Salt Lake City High Performance Building Initiative
Recommendations for Improved Indoor Environmental Quality
(Chapter Five Draft Narrative 05/16/02)
Indoor Environmental Quality
Vision: Salt Lake City shall achieve superior and award winning Indoor
As Salt Lake City continues to sustain major urban growth, it shall
maintain and improve the quality of life features of the indoor built
environment. Its building and rebuilding goals shall ensure healthy and
comfortable public, commercial and institutional spaces for residents,
commuters and visitors
Indoor environments must be healthy and comfortable.
Utah‟s spectacular geography has contributed to our love of the great
outdoors. Enhancing IEQ will engender similar feelings for our indoor
Implementation of good IEQ practice in both public and private buildings
results in demonstrated improvement in occupant health and
Improved IEQ will give SLC a competitive edge in business because of
increased work quality and productivity.
SLC will be selected over other cities for high profile and desirable
conventions and conferences, in part, because of SLC's reputation for
first class IEQ
Recognition that good IEQ design does not necessarily cost more to
construct than poor IEQ design
Recognition that payback period for investment in good IEQ often very
SLC becomes a "model" IEQ community that leads other communities in
Utah and the intermountain west
Recognition that "up front" attention to good IEQ well worth it because of
reduced owner liability and improved resale value.
Recognition that "up front" attention to good IEQ much less expensive
than restoring a problem building.
Recognition that with much of the built environment yet to come; SLC
has opportunity to realize the benefits of good IEQ.
Recognition that the benefits of good IEQ practices are realized not only
in new buildings but also in additions, retrofits and remodels of existing
New and desirable businesses will be attracted to Salt Lake City
because of SLC's ongoing commitment to superior IEQ.
Recognition that IEQ is must be considered with other high performance
building attributes to achieve maximum benefit.
Indoor Environmental Quality for Salt Lake City
Access to spectacular Western landscapes and all that nature offers
makes Salt Lake City one of the best places to live, work, play, visit, and
do business in America. Nevertheless, Utah is one of the most
urbanized states with over 70% of it‟s population living along the 100
mile long and 20 mile wide Wasatch Front. Salt Lake City is at the heart
of Utah‟s urban corridor. Accordingly, like most Americans, people that
live and work in Salt Lake City spend,
on average, 80% to 90% of their time indoors (reference 1). That makes
indoor environmental quality (IEQ) have a very significant influence on
health, productivity, and quality of life.
In general and nationwide, indoor environmental quality (IEQ) is an
important public health issue. Its absence- often through benign
neglect- can lead to widely publicized problems such as sick building
syndrome, building-related illness, and multiple chemical sensitivity.
IEQ problems are estimated to effect more than 10 million workers in up
to 30 percent of buildings in the United States alone, resulting in billions
of dollars of decreased productivity, litigation, and adverse publicity
(reference 2). Locally, highly publicized problem buildings such as
Riverton Elementary School, have heightened the awareness of IEQ for
building owners and occupants.
The concept of IEQ embraces much more than indoor air quality (IAQ),
a very important subcategory of IEQ. In addition to IAQ, IEQ includes:
thermal comfort, illumination, acoustics, occupant‟s self-determination of
comfort through more customized control of building systems,
daylighting, and views. Consideration of all these factors and how they
affect people‟s comfort and health is part of IEQ. A fundamental
recommendation of the IEQ workgroup is for Salt Lake City to raise the
bar for all projects so that indoor environments attain the highest levels
of health and comfort. To do otherwise ignores the numerous “bottom
line” health, comfort and business benefits of good IEQ.
In summary form, the following are the most impressive findings of the
financial value of health, productivity and human performance benefits of
high performance building and good IEQ (reference 14):
Absenteeism reductions to 40%
Far fewer complaints about IAQ
Office productivity increases up to 16%
Increased market value up to 100%
Overall paybacks under 1 year
ROI up to 1000%
Up to 40% increased retail sales
Up to 26% increased learning rates (in schools)
Up to 90% decreased energy costs
Up to 73% decreased O&M costs
Recently, psychologist Judith Heerwagen (reference 18) authored an
excellent, well referenced review article that provides additional
insight to the beneficial linkages between sustainable building design
and organizational performance. She concludes that:
Green buildings are relevant to business interests across the
full spectrum of concerns, from portfolio issues to enhanced
quality of individual workspaces.
Because the potential influence of green buildings is broad,
research on green buildings should address a range of
outcomes rather than focusing narrowly on just a few.
Outcomes of interest to organizations include workforce
attraction and retention, quality of work life, work output, and
Green buildings can provide both cost reduction benefits and
value added benefits. The emphasis to date, however, has
been on costs, rather than on benefits. The need for more data
underscores the importance of studies that focus on these
human and organizational factors.
The benefits of green buildings are more likely to occur when
the building and organization are treated as an integrated
system from the start.
The people that live and work in Salt Lake City are currently
enjoying many of these benefits but also have ample opportunity to
expand these benefits in the future and become a model IEQ
community in Utah and the intermountain west.
