defects, kidney damage, neurological damage and other serious health impacts.
Other Indoor Air Pollutants
While this section addresses only mold, VOCs, and cleaning products, children are exposed to a number of other indoor air pollutants that can contribute to asthma. These include allergens from dust mite and cockroach droppings, pet dander, environmental tobacco smoke, and pollutants from automobile exhaust that infiltrate indoors (Wu and Takaro, 2007). There are many indoor air pollutants that can contribute to asthma and to other illnesses, some of unknown etiology. Because of this, some of the recommendations in this section go beyond the specific contaminants addressed in this section, and offer suggestions for improving indoor air quality in general.
Childhood Exposure to Indoor Air Pollutants
The major routes of exposure to mold include inhalation and dermal contact (AAP 2003). Children are exposed to mold when they inhale air contaminated with mold spores or when they touch surfaces on which mold is deposited (AAP 2003). Dampness and mold are frequent problems in U.S. school buildings, particularly in older buildings or those with poor ventilation. Many schools throughout the country are in need of major repairs or renovation; approximately 28% of U.S. schools have inadequate ventilation, which could potentially lead to dampness and mold (Sahakian et al. 2008).
A study of VOCs in elementary and middle schools in Michigan found that some of the most prevalent VOCs in indoor school environments were benzene, ethylbenzene, toluene, xylene, and limonene. Benzene, ethylbenzene, and toluene have been associated with asthma development in children. The sources of VOCs tended to be art and science classrooms, as well as indoor pools; the study concluded that improving ventilation systems, such as introducing dedicated ventilation systems for VOC sources might prevent the spread of VOCs from these special-use areas into the rest of the school facilities. Indoor concentrations usually exceeded outdoor levels. The study also found that ventilation was inadequate in many school rooms (Godwin and Batterman 2007).
The primary exposure route for VOCs is via direct inhalation; inhalation accounts for more than 99% of exposure to many VOCs (AAP 2003). The primary source of VOC exposures are from indoor air sources (see other sections of this chapter).
Sources of VOCs in outdoor air include major industrial emitters. Emissions of VOCs from all sources have declined in the U.S. substantially over the last 40 years (Figure 2). However, VOC emissions to the environment remain a serious concern, especially in Michigan. According to the EPA Toxic Release Inventory (TRI) database, 144,462 pounds of formaldehyde alone were released into the air in 2006 134,462 in 2007, 88,545 in 2009, and 107,511 in 2012 (EPA 2010).
The primary routes of exposure to cleaning products are inhalation and dermal exposure, although accidental ingestion is also a concern for young children. Cleaning products are used in homes, schools, and other indoor buildings, thus there is significant potential for childhood exposure. Cleaning products used in small, unventilated spaces, such as windowless bathrooms, may lead to high levels of cleaning chemicals in indoor air (Gorman 2007). The U.S. market for household cleaning products is quite large, over $14 billion in 2005 alone. It is a rapidly expanding market, driven predominantly by the growth in popularity of disinfectant products (Gorman 2007).
Several chemical ingredients found in household and industrial cleaning products have been associated with asthma. These include:
- Ethanolamines: surfactants commonly found in detergent, which can irritate mucous membranes and airways, inducing coughing, shortness of breath, and wheezing (Quirce and Barranco 2010).
- Quaternary ammonium compounds (quats): used as disinfectants, detergents, and fabric-softening agents.
Phthalates (phthalate esters): while most commonly used to soften plastic in consumer products, some phthalates are also used as carriers of fragrance in glass cleaners, laundry detergents, deodorizers, and fabric softeners. Phthalates may be often included under the generic ingredient ‘fragrance(s)’ and therefore may not be listed as an ingredient, due to fragrances being considered trade secrets. In addition to exposure from cleaners, humans can come into contact with phthalates used in polyvinyl chloride (PVC) plastics, which can leach out into air, dust, soils, and food, as the phthalates are not chemically bound to the plastic molecules (Jaakkola and Knight 2008). Phthalate exposure has also been associated with reproductive effects, although these effects are out of the scope of this chapter (Jurewicz and Hanke, 2011).
The most common illnesses associated with exposure to mold are allergic rhinitis and asthma. For people who are sensitive to molds, inhaling mold spores can cause an asthma attack (EPA 2009A). In the upper airways, the early allergic response to mold can produce symptoms such as clear rhinorrhea (runny nose), nasal congestion, sneezing, post-nasal drip with sore throat, coughing, and hoarseness (Storey et al. 2004). The late phase allergic reaction can cause nasal obstruction and hyper-responsiveness to allergens. Hyper-responsiveness makes the airway very sensitive to an allergen or other stimulant. Subsequent exposure to the allergen can cause an extreme reaction in a hyper-responsive airway; this lung hyper-responsiveness is very typical of asthmatics (Glaser 2005). Mold can trigger allergic responses in the lower airways of sensitized individuals, resulting in bronchospasms, chest tightness, and shortness of breath.
On a molecular level, these hypersensitivity reactions occur after an initial exposure to an allergen, which triggers an immune response that favors the sensitization of mast cells, the major mediators of allergic response (Storey et al. 2004). These cells accumulate in the interstitial space of the respiratory tract. Re-exposure to the allergen, in this case, mold, causes the mast cells to release histamine and other chemicals that cause inflammation (Storey et al. 2004).
In a review of available data, the Institutes of Medicine evaluated the association between mold, damp indoor environments and asthma. They classified the strength of the evidence, summarized in Figure 1. The report concluded there was good evidence linking damp indoor environments and mold to asthma symptoms in people with asthma (IOM, 2000).
