As sick buildings become more visible, inaction is a liability. This situation begs the question: "Will you be ready when dissatisfied occupants, reporters and lawyers show up at your building?" As part of an overall preventive due diligence program, an IAQ audit can show good faith and quality management.
Making headlines
Most publicized incidents involving IAQ problems have involved moisture and microbial problems. For instance, an employee in a branch of the New York Library complained of respiratory illness. Even though the library had undergone an extensive renovation a few years earlier, basement flooding problems persisted.
A consulting group was brought in to investigate, and found a mold - Stachybotrys atra - that has been implicated in numerous sick buildings. The exact health effects of this mold are not clear, however. The building was closed, and other library branches were investigated. As a result of these additional investigations, two other branches were closed.
IAQ audit
An IAQ audit involves periodic inspection of an IAQ program to ensure practices are carried out and procedures are followed. In its simplest form, it involves a visual inspection of the building and its HVAC system components. A more comprehensive audit includes this inspection, along with a review of a building's:
• design documents
• training program
• written IAQ plan, including policies and procedures
• on-going documentation, such as complaint reports and maintenance records
• any IAQ or medical reports.
Fortunately, many useful resources exist to facilitate the audit process. For commercial buildings, the EPA's Building Air Quality guidance document contains blank forms that can be used to structure and conduct an audit. For educational facilities, EPA's IAQ Tools For Schools guidance kit contains practical checklists that can be used in an audit. An audit template accompanies this article on page 9, but any checklist used should be tailored to a building's specific needs.
Typical legal scenario
No legally established definitions exist as to what constitutes "good" IAQ in terms of design, operation and maintenance of HVAC systems or controlling indoor air contaminants. What should maintenance and engineering managers do to provide a healthful indoor air environment, given the lack of definitive standards?
Managers should base their conduct on industry standards developed by organizations such as the EPA, the Occupational Safety and Health Administration (OSHA), and the American Society of Heating, Refrigeration, and Air-Conditioning Engineers (ASHRAE), since the courts turn to these sources for guidance.
If managers can show that they are making a good-faith attempt to manage their facilities according to prevailing standards, their legal exposure to IAQ litigation will be minimized. How do managers show a judge or occupant they are making such an attempt? Documentation is key.
Building audits are an important process that managers should perform consistently in the course of building management. Aside from ensuring IAQ, audits can create necessary documentation to demonstrate good-faith IAQ efforts. A quality building audit provides a manager with tangible evidence that the building and its components have been assessed for current problems.
Regular building audits, much like regular medical check-ups, are preventive. They indicate a diligent, rather than an indifferent, management style, which can minimize legal exposure.
Air quality improvement
Maintenance and engineering managers need to meet rising occupant expectations each day, and they need to show a concerted effort is under way to maintain acceptable IAQ. Essentially, this is the concept of continuous quality improvement being applied to buildings: the air quality improvement process.
An IAQ audit can be a useful tool for isolating the areas on which management should focus. IAQ audits can pinpoint potential areas of concern, areas where preventive efforts are successful, areas that require the establishment of policies and procedures and areas where staff training is needed.
Implementation tips
The most effective way to start an audit program will depend upon a facility's in-house maintenance and engineering expertise. If a building's staff is well trained in IAQ and experienced with buildings and HVAC systems, managers can customize a checklist for the building, and audits can be performed periodically -at least once a year.
If in-house expertise does not exist, a consultant can be brought in to conduct the audit. During this third-party audit, appropriate personnel should accompany the consultant to learn how to conduct the audit themselves. It may be helpful to use photographs to document observations of the building and HVAC system.
The auditing process and the resulting observations can serve as a valuable training tool for all those charged with IAQ responsibilities.
After any audit, the auditor should brief members of the IAQ team on the resulting observations and suggestions. Managers should retain the completed audit checklist for future reference, and they should address problems in any areas that require corrective action, making sure to document the process.
With the increase in sick building visibility, inaction is a liability. After all, you never know when your IAQ might start making headlines.