Examples of Utah buildings that can be cited as models of good IEQ
are those that are compliant with State Environmentally Responsible
Guidelines for energy conservation (reference 16) include:
DOT Operations Building
Davis County Court House
USU Widtsoe Hall Chemistry Building
DATC Medical Building
State Mental Health Facility Forensic Hospital
The Olympic Oval built for the Olympic Winter Games of 2002 is a
LEED certified building. Points were awarded for excellence in
sustainable site and exterior features as well as for indoor
environmental quality and energy conservation achievements.
The Utah Department of Natural Resources Building is a good
example of how the benefits of daylighting can be realized.
Clearly, Salt Lake City has abundant opportunity for the future
considering that 75 percent of the buildings worldwide that will be
in existence in 2030 have not yet been built (reference 13). If
major building modification is considered, the opportunity is even
In the near term, office vacant space in Salt Lake County is on the
rise- 12.09% in December 2001 up from 5.7% in December 1997
(reference 23). This means that landlords are starting to give
more concessions- whatever it takes to attract tenants. The
availability of “green” office space in Salt Lake City could be a
differentiator and deciding factor for potential tenants to elect to
locate in Salt Lake City.
With these benefits and examples in mind, recommendations
have been tailored to consider the opportunities, constraints, and
resources special to Salt Lake City. In some areas, for example
humidity control and building security, the recommendations are
more encompassing than the LEED guidelines (reference 1).
1. Minimum IAQ Performance (Prerequisite 1)
Establish minimum indoor air quality (IAQ) performance to prevent
the development of indoor air quality problems in buildings,
maintaining the health and well being of the occupants.
Prerequisite 1.0: Meet the minimum requirements of voluntary consensus
standard ASHRAE 62-1999, Ventilation for Acceptable Indoor Air Quality
and approved Addenda.
Provide a letter from the mechanical engineer stating compliance with
Declare the ASHRAE 62-1999 procedure employed in the IAQ
analysis (Ventilation Rate Procedure of Indoor Air Quality Procedure)
and include design criteria with assumptions
Technologies & Strategies
Design the HVAC system to meet the ventilation requirements of the
reference standard. Identify potential IAQ problems on the site and locate
air intakes away from contaminant sources.
Proposed SLC Plus Credit
EQ-PR1 (1 credit)
Provide a design narrative from the mechanical engineer that
addresses the two following methods of employing evaporative
cooling/humidification and incorporate at least one of the approaches
in the design and installation of the HVAC components and it control
1. Utilize direct evaporative cooling to assist in cooling 100% of
the building supply air when outdoor humidity conditions permit,
and utilize direct evaporative cooling for humidity control in the
2. Utilize direct and indirect evaporative cooling to assist in
cooling 100% of the building supply air when outdoor humidity
Economic Optimal IAQ performance Increasing minimum
results in improved ventilation rates increases
occupant health and energy consumption.
productivity. One study
estimated employee salary
cost at $130 per sq. ft. per
year, while building energy
costs were less that $2 per
sq. ft. per year. Good IEQ
increases the value and
marketability of the
Cultural Good IEQ reduces
potential liability for
architects, engineers and
owners from sick building
Because Salt Lake City and most of Utah is a “high desert”
environment (altitudes above 4000 ft.,) there is almost never a need
to dehumidify outside air used for ventilation. In fact, most of the
time, ventilation air is dryer than building air so it absorbs excess
humidity generated by building occupants. This results in significant
Utah‟s low design wet bulb temperature (generally less than 62
degrees) provides the opportunity to use both direct and indirect
evaporative cooling to condition the outside air used for ventilation, as
well as to provide a significant portion overall building cooling load.
The same evaporative cooling equipment can be used to provide
much needed humidity in winter at minimal cost
Several Salt Lake City mechanical consultants have been
incorporating evaporative cooling into building ventilation systems for
more than ten years
Salt Lake City manufacturer‟s representatives have been supplying
both direct and indirect evaporative cooling systems for over twenty
The temperature inversion that plagues Salt Lake City residents
during the winter months often results in abnormally high levels of
atmospheric pollutants. If minimum outside air ventilation rates are
maintained during these times, higher efficiency filtration should be
installed in building air handling systems. At a minimum, 85% vs. the
generally accepted minimum of 35% efficient filters should be
installed. 85% filters remove 50% of particles greater than 0.3
microns while 35% filters remove less than 5% of the same size
First Cost – more than two dozen SLC office buildings have been
built with indirect/direct evaporative cooling at costs competitive with
designs employing chillers sized to handle the building‟s full cooling
Operating Cost - office buildings incorporating indirect/direct
evaporative cooling typically enjoy 25 to 35% savings in annual
building electrical energy costs. Many chillers run only 10 to 15 days
rather than all summer.
The Salt Lake City office building known One Utah Center utilizes
indirect/direct evaporative plus mechanical cooling. The mechanical
design received the 1995 ASHRAE Technology Award for
The 18 story Gateway Tower West owned by Zions Securities
employs an identical cooling system design.
In addition, Novell operates a number of buildings in Provo that use
indirect, direct evaporative plus mechanical cooling. Not only do
these designs have chillers sized at about 70% of the calculated
maximum cooling load but it has been found that chiller operating
hours are 70 to 75% less than conventional systems.