There is significant evidence linking mold to exacerbation of asthma, while links to causation are more speculative (Storey et al. 2004). Visible mold presence has been associated with a diagnosis of asthma in adults (Thorn et al. 2001). Furthermore, an EPA-funded study found that building dampness and mold are associated with increases of 30-50% in respiratory and asthma related health outcomes. A related analysis estimated that 21% of asthma in the U.S. is linked to exposures to mold and dampness in homes, and that this costs the nation an estimated $3.5 billion annually in treatment costs (Fisk et al. 2007).
VOCs may have short- and long-term adverse health effects (EPA 2007). VOCs may induce acute asthma attacks in sensitive individuals, due to nonspecific irritation of the airways. Additionally, exposure to VOCs may result in upper respiratory tract and eye irritation, rhinitis, nasal congestion, rash, pruritus (itch), headache, nausea, and vomiting (AAP 2003).
A few studies have linked exposures to VOCs (measured in classroom floor dust) with asthma and other respiratory symptoms in children (Daisey et al. 2003). A 2004 study of children in Perth, Australia found that exposure to VOCs in the home may increase the risk of having childhood asthma. Children with asthma were found to be exposed to significantly higher levels of VOCs in their homes than children without asthma. Most of the individual VOCs measured in households were associated with asthma risk. Among these, benzene, ethylbenzene, and toluene -- chemicals used as industrial solvents but also present in a variety of products, including paints and cleaners -- were associated with the highest increase in odds of a child having asthma. Additionally, the researchers found that the levels of VOCs associated with an increased risk of childhood asthma were below advisory goals set by an Australian health advisory group (Rumchev et al. 2004). There are currently no EPA guidelines for levels of these and other VOCs in the home environment.
Formaldehyde, a common VOC, has been linked to upper respiratory tract irritation, and also to asthma exacerbation in infants and children (AAP 2003). Although most measurements of formaldehyde in school studies were low (below 0.05 ppm) and unlikely to cause acute symptoms, a recent review suggests that these low levels may increase risks for chronic irritation of the airways, increased sensitization to allergens, and cancer. The same research group concluded that many classrooms are not adequately ventilated, and this is likely to be related to increased respiratory and other health symptoms in school children (Daisey et al. 2003). A recent review article analyzed data from nearly 6,000 participants in a number of studies and concluded that individuals with greater formaldehyde exposure had a higher chance of developing asthma (Tillett, 2010).
Acute exposure to cleaning chemicals can lead to skin, eye, and lung irritation. In 2005, household cleaners were the third largest category of substances associated with calls to poison controls centers, with over 218,000 calls. Over half of these calls involved children under the age of six (Gorman 2007). Generally, exposure to household cleaners has been associated with an increased risk of developing asthma, allergies, and other respiratory symptoms in children and adults (Choi et al. 2010; Zock et al. 2007). Furthermore, a study in the U.K. found an association between frequent use of household cleaning products during pregnancy and persistent wheezing in pre-school aged children, supporting an association between prenatal exposure to cleaners and asthma symptoms in childhood (Sherriff et al. 2005).
Several chemical ingredients found in household and industrial cleaning products have been associated with asthma. These include:
- Ethanolamines: surfactants commonly found in detergent, which can irritate mucous membranes and airways, inducing coughing, shortness of breath, and wheezing (Quirce and Barranco 2010). While little is known about the household effects of exposure to these chemical, case studies have shown ethanolamines to induce occupational asthma in cleaning workers (Savonius et al. 1994). A recent clinical study attributed ethanolamine exposure in specifically in cleaners to occupational asthma cases (Mäkelä et al. 2011).
- Quaternary ammonium compounds (quats): used as disinfectants, detergents, and fabric-softening agents that adults and children may be exposed to via inhalation. As with MEA, exposure to some of these compounds has been associated with occupational asthma in exposed workers, although the underlying mechanism for this association remains unclear (Quirce and Barranco 2010). Recently, a study of French occupational health departments found that occupational exposure to quats was strongly associated with the development of work-related asthma (Paris et al. 2012).
- Phthalates (phthalate esters): while often used to soften plastic in many consumer products, some phthalates are also used as carriers of fragrance in glass cleaners, laundry detergents, deodorizers, and fabric softeners. Exposure to certain phthalates has been linked to asthma, allergies, and other respiratory symptoms in children (Bornehag and Nanberg 2010). Furthermore, phthalates may not be listed as ingredients in many cosmetic and cleaning products because they are used in fragrances, and are therefore not subject to disclosure. In addition to exposure from cleaners, humans can come into contact with phthalates used in polyvinyl chloride (PVC) plastics, which can leach out into air, dust, soils, and food Jaakkola and Knight 2008). Thus far, the association between phthalate exposure and asthma development has not been extensively studied in humans, however, animal studies demonstrate a potential link between early life and prenatal exposure to phthalates and asthma development. However, the clinical relevance of typical levels of phthalate exposure has yet to be elucidated (Bornehag and Nanberg, 2010). The presence of PVC flooring has been associated with childhood bronchial obstruction in case-control studies. Similar studies have also discovered associations between the presence of d-(2-ethylhexyl) phthalate (DEHP), one of the most commonly used phthalate types, in household dust with childhood asthma (Tsai et al. 2012). Moreover, a study of a cohort of Swedish children found that PVC flooring in the bedrooms of children and parents’ bedroom when the children were 1-3 years old was significantly associated with the incidence of asthma in those children 5 years later (Larsson et al. 2010). These associations demonstrate that more research needs to be conducted into the level and types of phthalate exposures that can lead to asthma exacerbation and asthma development. More research is also needed around the mechanisms by which they may influence asthma development, as there is a possibility that other, confounding factors.
Furthermore, there is some indication that frequent exposure to chlorination products, such as chlorinated cleaners (ex. products containing chlorine bleach), may be associated with the development or exacerbation of allergic diseases such as asthma (Bernard, 2007).
