Indoor Air Quality Awareness Briefing

1. Indoor Air Quality Awareness Briefing For Presentation to: Project Managers, Resident Engineers, Facility Managers, & Facility Representatives

2. Background • Recent Indoor Air Quality (IAQ) Issues at ATO Facilities • Over 50 IAQ incidents at ATC facilities over the last 3 years • Majority of the incidents were construction-related • Media attention from high profile IAQ incidents at FAA • IAQ-related LR issues from several recent arbitrations • Congressional Hearing (7/24/07)

3. FAA IAQ Incidents • Internal and External sources • Odors from natural gas and sewers • migrate through floor drains • Vapors from paint, mastic, and new carpet/furnishings • Smoke and dust • Construction-related activities • Mold • Moisture build-up; Water leaks; Standing water • Exhaust gases from vehicles/jet engines/portable power tools • Through outdoor air-intakes

4. IAQ IncidentsCommon Causes • Construction/Renovation projects and activities • Nuisance odors, vapors, dust, etc. from products, chemicals used during construction activities

5. IAQ IncidentsCommon Issues • Lack of monitoring equipment • Proper equipment to identify contaminants • Lack of management training in • Appropriate incident response • Occupational Safety & Health (OSH) and IAQ issues at construction/renovation projects • Existing OSH Programs (i.e. Hazard Communication program requirements)

6. IAQ IncidentsCommon Issues • Emergency/Incident Response procedures • Not clearly defined at ATC Facilities • Employees not properly trained • Communication Coordination • Airport Authorities and FAA Facilities representatives/managers must increase communication • Utilize programs already in place (Hazard Communication, Checklists, etc).

7. Communication • Follow the prescribed FAA protocols for sharing information with building occupants prior to start of project (i.e. construction, asbestos) • Project location and schedule • Chemicals/products to be used • Material Safety Data Sheets • Disruptions to normal schedule • Egress/exits

8. Communication • Designate an individual (i.e. SECM) to respond promptly to potential IAQ issues • Liaison between facility and resident engineer and/or project manager

9. Communication • Prevent Nuisance Dusts, fumes, vapors & odors from entering your facility. • Look for potential sources in your facility and from nearby projects. Coordinate with personnel performing the work to ensure that these nuisance contaminants do not get into the workplace at FAA facilities through fresh air intakes or HVAC systems.

10. Contract Administration • Contract language should include IAQ specifications and recommendations • Contract Specifications include: • Notification and Hazard Communication requirements • Scheduling to minimize occupant exposure and risk to facility operations • Selection of building materials • Protection of building systems including the HVAC system • Use of isolation techniques, including barriers and negative pressure

11. Contract Administration • Ventilation and filtration requirements • Work practices and housekeeping • Material storage • Final clean-up and facility restoration • Close-out and commissioning criteria for new construction or renovations

12. Planning - FAA Order 3900.57 • FAA Pre-Construction & Maintenance Project Safety & Health Checklist (Form 3900-8) • Used by the RE, COTR, designated facility POC, and District Office or SSC Manager • For construction & maintenance activities with potential EOSH-related impacts • To assess and reassess hazards during project

13. Planning - FAA Order 3900.57 • Section 3 – Project Hazard Risk/Analysis • Potential IAQ hazards shall be identified • Section 4 – Site Safety and Health • IAQ controls shall be addressed and risks mitigated. • Consult an EOSH professional as needed • Ensure FAA Hazard Communication requirements are in effect and remain so throughout the project

14. Pre-Construction Meeting • Ensure compliance with the following: • FAA Form 3900-8 completed and reviewed • Hazard Communication requirements (29 CFR 1910.1200) • MSDSs submitted for review • EOSH expectations discussed and understood by all affected parties • Project Engineer must review all required EOSH permits • Brief management and employees as required (i.e. new materials, processes, project activities in order to minimize/mitigate risks to employees and NAS operations

15. Pre-Construction Meeting • Project-specific IAQ mitigation must be discussed and implementation requirements accepted by appropriate parties • Controlling outdoor air intake • Installing dust barriers • Additional ventilation • Proper storage/disposal of hazardous materials • Air monitoring equipment

16. Construction • Facility Emergency Plans • RE and Facility Manager (includes ATO-T, ATO-E, and ATO-W) shall review and revise • based on identified hazards following Pre-Construction Meeting. • Plans to be reviewed: • Occupant Emergency Plan • Asbestos Contingency Plan • Continuity of Operations Plan

17. Roles and Responsibilities • Resident Engineer • Ensure facility systems are installed and performing to meet owners EOSH performance requirements • Document all system testing results • Provide to building owner prior to acceptance • Validate that system performance and configuration meet the design basis and intent • Ensure system manuals are delivered to the building owner and system training is provided • Keep Facility Managers informed of all IAQ related issues/activities