EA – Credits – Optimize energy performance
2. Environmental Tobacco Smoke (Prerequisite 2)
The enactment of laws banning indoor tobacco smoking
reduces the exposure to both smokers and non-smokers to
chemicals produced by these products. Tobacco smoke is a
mixture of combustion products from cigarettes, cigars, pipes,
and the exhalation of smokers. This smoke contains over
4,000 substances, more than 40 of which are known
carcinogens and many of which are also strong irritants.
Exposure to second hand smoke is estimated by the EPA to
result in an additional 3,000 cancer deaths per year to non-
Utah Code 26-38-1 “The Utah Indoor Clean Air Act” prohibits the
possession of lighted tobacco products in enclosed places of public
access and publicly owned buildings and offices.
Utah Rule R392-510-2 requires employers to establish a policy
that prohibits employee smoking within 25 feet of any entrance,
exit, open window, or air intake of a building where smoking is
prohibited. Exceptions are the Salt Lake City Airport, bars,
taverns, and private clubs.
Utah Department of Health
288 North 1460 West, 2nd Floor
Salt Lake City UT 84114-2103
Salt Lake Valley Health Department
Environmental Health Division
788 East Woodoak Lane
Murray UT 84107
Utah Tobacco Prevention and Control Program
National Cancer Institute
The State of Utah already has in place a comprehensive Indoor
Clean Air Act that restricts exposure to second-hand tobacco
All public access and publicly owned buildings and offices in the State
of Utah are under the jurisdiction of the Act and Regulation in place.
Prohibit the use of all lighted tobacco products inside buildings and
within 25 feet of building entries or air intakes in accordance with the
Utah Indoor Clean Air Act.
3. Carbon Dioxide Monitoring (Credit 1)
Provide Demand Ventilation control strategies which vary outside air
introduced into the facility to match the occupant load by monitoring carbon
dioxide in the occupied space.
Credit 1.0 (1 point): Install a permanent carbon dioxide (CO2) monitoring
system that indirectly measures space ventilation performance and
provides feedback to the introduction of outside air to dilute and remove
human bioeffluents and other occupant generated odors and
contaminants. Specify initial operational set point parameters to
maintain a maximum inside to outside differential of 700 ppm CO2.
Technologies & Strategies
Design the HVAC automatic temperature control system with carbon
dioxide sensors and integrate these sensors with the building outside air
ventilation system. The control sequence should introduce outside air into
the occupied space to maintain a maximum inside to outside differential of
700 ppm CO2.
Recommended outside air ventilation rates are typically based on a “per
occupant “ basis because the contamination is presumed to be in
proportion to the number of occupants in the space. Airflow of outside air
brought into a building may be continually adjusted throughout the day to
match the occupant load.
Economic Benefits derived from reduction in volumetric air flow of outside
air required to dilute and remove human bioeffluents and other odors
associated with human occupancy. Maximum benefits may be obtained in
a facility with highly variable occupancy where the occupants only work in
the building for a few hours each day. Minimum benefit would be obtained
in a facility where contaminants generated are independent of human
occupancy and require continuous ventilation for dilution and removal of
those contaminants (e.g. formaldehyde, carbon monoxide from unvented
The following facilities with variable occupancy would be obvious
Worksite where employees come into the facility for only a few
hours each day.
Worksite where employees have large overlapping shift
· any meeting hall such as school auditorium
actual occupant densities differ significantly from original design
The equipment required to achieve this credit is readily
available from all major companies providing automatic
temperature control equipment.
This strategy should never be employed where the generation
of contaminants (unrelated to human occupancy) may exceed
concentrations known to impair health or cause discomfort.
Only comfort odor criteria will likely be satisfied with this
This strategy may be compromised if the supply of outdoor air
This strategy should not be employed if the required equipment
(sensors, dampers, etc.) is not operated per the original design
intent and not maintained to perform to the original design
intent. For example, the carbon dioxide sensors require
periodic maintenance and calibration.
4. Increase Ventilation Effectiveness (Credit 2)
Provide for the delivery and mixing of fresh air to support the health, safety,
and comfort of building occupants.
Credit 2.0 (1 point)
For mechanically ventilated buildings, design ventilation systems that result
in air change effectiveness (E) greater than or equal to 0.9 as determined
by ASHRAE 129-1997. For naturally ventilated spaces, demonstrate a
distribution and laminar flow pattern that involves not less than 90% of the
room or zone area in the direction of air flow for at least 95% of the hours of
For mechanically ventilated buildings, provide a report summarizing
test results and calculations demonstrating that the designed building
has an air-change effectiveness value of 0.9 or greater as determined
by ASHRAE 129-1997, Appendix B. If E is less than 0.9, provide
documentation indicating the corrected design ventilation rate
(CDVR) used in the system design.
For mechanically ventilated buildings, provide a design narrative that
describes the compliance with the recommended design approaches
in ASHRAE Fundamentals Chapter 31, Space Air Diffusion design as
described in the calculation details of this credit.