II. Policy Summary and Analysis
Mitigation of poor indoor air quality has the potential to greatly improve health conditions in indoor environments. For example, the Environmental Protection Agency (EPA) conducted a survey of indoor air quality (IAQ) programs in public and private schools, in which only forty-two percent of schools reported having IAQ programs. Respondents indicated that IAQ programs led to improved workplace satisfaction, fewer asthma attacks, fewer visits to the school nurse, and lower absenteeism. The study concluded that “when actively supported by the school administration, an IAQ program appears to be a valuable factor in improving the learning environment for U.S. schoolchildren” (Moglia et al. 2006). The following section evaluates current policies and provides recommended policy changes for improving indoor air quality in Michigan.
Designing and building homes and schools to provide healthy environments for children is an important means of preventing the generation of key indoor air contaminants. Eradicating mold or VOCs from a building post-construction can be extremely costly or impossible.
The U.S. Green Building Council (USGBC) has created the Leadership in Energy and Environmental Design (LEED) Green Building Rating System™, which is the “nationally accepted benchmark for the design, construction, and operation of high performance green buildings” (USGBC 2007). Improving the quality of indoor environments is an important emphasis in the LEED standards. There are several LEED rating systems for different types of building projects including new office/institutional construction, schools, homes, and commercial interiors. The rating systems have various categories of green design; and within each category, there are specific measures of sustainability that earn points on the rating system. The categories of green design include: sustainable sites, water efficiency, energy and atmosphere, materials and resources, indoor environmental quality, and innovation & design process. Compliance with American Society of Heating, Refrigeration, and Air Conditioning Engineers (ASHRAE) ventilation for indoor air quality standards (62.1-2007) is a prerequisite for LEED certification, and increases in ventilation rates beyond the prerequisite standards can account for additional points.
The ventilation rate of indoor air is an important determinant of indoor air quality and the health of individuals spending their time indoors. A review of 27 scientific studies on indoor ventilation rates and health found evidence of an association between an increase in ventilation rates and a decreasing frequency of asthma symptoms, allergies, and communicable respiratory infections; however, the strongest association found was in decreases in sick building syndrome (Sundell et al. 2011).
In an analysis of multiple studies on indoor air quality and child health, Daisey et al. found that many schools do not have ventilation rates which meet ASHRAE standards (2003). Furthermore, four studies of ventilation rates in Scandinavian homes suggest an association between low ventilation rates and conditions such as asthma and allergic rhinitis in children (Sundell et al. 2011). As such, prioritizing adequate ventilation rates in areas where children spend lots of time, such as schools and day-care centers, should be prioritized as a means of minimizing asthma and other respiratory symptoms in children. One policy method used by many other states which achieves this goal is having provisions requiring or incentivizing LEED certification in new and renovated buildings. These and other policy measures are discussed below.
Michigan Policy Highlights
- An Executive Directive signed by Governor Granholm in 2005, requires that all "state-supported capital outlay projects over $1 million," for state departments, agencies, universities, or community colleges, must be designed and constructed according to the Leadership in Energy and Environmental Design (LEED) Green Building Rating System. The Directive calls for all buildings to score a minimum of 26 points on the LEED scorecard, and extends the requirements to state-leased facilities, "to the extent feasible." (Executive Directive No. 2005-4).
Analysis and Policy Highlights from Other States
- Some other states have executive orders (EO) that have more extensive requirements for green building practices because they require LEED silver certification or higher:
- An Arizona EO requires state-funded buildings constructed after the order was issued to meet, to the "extent practicable," at least the Silver LEED Standard (Executive Order 2005-05).
- A California EO institutes the "Green Building Initiative,” which requires "state agencies, departments, and other entities under the direct executive authority of the Governor" to comply with the Green Buildings Action Plan instituted by the EO and requires, among other measures, that all "new and renovated state-owned facilities paid for with state funds" be certified "LEED Silver" or higher. The Green Action Team instituted by the Action Plan can mandate higher standards (Executive Order S-20-04).
- A New Mexico EO requires new construction of public buildings over 15,000 square feet to meet LEED silver standards, and encourages private sector businesses that lease to the state to meet similar standards (Executive Order 2006-001).
- Other states have passed legislation that encourages or requires the use of a green building rating system, such as LEED (or a comparable system), in new building construction or building improvement projects:
- Arkansas legislation encourages state funded public buildings to use LEED or Green Globes rating systems; it establishes an “award system” for meeting green standards; and it also creates a Legislative Task Force on Sustainable Building Design and Practices, which is charged with reviewing issues on sustainable design, monitoring and evaluating performance, and education; and which is authorized to ask for a review of sustainable building designs and practices by state agencies (A.C.A. § 22-3-1805, A.C.A. § 22-3-1804, A.C.A. § 22-3-1806).
- Hawaii requires each county that issues building permits to devise procedures for giving priority to projects that incorporate LEED standards (HRS § 46-19.6) and also requires each agency to design and construct buildings that meet LEED silver or two Green Globes (or a comparable system) standards, except when the green guidelines interfere with using the building as an emergency shelter. The statute also lays out other energy efficiency and environmental standards for state agencies and buildings (HRS § 196-9).
- Nevada requires all new public buildings, built after July 1, 2007, to meet "base level or higher" standards from the LEED Green Building Rating System or an equivalent system, and at least two buildings every two years must meet LEED silver or higher (Nev. Rev. Stat. Ann. § 338.187).
- Washington state requires all publicly funded "major facility projects" to at least meet LEED silver standards, with an exception where instituting silver standards is deemed "not practicable," and also requires annual reports detailing "major facility projects and operating savings" and a report to the legislature every other year on the overall projects (Rev. Code Wash. (ARCW) § 39.35D.030).