18. Roles & Responsibilities • Resident Engineer • Safety briefings must be conducted between the RE and the Facility Manager • Utilize Form 3900-8 • Review and revise facility emergency plans • Review all sections of MSDSs, communicate concerns to the SECM, and ensure chemicals are used as intended • Daily inspection / coordination to keep nuisance odors / fumes / dusts/ vapors from entering FAA workplaces • Review all product information (i.e. carpet for off-gassing); communicate concerns to the SECM

19. Roles & Responsibilities • Project Engineer • Coordinate review of project design with Engineering Services EOSH Professional and SECM • Ensure project activity information provided to employees prior to start of work activities • Safety briefing and project review must be completed and documented as appropriate between the RE and a facility designee

20. Roles & Responsibilities • Project Managers • Consider IAQ requirements in construction, installation, commissioning, and modifications phases • Include Engineering Services EOSH professional and SECM in the review of project documents, risk management planning and the coordination of the project • Incorporate applicable IAQ regulatory requirements and consensus standards into contract documentation

21. Roles & Responsibilities • Facility Manager • Assist individuals performing IAQ evaluations • Ensure HVAC systems are maintained regularly • Initiate investigations of worker complaints related to IAQ • Maintain documentation of all IAQ complaints, investigations, and subsequent resolutions • Maintain MSDSs on-site

22. Roles & Responsibilities • Facility Manager • Invite Bargaining Unit representatives to Pre-Construction meetings • Review and revise facility emergency plans • Inform facility employees of upcoming project activities prior to start of construction • Ensure compliance with Hazard Communication program requirements and keep employees duly informed

23. Roles & Responsibilities • Facility Manager • Conduct at least weekly, safety briefings with the Resident Engineer during construction • Complete Form 3900-8 for all maintenance activities with potential EOSH-related impacts • Daily inspection / coordination to keep nuisance odors / fumes / dusts/ vapors from entering FAA workplaces • Ensure compliance with PASS CBA Article 52 especially Sections 9, 10, & 13 and NATCA CBA Article 53 especially Sections 8, 9, & 12

24. Roles & Responsibilities • Facility Representatives • Participate in Pre-Construction meetings • Review facility emergency plans • Review MSDSs of chemicals/products to be used during construction • Daily inspection / coordination to keep nuisance odors / fumes / dusts/ vapors from entering FAA workplaces • Participate in risk management planning

25. General Activities • Preparation • Work shall be scheduled while building is unoccupied, whenever possible • Use ventilation and containment strategies to prevent spread of contaminants • Use fire retardant plastic sheeting/barriers • Isolate areas and occupants from dust or pollutants generated during renovations • Temporarily relocate occupants when necessary

26. General Activities • Ventilation • Avoid cutting off outdoor air supply • Do not enclose a pollutant source (e.g. copiers) in areas with inadequate exhaust or supply air • Do not erect barriers (e.g. new walls) that could prevent adequate movement of air

27. IAQ Concerns • Asbestos / Lead Paint • Review Asbestos Survey Inventories to determine where presumed asbestos containing material/asbestos containing material (PACM/ACM) are located • Do not disturb asbestos/ lead paint during repairs, renovation or maintenance activities • If suspected/presumed asbestos containing materials (ACM) or lead paint may be impacted: • Consult an EOSH professional • Review the facility Operations and Maintenance Plan

28. IAQ Concerns • Mold • If mold and mildew are observed during renovations • Consult an EOSH professional • Consult the Indoor Air Quality Implementation Guidance (http://ats.awa.faa.gov/aaf/afz/800/afz800frame.htm)

29. IAQ Concerns • Pesticide Use • Ensure that only necessary and appropriate pest control practices are used • Choose the least toxic chemicals • Avoid dust and spray formulations if possible • baits, traps, or granules are the preferred formulations

30. Building Maintenance • HVAC System • Coordinate with building management to discuss operation, and maintenance of the HVAC system • Work with building management to ensure that system is balanced • Ensure regular Preventive Maintenance is performed on window air conditioners and perimeter heating and cooling units • e.g. regular filter change • Recommend changing all impacted filters after a major rennovation or when IAQ related impacts were potentially involved

31. Building Maintenance • Cleaning Products • Replace with less hazardous products • Take steps to reduce exposures to contaminants from cleaning products • E.g. adequate ventilation, proper PPE (gloves) • Janitorial procedures • Evaluate procedures • Cleaning Chemicals/Products • Review MSDSs to ensure chemicals do not increase worker exposure

32. Building Maintenance • Use HEPA Filtered vacuums • Carpet Cleaning • Use adequate extraction methods for wet carpet cleaning • Ensure carpet or other porous materials do not remain wet for more than 48 hours

33. Off-Gassing • New materials/furnishings may emit organic compounds • Increase ventilation with outdoor air during and immediately after installation • Delay re-occupancy of space when possible

34. Project Completion and Commissioning • Establish IAQ-related procedures and criteria for all renovation projects. • Conduct general cleaning of renovation space • Wipe surfaces • Vacuum using high-efficiency particulate air (HEPA) filters or equipment

35. Project Completion and Commissioning • Clean building system components • E.g. ventilation system • Ensure proper disposal and replacement of air filters • Balance and test the ventilation system