For naturally ventilated spaces, provide airflow simulation results
including locations of inlets, outlets, and flow patterns. Provide a
narrative with graphics describing sequence of operations of the
ventilation system and demonstrate that distribution and flow patterns
in all naturally ventilated spaces involve at least 90% of the room or
zone area in the direction of air flow for at least 95% of the hours of
The minimum values for ventilation air rates in a space are determined by
ASHRAE 62-1999 as part of EQ Prerequisite 1. EQ Credit 2 enhances the
minimum outdoor air quality requirements by ensuring that proper
ventilation is delivered to the building occupants. In general, this credit
rewards the employment of architectural and mechanical system design
strategies that increase ventilation effectiveness and prevent short-
circuiting of airflow delivery. Ventilation effectiveness refers to the
movement of supply air (that contains outdoor air) through the occupied
There are two approaches to ventilating buildings: mechanical ventilation
and natural ventilation. Mechanical ventilation strategies use fan energy to
ventilate occupied spaces. Mechanical systems provide high reliability and
control. Conversely, natural ventilation strategies take advantage of
physical properties of the building design and site such as stack effects,
operable windows, and site wind patterns to ventilate occupied spaces.
Natural ventilation provides a connection to the outdoors and has low
operation and maintenance costs. Project teams should evaluate the
strengths and weaknesses of the two approaches and include client
preferences in the final decision for ventilation systems.
The referenced standard describes a test method for quantifying the air
change effectiveness (E) for a given room design. The measured value is
influenced by the shape of the room, the extent of mechanical recirculation,
the location of heat generating objects, and air motion. Because these
variables are highly specific to each design, a full-scale mock-up is the
most effective way to verify E with a high level of confidence. See the
referenced standard for more information on the prescribed testing
It is important to note that testing under ASHRAE 129 is suitable only for
laboratory-based conditions and is not appropriate in most field
applications. ASHRAE states “the test method has been used successfully
in laboratory test rooms to study the performance of different ventilation
systems, but there is considerably less experience in the field where many
factors can complicate the measurement process and increase
measurement uncertainties. Therefore, the standard places strict limitations
on the characteristics of the spaces that can be tested with this method.
While the test method will not be usable in all field situations, it is generally
applicable in laboratory test rooms.” ASHRAE also states that the data set
of current test results is very small, and the test requires very close
attention to the protocol described in the standard, factors that contribute to
some uncertainty when evaluating test results. Therefore, the standard
should be used as a guide to increase ventilation effectiveness.
Conventional ventilation designs locating supply and return air vents in the
ceiling are discouraged in place of natural ventilation designs and
displacement ventilation designs that locate air supply vents at the bottom
of the occupied space and return vents at the top of the space. For
conventional mixing HVAC systems, ASHRAE Fundamentals Chapter 31,
Space Air Diffusion lists the 5 major types of outlet types: Group A,
mounted near the ceiling discharging horizontally; Group B, mounted in or
near the floor discharging a vertical non-spreading jet; Group C, mounted
in or near the floor discharging a vertical spreading jet; Group D, outlets in
or near that discharge horizontally; and Group E, mounted in or near the
ceiling projecting vertically. Each of these types has strengths and
weaknesses depending on the load conditions. See the ASHRAE chapter
There are several new applications for mechanical ventilation systems in
the market today that are very effective at preventing short-circuiting of
airflow delivery. These applications include the use of displacement
ventilation, low velocity ventilation, and plug flow ventilation such as
underfloor or near-floor delivery.
The following diagram illustrates an underfloor ventilation system. Supply
air is introduced through diffusers and grills in the floor. The air travels
upward through the occupied space and is exhausted in return grills in the
ceiling. The underfloor plenum can also be used as a cabling conduit.
Natural ventilation strategies rely on openings in the building envelope to
develop building air flows. Operable windows are the most common
architectural strategy to create natural ventilation, cross ventilation, and
stack effects. Application of operable windows and other openings as
elements of the ventilation system requires analysis of inlet and outlet
locations and sizes. Operable windows combined with fan-powered mixing
boxes do not qualify under this credit with a demonstrable architectural
strategy for natural ventilation. Other factors to consider in the building
ventilation design scheme include windows, doors, non-powered
ventilators, and building infiltration. Computer models are helpful to predict
ventilation processes and determine the best location for ventilation
elements. For gross studies, a water table can be used to study one-
Proposed SLC Plus Credits
No other credits are proposed for this section
Salt Lake City‟s “high desert” environment (see the discussion in
Opportunities in EQ Prerequisite 1) enables the use of direct and
indirect evaporative cooling to provide a significant portion of the
overall building cooling load. For all but about three weeks during the
summer, this system can provide 62 to 63 degree supply air used by
underfloor air distribution designs without using mechanical
Manufacturers of underfloor and displacement type air distribution
systems and components such as Halton, Trox, and York can provide
design guidelines and other tools to assist the mechanical engineer
with the design of systems.
The environmental issues referred to in the LEED discussion state
that “increased ventilation in buildings typically requires additional
energy use…” This is much less of a factor in Salt Lake City because
of our low humidity levels in the summer.
There are no local constraints that would appear to effect the
implementation of increased ventilation effectiveness.
First Cost – If underfloor air distribution systems are designed into the
building from its inception, and full advantage is taken of the modular
approach to electrical power, telephone and computer systems, then
first cost can be competitive with conventional overhead air
Operating Cost - office buildings with frequent tenant “turn” will enjoy
significant saving over overhead air distribution because of the ease
of rearranging the air distribution components to accommodate
varying tenant requirements.