- Washington, D.C. requires that all city owned or financed residential construction or improvements above 10,000 square feet meet Green Communities 2006 standards (or equivalent) and submit a Green Communities Self Certification Check List and verification of meeting Green Communities requirements (D.C. Code § 6-1451.02).
- Washington, D.C. requires that private building applications (for buildings greater than 50,000 square feet) submit a green building checklist and meet or exceed green building requirements two years after occupancy. It further requires nonresidential and post-secondary education facilities to meet or exceed LEED-NC 2.2 or LEED-CS 2.0 standards, and educational facilities to meet or exceed LEED for schools standards (or equivalent), with exceptions for post-secondary educational facilities (D.C. Code § 6-1451.03).
- Some states implement a tax credit or economic incentive program for green buildings:
- Maryland has a tax credit for "green buildings and green building components" (the tax credit is $120 per square foot for base building and $60/sq ft for tenant space for the building as a whole, or other specific amounts for different green components). The overall tax credit is capped at $5 million for 2007, and for other years as laid out in the code (Md. Tax-General Code Ann. § 10-722(b)). In addition, Maryland permits cities and municipalities to offer a property tax credit for "high performance buildings" with at least a silver LEED or comparable rating (Md. TAX-PROPERTY Code Ann. § 9-242).
- Nevada regulation authorizes the Nevada Commission on Economic Development to offer partial tax abatement on all properties that are rated LEED silver or higher (or its equivalent). The abatement is for no more than 10 years and no more than 50% of the property tax assessed (Nev. Rev. Stat. Ann. § 361.0775). Statute sets the property tax abatement for reaching Green Building Standards, with the level of abatement depending on the LEED standards attained: 25% for silver standard, 30% for gold, and 35% for platinum. The abatement does not include abating taxes for public education (Nevada AB 621).
- New Mexico established a sustainable building tax credit for the owner or purchaser of a LEED or "Build Green New Mexico" certified building. The level of the credit depends on the LEED certification (N.M. Stat. Ann. § 7-2-18.20).
- New York created the Green Building Credit program, which provides credits of a percentage of "allowable costs" for buildings that meet green standards (informed by LEED), as determined by the Dept of Environmental Conservation. There are six different components to the tax credit with different amounts of credit and caps, with a total program cap of $25 million (NY CLS Tax § 19).
- Washington, D.C. established the Green Building Fund to implement the Green Building plans, undertake education efforts, and fund incentives (D.C. Code § 6-1451.07).
- Some states have specific green building programs for school buildings:
- A New Jersey Executive Order (EO) requires all new school designs to use LEED, Version 2.0 guidelines in school designs (Executive Order 24.4, 2002).
- A New Mexico EO established a "Public Schools Clean Energy Task Force" to issue recommendations about energy efficiency and green building in public schools (Executive Order 2006-001).
- Pennsylvania requires the Dept of Education to increase payments made for school buildings that receive LEED silver, gold, or platinum certification ($470 per pupil for elementary schools, $620 per pupil for secondary, or a proportionate amount for both) (24 P.S. § 25-2574[c.4]).
- Washington State requires "major facility projects" in public school districts to meet LEED silver standard or the "Washington sustainable school design protocol” (Rev. Code Wash. (ARCW) § 39.35D.040).
- Washington, D.C. requires educational facilities to meet or exceed LEED for Schools standards (or equivalent), with exceptions for post-secondary educational facilities (D.C. Code § 6-1451.03).
Evaluation and Recommendations
Michigan should tie state dollars to LEED certification (or comparable standards like the Green Guide for Healthcare) for all newly constructed and renovated primary and secondary schools. Michigan should also strongly consider providing tax credits for construction of new, private green buildings. In addition, Michigan should consider specific legislation that institutes a green building standard for any new schools, using LEED certification (or comparable standards).
Indoor Air Quality (General)
Michigan Policy Highlights
No enacted Michigan policy meets our specific criteria to address indoor air quality.
Analysis and Policy Highlights from Other States
- Several other states require or allow indoor air quality monitoring or assessment:
- California requires the Department of Health Services to "coordinate efforts to assess, protect, and enhance indoor environmental quality," which is defined as the environment inside "…a residential dwelling, including a house or apartment, or inside a school, office, public building, or other facility to which the general public has access" (Cal Health & Saf Code § 105420, § 105415).
- Hawaii permits the Director of the Department of Health to establish a program for approving plans to construct ventilation systems and monitor them to ensure that they are properly maintained (HRS § 321-412, § 321-413).
- Indiana authorizes the State Department of Health to undertake indoor air quality inspections of public buildings and institutions (Burns Ind. Code Ann. § 16-19-3-7).
- Florida requires the Department of Health to undertake environmental health monitoring, including the establishment of an indoor air quality testing and monitoring program. The goal of the program is to assess "…health risks from exposure to chemical, physical, and biological agents in the indoor environment" (Fla. Stat. § 381.006).
- Maine requires the Department of Administrative and Financial Services to provide "indoor air quality assessment and mitigation oversight services for public schools and state facilities" (5 M.R.S. § 1742-E).
- New York requires investigations into remediation of Brownfield Cleanup sites to, among other things, assess the existing and potential impact of groundwater contamination on indoor air quality (NY CLS ECL § 27-1415).
- Oregon permits construction and renovation of state facilities only if the authorized agency considers indoor air quality in its determination that the design "incorporates all reasonable cost-effective energy conservation measures and alternative energy systems" (ORS § 276.915).
- Texas refers matters related to the testing of indoor air quality to the Texas Department of Health, which should conduct necessary investigation and testing of indoor air quality and adopt rules related to indoor air quality in state buildings (Tex. Gov't Code § 2165.302).
