Indoor Air Quality Policy
Indiana University Purdue University Indianapolis is committed to providing a work environment that is free of recognized hazards and to investigate complaints that may be related to poor indoor air quality (IAQ). Acceptable indoor air quality is air in which there are no known contaminants at harmful concentrations as determined by the Department of Environmental Health and Safety (EHS) and with which a substantial majority of people exposed do not express dissatisfaction.

Mildew and other molds are often identified by visual observation. When not readily observed, probable mold sources include: dirty ventilation ducts, old air conditioner filters, fabrics in humid environments, and where water intrusion has occurred; affected carpets, walls, ceiling, and office furnishings.

Another consideration is the magnitude of the probable sources of the suspected contaminant. A small area of old carpeting is less likely to be a problematic mold source than a larger area where flooding had occurred.

Area of Concern
During its investigation, EHS will delineate an area of concern for indoor air quality problems and possible remediation. The area of concern will be delineated according to the locations of complainants, the probable source of the suspected contaminant, the design of the HVAC system, and physical barriers.

Remedial Measures
Remedial measures may be confined and temporary, or as extensive as renovation of a building’s heating, ventilation, and air conditioning (HVAC) system. Less extensive remedial measures include better housekeeping, replacing furniture, cleaning mildew off of pipes, installing portable dehumidifiers or air cleaners, cleaning window air conditioners, and replacing carpet with tile.

Sick Building Syndrome
When the symptoms of respiratory tract and eye irritation, headaches and fatigue are experienced by a sizeable percentage of building occupants (usually more than 20 percent), the situation has become known as Sick Building Syndrome (SBS). Specific causes of SBS remain unknown. Insufficient fresh air (outdoor air) being brought inside is sometimes associated with buildings with SBS. A single cause for SBS is unlikely. Many hypotheses must be considered in determining the cause of complaints in any particular building, including ventilation rates, ventilation system maintenance and type, and a multitude of irritants from occupant activities, microbial contamination, and off-gassing from building furnishings.

Building-Related Illness
Building-related illness is very rare, but often more serious than symptoms reported in SBS, and may affect only a small number of building occupants. BRI is characterized by a distinguishable set of common occupant symptoms, often accompanied by physical signs and clinical abnormalities. BRI is confirmed by a physician’s diagnosis and may include infections such as legionellosis, toxic syndromes associated with exposure to chemical or physical agents, and hypersensitivity diseases, including hypersensitivity pneumonitis, “humidifier fever,” asthma, and allergic rhinitis.

Prevention Of Indoor Air Quality Problems
Many IAQ issues can be avoided with timely maintenance and repair of building HVAC systems and rapid response to water intrusion into a building. The drying process of water damaged areas must be started within 48 hours to prevent the initiation of fungal growth. Building occupants should notify Campus Facility Services (CFS) as soon as
possible of plumbing, roof and foundation leaks or HVAC malfunctions. CFS and EHS respond quickly to these problems. CFS will follow the established guidelines for water remediation.

EHS Indoor Air Quality Investigation
Evaluation of building related complaints requires the cooperative effort of the complainant, CFS, and EHS. Following the initial complaint, EHS will interview the complainant to determine if his or her symptoms are potentially related to IAQ problems. When such a potential exists, EHS will conduct an IAQ investigation with appropriate CFS staff according to the following procedures. The investigation may lead to plans for remediation.

Identification of IAQ Problems
Building occupants who experience irritations that may be related to indoor air quality should complete a Request for Indoor Air Quality Investigation and forward it to EHS for review. An EHS Industrial Hygienist will review the form and interview the complainant to determine what further action is needed.

Complaints received by CFS, involving specific symptoms, should be forwarded directly to EHS for review. Facility engineers and campus maintenance workers who identify IAQ problems or risks (e.g., odors, significant mold growth, faulty building humidification systems) should contact EHS directly.