The use of underfloor ventilation, which is the most straightforward
way to qualify for the LEED credit, has been used on a handful of
projects in Salt Lake City, so some limited examples are available.
EA – Credits – Optimize energy performance
EQ – Credit 8 – Daylight and Views
5. Construction IAQ Management Plan (Credit 3)
Prevent indoor air quality problems resulting from the
construction/renovation process, to sustain long-term installer and
occupant health and comfort.
Develop and implement an Indoor Air Quality (IAQ) Management Plan for
the construction and preoccupancy phases of the building as follows:
Credit 3.1 (1 point): During Construction meet or exceed the minimum
requirements of the Sheet Metal and Air Conditioning National Contractors
Association (SMACNA) IAQ Guideline for Occupied Buildings under
Construction, 1995, AND protect stored on-site or installed absorptive
materials from moisture damage, AND replace all filtration media
immediately prior to occupancy. Filtration media shall have a Minimum
Efficiency Reporting Value (MERV) of 13 as determined by ASHRAE 52.2-
Credit 3.2 (1 point): Conduct a minimum two-week building flush-out with
new filtration media at 100% outside air after construction ends and prior to
occupancy, OR conduct a baseline indoor air quality testing procedure
consistent with current EPA Protocol for Environmental Requirements,
Baseline IAQ and Materials, for the Research Triangle Park Campus,
Technologies & Strategies
Adopt an IAQ management plan to protect the HVAC system during
construction, control pollutant sources, and interrupt pathways for
contamination. Sequence installation of materials to avoid contamination of
absorptive materials such as insulation, carpeting, ceiling tile, and gypsum
wallboard. Prior to occupancy, perform a two-week building flushout or test
the contaminant levels in the building.
Good indoor air quality (IAQ) is a very important component of good
indoor environmental quality. The benefits of good IAQ are numerous and
mentioned elsewhere in this chapter narrative. Conversely, the penalties
and consequences of poor IAQ can be devastating to building occupants
Assuming good IAQ building design, the opportunity for achievement
of sustained high quality IAQ begins during the construction or
renovation of buildings. Clearly, good construction phase IAQ
practice benefits construction workers and installers. In addition, the
benefits of good IAQ practice during construction and preoccupancy
phases of the building provide an important first step for achievement
of sustained long-term occupant health and comfort. Nothing can be
worse for building owners than a building being labeled as “sick”
before the doors open. The concept of a construction IAQ
management plan has everything to do with preventing IAQ
problems resulting from the construction/renovation process.
A construction IAQ management plan is viewed as an essential and
relatively easy to achieve high performance building requirement for
Salt Lake City. The construction IAQ management plan is a
relatively low cost, low risk and high value item that can result in
improved IEQ in Salt Lake City almost immediately.
Suggested SLC Policy:
Establish the requirement for a construction IAQ management plan
in Salt Lake City.
Building construction processes invariably include activities that
contaminate the building during construction. Often, these activities
result in residual building contamination that continues to impact IAQ
over the lifetime of the building. Fortunately, construction
management strategies can be instituted during construction and
before occupancy to minimize the potential for building
contamination and to remediate or clean up any contamination that
Therefore the primary benefits of developing and complying with a
construction IAQ management plan are:
Economic Avoid the potentially huge cost and liability
associated with sick building syndrome
and building related illness
Health of construction workers
Long –term health and comfort
The LEED IEQ Credit 3, “Construction IAQ Management Plan”
(reference 1) provides essential requirements, submittals, and
standards for development and proof of a construction IAQ
The Sheet Metal and Air Conditioning Contractors‟ National
Association (SMACNA) IAQ guidelines (reference 8)
(http://www.smacna.org) must be achieved or exceeded.
American Society of Heating Refrigeration and Air Conditioning
Engineers (ASHRAE), http://www.ashrae.org
U.S. Environmental Protection Agency, http://www.epa.gov/rtp/new-
Utah Department of Environmental Quality,
Occupational Safety and Health Administration (OSHA) Technical
Center, 1781 S 300 W, Salt Lake City, UT, 84115-0200
With Utah and Salt Lake City envisioned as a growing community,
development of the built environment will likely proceed at a pace
that exceeds the national average. Therefore, establishment of a
construction IAQ requirement will have a significant positive impact
on the overall achievement of superior and award winning IEQ in
Salt Lake City.
Construction companies may be reluctant to extend construction
schedule to perform 2- week flush out or baseline IAQ testing.
IAQ testing may reveal problems requiring corrective action,
further delaying building occupancy date.
Preparation and execution of IAQ management plan may be new
for many construction companies. The benefit of change may be
difficult to understand for some.
Both the preparation and execution of a construction IAQ
management plan including the 2-week washout or baseline IAQ
testing will clearly add to the cost of construction. On the other hand,
the principal, “an ounce of prevention is worth a pound of cure”
applies. The cost of baseline testing may be imbedded as part of the
cost of an overall building commissioning evaluation.
Examples and Images:
The Olympic Oval received LEED credit for protected indoor air
quality during construction. The air handling system, including
ductwork, was protected during construction to eliminate dust and
other contaminants that would normally enter the building once the
system was activated. Eighty-five percent filtration rates were
achieved during construction.