- Washington State requires the Department of Labor and Industries to recommend policies for evaluating state-owned buildings regarding their indoor air quality, to recommend stronger workplace regulation of indoor air quality, to review air quality programs in public schools, provide educational information to state agencies, and recommend to the legislature necessary measures to improve indoor air quality (Rev. Code Wash. (ARCW) § 70.162.020).
- Washington State directs the state building council to review the state building code to determine how comparable the current ventilation and filtration standards are to industry standards, and to change the building code to bring it into conformity with industry standards (Rev. Code Wash. (ARCW) § 70.162.030).
- Some states have established specific standards or guidelines for indoor air quality in public and/or private dwellings:
- Maine requires the Department of Administrative and Financial Services to set minimum air quality standards for buildings in which state employees will be in. The minimum standards must be equal to the American Society of Heating, Refrigerating and Air Conditioning Engineers' (ASHRAE) "Ventilation for Acceptable Indoor Air Quality" (5 M.R.S. § 1742, 24).
- Maine requires any new or renovated residential buildings with more than two dwelling units to meet indoor air quality standards, as laid out in ASHRAE's "Ventilation and Acceptable Indoor Air Quality in Low-Rise Residential Buildings" (10 M.R.S. § 1415-C).
- Maine gives the Bureau of Labor Standards authority for enforcing indoor air quality standards in state-owned buildings (26 M.R.S. § 42).
- New Jersey requires the Department of Health and Senior Services (DHSS) (in consultation with other agencies) to adopt regulations for workplace rules regarding hazardous substances that are consistent with "federal and state indoor air quality standards and standards governing the exposure of children to hazardous substances as they are adopted by the federal government" (N.J. Stat. § 34:5A-10.5).
- Oregon authorizes, but does not require, the Department of Human Services to establish indoor air quality standards for "significant indoor air pollutants." If adopted, the standards must include an adequate margin of safety, be adequate for sensitive groups, and at least cover specific contaminants such as particulate matter, aldehydes, radon, carbon monoxide, carbon dioxide, ozone, and water vapor (ORS § 433.521).
- Texas authorizes the Board of Health (BOH) to establish voluntary guidelines for indoor air quality in government buildings. The BOH must also consider the potential health effects of air contaminants and insufficient ventilation, as well as the potential long and short-term costs of health care due to problems caused by exposure to contaminants (Tex. Health & Safety Code § 385.002).
- Washington State encourages public agencies to evaluate the adequacy of their ventilation systems to ensure they meet the recommendations of the American Society of Heating, Cooling, and Air-Conditioning Engineers (ASHRAE) (Rev. Code Wash. (ARCW) § 70.162.040).
- Some states have allocated funding or budget requests to improve air quality:
- Hawaii established a special fund for noise, radiation, and indoor air quality. Funds can be used to pay for costs of the program's mandated activities, statewide education programs, training opportunities, and for future growth and plans (HRS § 342P-7).
- Maine requires the Commissioner of the Department of Administrative and Financial Services to develop priorities in indoor air quality improvements when making budget requests for state buildings (5 M.R.S. § 1877-A).
- Some states have established indoor air quality working groups:
- Illinois established an Indoor Air Pollution Advisory Council in the Illinois Board of Health. The Council is charged with developing criteria for acceptable indoor air quality, issuing recommendations on achieving acceptable indoor air quality, undertaking public education programs, and issuing rules regarding the certification of indoor air quality inspectors. The Board is authorized to develop statewide indoor air quality guidelines including: ventilation standards, source control guidelines for indoor air contaminants, occupancy control, and air cleaning products (410 ILCS 87/15).
- Investigation of indoor air quality complaints:
- New Hampshire requires the Department of Health and Human Services to investigate poor indoor air quality complaints, inspect buildings and dwellings for presence of indoor air health hazards, and, in conjunction with the University of New Hampshire, provide education, consultation, and recommendations for abating those hazards (RSA 125:9.X).
- Wisconsin requires the Health Department to investigate illnesses or diseases thought to have been caused by indoor air quality problems; if it is determined that indoor air quality is the cause of such illnesses, the Department is required to assist local agencies in establishing control measures (Wis. Stat. § 254.22).
- Wisconsin requires the Department to assist local health departments in adopting regulations to establish indoor air quality standards for public buildings to "protect the occupants from adverse health effects due to exposure to chemical or biological contaminants." The statute also requires the Department to train and support local health departments in conducting indoor air quality testing and investigations (Wis. Stat. § 254.22).
- Some additional states have established education or outreach programs concerning indoor air quality:
- Texas requires the Department of Health to conduct education and outreach programs regarding the importance of air quality in buildings and how to improve it. The program can include developing public information, educational programs and exhibits, or other methods of education (Tex. Occ. Code § 1958.052).
- Hawaii established an indoor air quality program in the Department of Health, which must (1) provide information regarding indoor air quality to the managers, owners, and occupants of publicly owned buildings, (2) assist in identifying and correcting problems (it can provide the same to non-public buildings) and (3) coordinate an indoor air quality assessment network comprised of state agencies and managers of publicly owned buildings to identify and correct problems (HRS § 321-412, § 321-413).
- Some states have set indoor air quality standards in conjunction with green building standards (see Green Building section for more information):
- Maryland authorizes the development of indoor air quality criteria for certifying a building as a "green building" for tax credits (Md. Tax-General Code Ann. § 10-722(l)).
- Nevada requires guidelines for green buildings to include standards for indoor environmental quality (Nev. Rev. Stat. Ann. § 701.217).
- New York sets indoor air quality standards that must be met for a building to be designated as a green building and for the owner to receive related tax credits (NY CLS Tax § 19(9)(B)).