Initial On-Site IAQ Investigation
When notified and if warranted, an EHS Industrial Hygienist will conduct an initial on-site investigation. The following conditions will typically be evaluated:

• Percentage of outside air being supplied to building
• Location of outside air intake(s)
• Immediate outside environment
• Ventilation rate
• Operation and maintenance of HVAC system
• Relative humidity
• Temperature
• Carbon dioxide level
• Signs of water intrusion including plumbing, roof, and foundation leaks

EHS will also evaluate the work area and building for probable sources of contaminants, such as: chemical use and storage, general housekeeping, recent renovations and/or new furnishings, floods, activities in work area, and the building HVAC system. Some investigations will require the assistance of CFS.

Phase II IAQ Investigation
In some cases, the initial investigation indicates the need for a Phase II IAQ investigation to provide more detailed information regarding the nature of the problem. This phase of the investigation may include the following:

• Monitoring for chemical contaminants
• Bioaerosol monitoring
• Detailed HVAC evaluations
• Medical examinations and/or testing at Occupational Health Services

Limitations of IAQ Investigations
Sampling methodologies and acceptable limits have been established for many contaminants. However, occupants may continue to experience discomfort at contaminant levels below standards for occupational exposure. Individual sensitivities vary and the ability to measure possible irritants at low concentrations is limited by technology. Thus, irritants may be present at concentrations that are undetected but may cause health effects in sensitive individuals.

Sampling and measuring indoor mold contamination on surfaces is of limited value because mold is found in virtually all environments, and because no consensus or regulatory standards have been established. One of the problems with establishing standards is that individual sensitivity to mold varies greatly.

Because of the small number of occupants and uncontrolled conditions, epidemiological studies are of no or very limited value.

Remedial Measure Decision-making
When indicated, EHS will recommend remedial measures. These will be reviewed by Occupational Health Services, the complainant’s supervisor, and/or CFS as needed. When visual observations find significant mold in water-damaged environments, controlling and eliminating mold growth will be recommended in accordance with the IUPUI Mold Investigation Guidelines. EHS will determine if other IAQ risks are actionable by evaluating four variables:

• Probable source of a suspected contaminant, and its extent or magnitude
• Number of occupants with symptoms appropriate for the suspected contaminant, and the severity of their symptoms
• The availability of reasonable and effective measures to mitigate the suspected contaminant
• Time of exposure of the symptomatic employees to the suspected contaminant

When the source of an indoor air quality problem and appropriate remedial measures are difficult to discern, recommendations will rely on the judgment of CFS and EHS staff.

Implementation of Occupant-Responsible Remedial Measures
Remedial action that needs to be implemented by the supervisor should be completed within a reasonable time. This type of action could include general housekeeping, the purchase of a non-fabric chair, or the relocation of printers or paper storage.

Implementation of Other Remedial Measures
If the remedial measures require building maintenance or repair, CFS or Student
Housing (as appropriate) will work with EHS and the building occupant to implement
them.

Except for very small projects, areas found to have an indoor air quality problem are
prioritized for remediation and classified as “Class A-High Priority,” “Class B-Further
Evaluation Needed,” and “Class C-IAQ Improvements Already Funded.”

Employees with Continuing IAQ Complaints
Employees who experience symptoms after the remedial measures have been implemented should report the symptoms to their supervisor and call Occupational Health Services (OHS) at 274-5887 for a medical evaluation. If an employee presents medical documentation to his or her supervisor from the employee’s personal physician, the supervisor should forward the note to OHS.

After review of all reports, OHS will make its recommendations to the employee, his or her supervisor, and EHS for any additional follow-up. The affected department should not implement any permanent accommodations that the employee’s physician has requested until OHS completes an occupational medical assessment and reviews EHS IAQ investigation reports.

If OHS deems that the medical accommodation for the employee’s position is necessary, the employee’s supervisor should contact the University’s ADA Officer. The ADA Officer will work with the employee’s department in determining what accommodations are reasonable under the current essential job functions for that employee.