Salt Lake City adopts the LEED (reference1) construction IAQ
management plan requirements and submittals as written and in
6. Low-Emitting Materials (Credit 4)
The use of low-emitting materials provides for healthier indoor
environments for building occupants and visitors by reducing
potentially irritating, odiferous, or noxious contaminants. Low-
emitting materials will prevent indoor air quality problems such as
“sick building syndrome” and eliminate future mitigation costs for
such potential problems. Mitigation costs for contaminant clean up
are much greater than are prevention costs.
The use of low-emitting materials will encourage the production of
such materials locally. Additionally, the use of low-emitting
materials will enhance the image of Salt Lake City for
South Coast Air Quality Management District (SCAQMD) Rule
#1168and Bay Area Air Quality Management District (BAARB)
Regulation 8, Rule 51.
Adhesives used must meet or exceed the VOC limits of the
South Coast Air Quality Management District (SCAQMD) Rule
South Coast Air Quality Management District
1. 21865 E. Copley Drive
Diamond Bar CA
Product VOC Limit (mg/m2/hr)
Carpets Total VOC‟s 0.50
Adhesives Total VOC‟s 10.00
Cushion Total VOC‟s 1.00
Adhesives used must meet or exceed the VOC limits of the Bay
Area Air Quality Management District (BAARB) Regulation 8,
Sealants VOC Limit(g/L)
Roofing Material Installation 450
PVC Welding 480
Sealant Primer VOC Limit(g/L)
Architectural (non-porous) 250
Architectural (porous) 775
Provide a cut sheet and a Material Safety Data Sheet (MSDS)
for each adhesive used in the building highlighting the VOC
Green Seal Requirements for Paints and coatings.
Paints and coatings used must meet or exceed the chemical
limits of the Green Seal Requirements.
Paint VOC Limit (g/L)
Green Seal :
1001 Connecticut Avenue, NW, Suite 827
Washington, .C. 20036-5525
Provide a cut sheet and a Material Safety Data Sheet (MSDS)
for each paint or coating used in the building highlighting the
VOC and chemical component limits.
The Carpet and Rug Institute Green Label Indoor Air Quality Test
Carpets used must meet or exceed the Carpet and Rug
Institute Green Label Indoor Air Quality Test Program limits.
Product VOC Limit (g/L)
Welding & Installation
Non-vinyl backed insulation 150
Carpet pad installation 150
Wood flooring installation 150
Ceramic tile installation 200
Subfloor installation 200
Rubber floor installation 150
VCT &asphalt tile installation 150
PVC welding 510
CPVC welding 490
ABS welding 400
Plastic cement welding 350
Cove base installation 150
Adhesive primer for plastic 650
All others 250
Metal to metal 30
Plastic foams 120
Porous material except wood 120
Carpet and Rug Institute
Provide a cut sheet and a Material Safety Data Sheet (MSDS)
for each carpet used in the building highlighting the VOC limits.
Composite wood and agrifiber products used must contain no
added urea-formaldehyde resins.
Provide a cut sheet and a Material Safety Data Sheet (MSDS)
for each composite wood and agrifiber product used in the
building highlighting the urea-formaldehyde resin limits.
Materials and contractors available for low-emitting materials are
listed in the Sustainable Building Sourcebook:
Materials cost may increase the initial cost of construction or
renovation using low-emitting materials. Builders may be
unfamiliar with low-emitting product use and availability. Low-
emitting materials may be minimally available or unavailable
The following facilities were constructed using “green building” design
Utah Olympic Oval, Salt Lake City
E-Center, Salt Lake City
Center for Environmental Health, Salt Lake Valley Health
Procure and use only low-emitting materials for new building
construction and remodeling projects.
Use the standards and recommendations described by the referenced
organizations to identify low-emitting materials.
7. Indoor Chemical & Pollutant Source Control (Credit 5)
[Note: -I relied heavily on LEED but I think that it misses many potential
indoor air contaminant issues. Issues that are likely addressed in other
sections but are indoor air pollutants and deserve at least mention in a
section entitled „Indoor Chemical and Pollutant Source Control.‟ We may
just want to mention potential contaminant sources and reference to
appropriate section or credit for proper design, control and/or management
– After a quick scan of ASHRAE 62-1999 (prerequisite 1) some of my
concerns were addressed:
Section 5.4 – Design of ventilation systems to prevent re-entrainment of
exhaust contaminants and outdoor sources of contamination (including
– This section also addresses buildings on soils with high radon content.
Microbiological growth –section 5.5 and section 5.10 High humidity and
proper ventilation for bathrooms
And 5.11 stagnant water in HVAC systems
Section 5.6 control of contaminants from stationary sources
Section 5.7 addresses fuel-burning appliances.
It seems that single pass ventilation for chemical storage; housekeeping is
likely in ASHRAE 62-1999 or other ASHRAE standard.
Refer to credit on low emitting materials
Radon deserves special mention. Radon is a naturally occurring
radioactive gas that is not detectable by the human senses. Because
radon is chemically un-reactive with most materials, it is free to travel as a
gas. Radon is found virtually everywhere in at least small amounts. Most
indoor radon comes from the rocks and soil around and under a building or
home. An increased risk of developing lung cancer is the only known
health effect associated with elevated concentrations of radon.