- Some states have developed incentive programs for improving indoor air quality in buildings:
- Oregon authorizes the Department. of Human Services to establish a public recognition program for building regulations that exceeds the public indoor air quality standards (ORS § 433.526).
- Oregon authorizes the Environmental Quality Commission to establish a voluntary accreditation program for companies providing indoor air quality sampling or ventilation system evaluations (ORS § 468A.775).
- Several states have included indoor air quality improvements in the definition of energy savings measures that are eligible for tax breaks or other financial incentives or that are exempt from regulatory limitations:
- Alabama (Code of Ala. § 41-16-141).
- Arizona (A.R.S. § 15-213.01).
- Colorado (C.R.S. 24-30-2001)
- Georgia (O.C.G.A. § 20-2-506)
- Louisiana (La. R.S. 33:4547.1)
- Missouri (§ 8.231 R.S.Mo.)
- Nevada (Nev. Rev. Stat. Ann. § 332.330).
- Oklahoma (61 Okl. St. § 212).
- Pennsylvania (62 Pa.C.S. § 3752)
Evaluation and Recommendations
Michigan is one of few states without policies pertaining to indoor air quality, and the state should consider policies that address this issue. Specifically, Michigan should establish specific standards or guidelines for indoor air quality in public buildings and pursue policies that require monitoring and assessment of indoor air quality, especially in public buildings. The state should also consider the establishment of specific standards or guidelines for indoor air quality in public buildings and private dwellings. Other possible Michigan programs to address indoor air quality include: education and outreach efforts, allocation of state funds for indoor air quality improvement, a state-wide working group, and the inclusion of indoor air quality improvement in the definition of energy savings measures eligible for financial incentives.
Indoor Air Quality in Schools
Michigan Policy Highlights
No Michigan policy met our specific criteria to address indoor air quality in schools.
Analysis and Policy Highlights from Other States
- Some states require or recommend indoor air quality monitoring for school buildings:
- Arizona requires school boards to do an environmental health assessment before approving new school buildings, and not approve the building if the plans do not have acceptable indoor air quality guidelines (A.R.S. § 15-2132).
- California requires the California Air Resources Board (CARB) to assess indoor air quality in portable school classrooms (Cal Health & Saf Code § 39619.6).
- Connecticut requires that prior to January 1, 2008, and every five years after, every school that has been built or renovated after January 1, 2003, must have the local or regional Board implement a "uniform inspection and evaluation program" for indoor air quality (such as the EPA's "Tools for Schools Program") (Conn. Gen. Stat. § 10-220(d)).
- Indiana permits the State Department of Health (DOH) to issue rules regarding instituting indoor air quality in schools’ inspection and evaluation programs. The DOH must inspect a school if it receives a complaint about the quality of air in the school (Burns Ind. Code Ann. § 16-41-37.5-2). In addition, Indiana created a "School Air Panel," to identify and inform schools of best operating practices for indoor air quality in schools and assist the State Department of Health in developing plans to improve air quality conditions found in inspections (see above) (Burns Ind. Code Ann. § 16-41-37.5-3).
- Maine requires the Department of Administrative and Financial Services to provide "indoor air quality assessment and mitigation oversight services for public schools and state facilities"(5 M.R.S. § 1742-E).
- Tennessee encourages each Local Education Agency (school district) to conduct an indoor air quality inspection and evaluation program, such as the EPA's Indoor Air Quality Tools for Schools Program, for facilities in its jurisdiction (Tenn. Code Ann. § 49-2-121).
- Some states have programs to improve indoor air quality in schools:
- Arizona requires the School Facilities Board to provide school districts with information about improving and maintaining "indoor environmental quality" in school buildings (A.R.S. § 15-2002).
- California permits "indoor air quality" improvements to be used as a criteria for receiving school funding (Cal Ed Code § 17070.96).
- California requires the California Air Resources Board (CARB) to report on indoor air quality to the state legislature by January 1, 2004, including a "description of options for schools to improve indoor air quality in public schools" (Cal Health & Saf Code § 39930).
- California permits the use of new school construction grants for maximizing indoor air quality (Cal Ed Code § 17072.35).
- Connecticut requires local or regional Boards of Education to adopt indoor air quality programs that would ensure maintenance and improvement of indoor air quality in school facilities (Conn. Gen. Stat. § 10-220).
- Connecticut permits local school boards to establish Indoor Air Quality Committees (Conn. Gen. Stat. § 10-231f).
- Maryland requires the Board of Public Works to adopt regulations regarding improving indoor air quality in "re-locatable classrooms." The regulations must require that each unit protect against water damage; provide continuous "forced ventilation" when it is occupied; have a programmable thermostat; be outfitted with energy efficient lighting, heating, and air conditioning systems; and mandate that each unit contain low amounts of volatile organic compounds (HB 164).
- New Hampshire includes purchasing or leasing equipment for improving indoor air quality in schools buildings in its definition of "construction" that is eligible for partial repayment under School Building Aid annual grants (RSA 198:15-b).
- New Hampshire requires electric utilities that receive funds for energy efficiency programs include measures that "help enhance the energy efficiency of public school construction or renovation projects that are designed to improve indoor air quality" (RSA 374-F:4.VIII-a). The state further requires the Department of Education to coordinate with the Public Utilities Commission to ensure that school districts eligible for grants under the School Building Aid program (see above) have submitted applications for funding reimbursement and technical assistance from energy utility companies to promote indoor air quality in public schools (RSA 198:15-c).
