SECTION 297.7. Assessing and Resolving IAQ Problems

(a) A written plan should be developed as part of the building indoor air quality plan to include specific steps for investigating and resolving IAQ problems. Each facility or governmental entity should decide when and if investigations will be handled by in-house staff or if outside assistance is needed.

(b) Complaint response. All IAQ complaints should be acknowledged and investigated as quickly as possible. A written record should be kept of the complaint, investigation findings and resolution.

(c) Information gathering. The person(s) complaining or reporting an IAQ situation should be interviewed by a trained IAQ coordinator or qualified individual to gather as much information as possible. This information should include the nature of the complaint, the timing, complainant's symptoms, health effects, observed conditions at time of symptoms, such as odors, weather, occupant activities, and specific location(s) of problem(s). If several people and locations are involved, an occupant questionnaire can be used to help determine if the problem covers a specific location or is throughout most of an area or building, and if there are one or more problems. Results of the questionnaire may also be used to compare with building drawings to locate causes of the problem(s) and sources.

(d) On-site inspection. The complaint area should be inspected to locate any problem conditions or materials. Measuring temperature and humidity is recommended. Any visible microbial, chemical or material contamination sources, including the presence of odors, should be noted. During the inspection, the information gathered from the interviews should be compared with possible health effects of various contaminants and their sources, such as listed in Table 1, in §297.8(b), to aid in determining possible sources and contaminants to look for in the problem and related areas.

(e) HVAC system. The operation and condition of the HVAC system should be verified to ensure that adequate acceptable outside air provisions are being met. Check for drafts or stagnant areas. Check whether the layout of air supplies, returns, and exhausts promotes efficient air distribution to all occupants and isolates or dilutes contaminants. Check for short circuiting, airflow patterns and air velocity in occupied zone. Possible exterior contamination sources, such as vehicle exhausts, maintenance and construction operations and levels of natural exterior allergens should be noted.

(f) Resolution. Resolution of problem conditions determined as a result of occupant interviews and on-site inspections are often the only actions needed to resolve the complaint.

(g) Testing. Performing tests for contaminants of concern and factors affecting IAQ, unless conducted at the time of exposure, are unlikely to locate or measure a transient condition, and are not recommended for most investigations. If specific conditions are suspected and a need for verification testing is required, based on the visual inspection, health symptoms, clinical data and contents, and practices of the facility, then appropriate test methods should be performed by qualified personnel. Laboratory analysis of samples, where required, should be performed by a laboratory recognized or, preferably, certified in performing the analyses requested. Equipment utilized in the evaluation procedures should be calibrated according to manufacturers' recommendations and the sampling methods utilized. Outdoor samples may be needed for comparison with indoor samples for some conditions, such as temperature and relative humidity, and some contaminants, such as carbon dioxide and air-borne mold.

(h) Evaluating data and exposures.

(1) Before any sample collection, a standard of comparison and/or recognized acceptable standards should be selected. (i.e., carbon dioxide 700 ppm above outside level).

(2) Compare samples collected to standards established by the same testing methods.

(3) Compare indoor and outdoor sample results if appropriate.

(4) Compare sample results to the symptoms and complaints using standard toxicological procedures.

(i) Remediation. If suspected or other contaminants are identified, perform any necessary remediation using established and appropriate control methods for the situation.

(j) Communication. Any perception by building occupants that management is withholding information about an indoor air problem can be very damaging. Steps should be taken to ensure that up-to-date information is provided to building occupants and other concerned parties regarding any on-going IAQ investigations, survey results, planned repairs or remediation projects.

(k) Hiring professional assistance.

(1) Professional companies or contractors hired to solve, prevent, or control IAQ problems should provide evidence of meeting minimum criteria, to include at least:

(A) Education. The contractor should provide evidence of having obtained formal education appropriate to the scope of their professional expertise.

(B) Training. The contractor should provide a record of all training in IAQ issues for all workers, as appropriate.

(C) Licensure. Contractors performing services that require licensure, such as physicians, engineers, architects, lawyers, asbestos or lead abatement contractors, and similar categories, should provide proof of licensure.

(D) Experience history. The contractor should provide verifiable references for at least five projects of similar size and scope.

(E) Compliance history. The contractor should provide a list of all compliance actions initiated by the U.S. EPA, U.S. Occupational Safety and Health Administration, the Department, the Texas Commission on Environmental Quality (formerly the Texas Natural Resources Conservation Commission) or similar local agencies that are applicable to the job.

(F) Proof of insurance. The contractor should provide proof of insurance that includes general liability and/or errors and omissions coverage, as appropriate, to cover the job.

(G) Equipment. The contractor should have knowledge and skill to use the proper testing and inspection equipment needed to perform the job.

(2) Avoid conflicts of interest. Ensure that contractors are not in a position of (or the appearance of) creating work for themselves, nor inspecting or approving their own work.

Source Note: The provisions of this §297.7 adopted to be effective December 22, 2002, 27 TexReg 11759