The Indoor Radon Abatement Act of 1988 (reference 22) establishes a
long-term national goal of achieving radon levels inside buildings that are
no higher than those found in ambient air outside of buildings. Utah‟s
Indoor Radon Program goal is to reduce the level of indoor radon in the
state of Utah to concentrations less than the Environmental Protection
Agency‟s (EPA) action level of 4 pCi/L (pico-Curies per liter) (reference 19).
While it is not currently possible to make a precise prediction of indoor
radon potential for a specific building site, a general assessment, on a
statewide, county, or grouping of counties basis, can be made by referring
to EPA‟s Map of Radon Zones and other locally available data (reference
17). In Utah, test results by postal Zip code are available (reference 19).
Some radon potential exists in all areas. However, EPA recognizes that
based on available data, there is lower potential for elevated indoor radon
levels in some states and portions of some states, and that adoption of
building codes for the prevention of radon in new construction may not be
justified in these areas at this time (reference 17).
Within Salt Lake City limits the potential for elevated indoor radon levels is
low (reference 20). Therefore, the IEQ workgroup does not recommend an
across the board, routine requirement for radon-resistant construction
techniques in Salt Lake City. However, the IEQ workgroup does
recommend that specific building sites be evaluated for radon potential
based on review of Utah‟s radon database or consultation with Utah‟s
radon program coordinator, Mr. John Hultquist. Based on this review,
building owners can decide whether or not radon resistant construction
(reference 17 and 21) is warranted.
Designing and constructing buildings to avoid generation of indoor air
contaminants or cross contamination will contribute to superior indoor air
quality. Clean healthy air is necessary for health productive building
occupants and conversely poor indoor quality negatively impacts building
occupants, decreases worker productivity and often results in costly indoor
environmental quality investigations and remediation.
NIOSH Building Air Quality Action Plan http://www.cdc.gov/niosh/98-
123a.html (includes guidance for ongoing preventative maintenance)
EPA Indoor Air Quality Hotlines and Resources
Check out green housekeeping web site listed in LEED
Sources for slc?
“Radon Prevention in the Design and Construction of Schools and Other
Large Buildings”, U.S. EPA, Document #625-R-016, June 1994.
UDEQ Radon Hotline 1-800-458-0145
Radon predictions maps by counties, http://eande.lbl.gov/iep/high-
Radon information, http://www.physics.isu.edu/radinf/radonpubs/htm
Can not think of opportunity for SLC with respect to indoor air pollutants.
Except perhaps episodes of poor ambient AQ.
Additional materials and energy may be needed to provide entryway
systems and isolate chemical use areas.
Ongoing preventative maintenance is critical for maintaining acceptable
indoor air quality.
A written preventive maintenance program is an effective tool for improving
IAQ. The plan should include monitoring, inspecting and cleaning HVAC
components such as outside air intakes, outside air dampers, air filters,
drain pans, heating and cooling coils, the interior of air handling units, fan
motors and belts, air humidification, controls and cooling towers. Pages
34–36 of the Building Air Quality guide contain general information on
maintenance activities while pages 123–137 detail specific HVAC
components, their role in IAQ, and instructions for preventive maintenance.
From EPA/NIOSH reference.
Examples and Images
Insert LEED Credit 5
Design to minimize cross contamination of chemical and other pollutants.
Employ permanent entryway systems (grills, grates, etc.) to capture dirt
particulates, etc. from entering the building at all high volume entryways,
AND provide areas with structural deck to deck partitions with separate
outside exhausting, no air recirculation and negative pressure where
chemical use occurs (including housekeeping areas and copying/print
rooms), AND provide drains plumbed for appropriate disposal of liquid
waste in spaces where water and chemical concentrate mixing occurs.
Specific Recommendations to the City that would enable success of
LEED? FROM LEED
Exterior Entry Ways
Design all exterior entrances with permanent entryway systems (e.g.
grilles and grates) to catch and hold dirt particle and prevent
contamination of building interior.
Design exterior surfaces to drain away from building entrances.
Landscape design at entrances should be low maintenance and pest
control based on integrated pest management to avoid use of
Water spigot and electrical outlet should be located at entryways for
maintenance and cleaning activities.
Physically isolate occupant activities associated with chemical use through
proper building and ventilation design. Isolation includes:
Adequate and secure storage of housekeeping chemicals, HVAC
maintenance chemicals, photo processing chemicals or any other
chemical sources within the building. Recycling areas may secure store
depending on what materials are recycled.
Isolate sources of chemicals from general building ventilation through
floor to deck partitions, dedicated exhaust systems with no recirculation,
and negative pressure.
Ensure discharge points for exhaust systems are located away (need
more specific requirement is this in ASHRAE?) from HVAC system air
Institute operation and maintenance programs to ensure effective and
Note: Text in italics is either directly from LEED or paraphrased from
8. Controllability of Systems (Credit 6)
Provide a high level of individual occupant control of thermal, ventilation,
and lighting systems to support optimum health, productivity, and comfort
Credit 6.1 (1 Point): Provide a minimum of one operable window and one
lighting control zone per 200 s.f. for all occupied areas within 15 feet of the
Credit 6.2 (1 Point): Provide controls for each individual for airflow,
temperature, and lighting for 50% of the non perimeter, regularly occupied
Credit 6.3 SLC (1 Point): Provide an opening limit device for all operable
windows within 42" of the floor, limiting an opening width to a dimension
through which a 4" diameter sphere cannot pass.