- New Jersey requires that the Department of Health and Senior Services (DHSS) issue regulations by January 11, 2008, to establish procedures for evaluating and assessing the interior of buildings to be used for child care centers, and to issue maximum contaminant levels for the interior of child care centers or schools. The rules must be "protective of the health of children and infants, and shall account for the difference in rate of the absorption, metabolism, and excretion of compounds between adults and infants and children." The statute requires DHSS to issue rules and standards to certify childcare centers and schools that do not have contaminants above the maximum contaminant levels and establish rules for applying for certification (N.J. Stat. § 52:27D-130.4).
- Maine requires school districts that apply for low-interest loans under the Efficiency Partners Program to be in compliance with ASHRAE's "Ventilation for Acceptable Indoor Air Quality" standards (30-A M.R.S. § 5953-C).
- Washington State permits the Superintendent of Public Instruction to implement a model indoor air quality program in a selected school district (Rev. Code Wash. (ARCW) § 70.162.050).
- Some states require investigation of indoor air quality complaints:
- West Virginia requires the State Board of Education to promulgate rules regarding investigations reports of indoor air quality problems in schools (W. Va. Code § 18-9E-5).
- Other states have set specific indoor air quality standards for schools:
- Several states including West Virginia (W. Va. Code § 18-9E-3; applicable only to new schools) and Connecticut (Conn. Gen. Stat. § 10-231e) require schools to meet the "current standards" of the American Society of Heating, Refrigerating and Air Conditioning Engineers (ASHRAE) handbook regarding heating, ventilation and air conditioning (HVAC) systems.
- Other states allow the levying of taxes to improve indoor air quality in schools:
- Nebraska includes expenditures necessary for indoor air quality modification in schools in permissible causes for levying taxes (R.R.S. Neb. § 79-10,110).
- North Dakota permits public school districts, with a 2/3 majority, to levy taxes to pay for the issuing of bonds to fund specific school improvements, among which could provide funds to repair, replace, or modify heating, ventilation, or air-conditioning systems to improve indoor air quality that meets the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) standards (N.D. Cent. Code, § 57-15-17.1).
Evaluation and Recommendations
In order to better protect children’s health, Michigan should consider policies that require both monitoring and improving indoor air quality in school buildings. These include:
- Consider including indoor air quality improvements in criteria for state funding, via grants, loans, or tax credits.
- Pursue the setting of specific indoor air quality standards for school buildings and consider policies to determine a standard method for investigating indoor air quality complaints in school buildings.
Volatile Organic Compounds (VOCs): Indoor Pollution
Michigan Policy Highlights
No Michigan policy met our specific criteria to address VOCs in the indoor environment. However, the federal government (EPA) does have regulations regarding VOCs in consumer products. The regulation requires many U.S. manufacturers, importers, and distributors to limit the VOC content of their products. The EPA also issued a rule limiting emissions from architectural coatings (exterior and interior house paints, wood and roof coatings).
Analysis and Policy Highlights from Other States
- Other states have additional guidelines for VOC emissions from indoor materials or consumer products:
- California requires the California Air Resources Board’s (CARB's) Indoor Air Quality Section to develop nonbinding guidelines regarding VOCs from construction materials in office buildings (Cal Health & Saf Code § 105405).
- California requires the CARB to impose a fee on consumer products and architectural coatings if a manufacturer’s total sale of these products in the state will result in the emission in the state of 250 tons or more per year of VOC emissions. The fees collected will be used to remediate VOC emissions (Cal Health & Saf Code § 39613).
- California permits air pollution control officers to require distributors of VOCs to disclose customer lists and chemical types and quantities of compounds and substances specified by the district, if they promulgate a list of VOCs (Cal Health & Saf Code § 42303.2).
- California regulation sets the VOC standards for certain consumer goods, and bans the sale or manufacture of products with VOC levels greater than the standards (Title 17, California Code of Regulations, Section 94509).
- Maine banned the sale or manufacture of any "architectural or industrial maintenance coating" manufactured after January 1, 2006 that contains VOCs in excess of specific standards (38 M.R.S. § 585-J).
- New York mandates that buildings eligible for the green buildings tax credit program follow standards for maximum levels of VOCs in building materials and meet indoor air quality standards (including VOC limits) both to be issued by the Department of Environmental Conservation, and requires qualifying buildings to monitor VOCs (among other regulations) (NY CLS Tax § 19).
- New York establishes standards for volatile organic compound (VOC) content limits (percent by weight) in consumer goods (Title 6 §235-3.1).
- Rhode Island Department of Environmental Management (DEM) issued a regulation that bans the sale or manufacture for sale of certain consumer products containing VOCs, with exemptions for products offered for sale outside of Rhode Island and certain other products (Air Pollution Control Regulation No. 31.2).
- Rhode Island limits the amount of VOCs in inks used in printing operations unless systems to capture VOC emissions are in place (Regulation No. 21).
- Virginia sets VOC standards for consumer products in the "Northern Virginia and Fredericksburg Volatile Organic Compound Emissions Control Area" and bans the sale or manufacture of products whose VOC content exceeds limits (9 VAC 5-40-7270).
- Other states require indoor air testing for VOCs in schools:
- Connecticut requires Boards of Education to conduct air quality testing for a variety of potential toxicants for all schools built or renovated after January 1, 2003; the toxicants of interest include both molds and "volatile organic compounds (VOC)"(Conn. Gen. Stat. § 10-220(d)).
- Other states limit VOCs in schools:
- Maryland requires that portable classrooms be built with building material containing low amounts of volatile organic compounds, but does not statutorily define what, if any, limit there is on VOCs. (Md. HB 164 (2007 Md. Laws 223; 2007 Md. Chap. 223)).
Evaluation and Recommendations
Michigan should consider the establishment of guidelines for VOC emissions from indoor building materials and consumer products. In addition, the state should consider either setting VOC standards for certain consumer goods or banning the sale or manufacture of products with VOC levels greater than set standards. In addition, Michigan should address VOC pollution in school buildings by requiring air quality testing and/or by requiring use of building materials with low levels of VOCs.
Use of Less-toxic Cleaning Products
Michigan Policy Highlights
No Michigan policy met our specific criteria to address the use of less toxic cleaning products.
Analysis and Policy Highlights from Other States
- Three states have passed legislation that requires implementation of guidelines for the use of green cleaning products in school buildings:
- Connecticut requires that by July 1, 2011 each local and regional board of education establish a green cleaning program and that no cleaning product be used in a school unless it meets the environmental standard set by a national or international certification program approved by the Department of Administrative Services. These certification programs include “Green Seal” and “Ecologo” certification. This requirement, however, does not apply for disinfectant products. Additionally, copies of the program shall be distributed to staff members and, upon request, parents and guardians of children at the school (P.A. 81).
- Illinois requires that the Illinois Green Government Coordinating Council (IGGCC) establish guidelines for "environmentally-sensitive cleaning and maintenance products for use in school facilities." Within 90 days of the issuing of the guidelines, all elementary and secondary schools with more than 50 students must establish a green cleaning policy and exclusively purchase products that meet guidelines (with an exception for previously purchased supplies) if "economically feasible." Schools must provide annual written notice if the green cleaning program is deemed not “economically feasible” (105 ISL 140/10).
- Maine requires the Department of Education (DOE) to promote implementation of green cleaning programs in schools. The Department is required to compile a list of cleaning products that either meet "health-based criteria" by an independent agency or are listed as "environmentally preferred janitorial products" by the Maine Bureau of General Services. A list detailing these products is to be provided to schools every year. The DOE is also required to compile a list of disinfectants that have been evaluated using "acceptable criteria" for preferred janitorial products and registered with the Board of Pesticide control; this list is also to be distributed to each school district annually. Additionally the statute requires the DOE to (1) develop cleaning procedure recommendations that reduce the use of toxic chemicals and improve indoor air quality while maintaining cleanliness performance standards and (2) disseminate these "green cleaning procedures" to school districts. The statute authorizes the DOE to compile and maintain a list of school districts that committed to implementing the green cleaning program, and to make that list available to the public (LD 88 (SP32) 2007).
- Other states have incorporated goals to improve indoor air quality in their definitions and information gathering processes:
- California includes products that result in "less harm to indoor air quality" when defining "environmentally preferable products" that can be used in the construction and modernization of schools (Cal Pub Resources Code § 42635).
- Vermont directs the Department of Health to compile information about materials and practices used in schools that have a detrimental impact on indoor air quality and human health and to make those available to Vermont schools. The 1999 act set a goal of 50% of schools qualifying for “environmental health certification” by Jan. 2005 (Legislative Findings, Purpose and Goals. 1999, No. 125 (Adj. Sess.), § 1 to 16 V.S.A. § 1421).
- Other states have developed ozone standards for indoor cleaning products:
- California required CARB to develop regulations regarding ozone emitting indoor cleaning products by December 31, 2008, and laid out guidelines for those regulations (Cal Health & Saf Code § 41986).
Evaluation and Recommendations
Michigan should strongly consider passing legislation to require the use of green cleaning products in school buildings, such that the products meet an environmental standard set by a national or international certification program approved by the State of Michigan.
III. Summary of Recommendations for Michigan
To better protect children from harmful exposures indoors, Michigan should strongly consider implementing the following policy measures:
- Establish monitoring and/or assessment programs of indoor air quality, especially in public buildings, similar to those in California, Hawaii, Indiana, Florida, Maine, Texas, and Washington State.
- Establish specific standards or guidelines for indoor air quality in public and/or private dwellings, like in Maine and New Jersey.
- Establish programs for education and outreach, like Hawaii and Texas.
- Allocate state funds for indoor air quality improvement, like Hawaii and Maine.
- Establish a state-wide working group, as done in Illinois.
- Include “indoor air quality improvement” in the definition of energy savings measures eligible for financial incentives, as done in Alabama, Arizona, Colorado, Georgia, Louisiana, Missouri, Nevada, Oklahoma, and Pennsylvania.
- Establish indoor air quality monitoring programs in school buildings, as done in Arizona, California, Connecticut, Indiana, Maine, and Tennessee.
- Establish programs to improve indoor air quality in school buildings. For example, Michigan may consider including indoor air quality improvements in criteria for grants, funding or loans, as done in California, New Hampshire, and Maine.
- Investigate indoor air quality complaints in school buildings, as done in West Virginia and Wisconsin.
- Set ‘high-performance school’ construction standards for schools, as is done in Vermont and Rhode Island, and incentivize newly constructed schools to follow these standards by increasing state funding towards projects that do. This would include require building material that have been tested and certified as emitting low levels of VOCs, for instance.
- Set specific indoor air quality standards for schools such as ASHRAE ventilation standards, as done in West Virginia and Connecticut, or specific standards to “protect the occupants from adverse health effects due to exposure to chemical or biological contaminants,” as done in Wisconsin.
- Set guidelines for VOC emissions from indoor materials or consumer products, as done in California, Maine, New York, Rhode Island, and Virginia.
- Ban the sale or manufacture of products with VOC levels greater than set standards, as done in Maine and Rhode Island.
- For schools, require air quality testing and/or requiring building material with low levels of VOCs, as done in Connecticut and Maryland.
- Michigan should offer increased state funding to those schools that meet higher tier LEED certification (e.g., silver, gold, and platinum certification), as is done in Pennsylvania.
- Michigan should offer tax credit or other economic incentives for green building projects, as is the case in Maryland, Nevada, New Mexico, and New York.
- Require least toxic cleaning products and materials to be used in schools, as done in Connecticut, Illinois, and Maine.
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