Credit 6.4 SLC (1 Point): Provide sensors and controls which meet
ASHRAE 55a-1995 requirements for comfort.
Credit 6.5 SLC (1 Point): Provide commissioning of building systems per
Credit 6.6 SLC (1 Point): Provide preventive maintenance guidelines per
Credit 6.7 SLC (1 Point): Provide a system of baffles at operable windows
to assist with acoustical control of outdoor sounds getting inside.
energy savings wasted energy
quantifying the environmental performance dependance on fossil
guidelines for designers undesired space
a rating system
individual lighting control
level of sustainability
more productive work
more comfortable surroundings
good green design
1. Standards challenge designers to do their job with the building
users in mind.
2. Salt Lake City has the climate conditions, which allow the
introduction of individually controlled light and air, due to the long
periods of temperate weather.
3. Using operable windows, because of the dry humidity, all one
need do is control the wind to be warm in winter in the sun, or cool in
summer, in the shade.
4. New products are available that allow individual control of air
grilles in rooms.
5. Designers have the opportunity to do thoughtful designs.
6. Building users have the opportunity to live, work, or play in
7. Building owners have the opportunity to achieve cost reductions
in energy use.
8. Motion sensors can turn off lights when people leave spaces.
9. Salt Lake designers already have experience meeting
environmental design criteria if they have worked on state projects.
10. Experience has shown that designers need no other impetus
than the requirement to meet sustainable criteria.
11. Salt Lake needs only to issue environmental design criteria and
builders, developers, and designers will create sustainable projects
with individually controlled HVAC systems, lighting, and windows.
Leadership in Energy and Environmental Design, Green Building
Harvard Business Review, Magretta, 1997
National Oceanic and Atmospheric Administration
Environmental Design Guidelines, Utah State Building Board
Utah Division of Facilities Construction and Management
Fairfax Co., VA, Annual Report on the Environment 2000
Metropolitan Washington Council of Governments, Meeting
Highlights, March 8, 2000, January 10, 2001, March 14, 2001, June 11,
When individuals are given control of their environment, they
need to be carefully instructed in the use of the controls.
Heating, ventilating, and air conditioning (HVAC) and lighting
controls need to be designed to link the individual controls to
the building systems, i.e. when daylight is exceeding the design
light level of the artificial lighting, sensors can ramp down the
artificial lights, saving energy.
With operable windows, sensors need to tell if individuals have
left windows open, thereby adjusting HVAC systems to
recognize the temperature of the fresh air being introduced.
The Computer Power Technology Building, 3949 S. 200 E. offers their
office staff individual air louver controls with an under floor air distribution
Virtually every home in Salt Lake has operable windows, but few if any
have sensor links to HVAC systems.
9. Thermal Comfort (Credit 7)
Provide for a thermally comfortable environment that supports the
productive and healthy performance of the building occupants. Thermal
comfort as defined by ASHRAE is “that condition of mind that expresses
satisfaction with the thermal environment”.
Credit 7.0 (1 point): Design, operate and maintain the facility to comply
with the intent of ASHRAE Standard 55-1992 - Thermal Environmental
Conditions for Human Occupancy (ANSI approved).
Technologies & Strategies
Design, operate and maintain all building systems which affects the four
measured elements essential to compliance with the intent of ASHRAE
Standard 55-1992. The four measured elements are temperature, thermal
radiation, humidity and air speed in the occupied space. Building systems
which affect thermal comfort are not limited to heating, ventilating and air-
conditioning systems, but also include building envelope, ceiling height, etc.
Providing occupants with a thermally comfortable environment is an
important aspect of indoor environmental quality. A comfortable work
environment supports productive and healthy performance.
Utah‟s dry climate provides the following opportunities:
Excess humidity is generally not a concern, in terms of
Evaporative cooling is widely employed during the summer and
the same equipment may be used during the dry heating
season as a moisture source to meet humidification
During cooling season, HVAC equipment can be operated
during nightime hours to flush the building with 100% outside
air in order to remove lagging daytime heat gains. This method
is typically not used in humid environments where the building
would absorb the latent heat load from the outside air flush.
ASHRAE Standard 55-1992: Thermal Environmental
Conditions for Human Occupancy
Addendum 55a-1994 to ASHRAE Standard 55-1992:
Thermal Environmental Conditions for Human Occupancy
ASHRAE Fundamentals Handbook-2001: Chapter 8,
State of Utah Building Board, Environmentally responsible
Guidelines, May 17, 1996; Section 5.1 Thermal quality
Enforcement of future energy conservation measures
may require the facility to be operated outside the
recommended temperature/humidity envelope of
ASHRAE 55-1992. If energy conservation
recommendations are ignored, then energy consumption
will not be reduced and energy costs will increase.
In some facilities with marginal cooling capacity, following
the operating set points of thermal comfort in ASHRAE
55-1992 may compromise indoor air quality. For
example, in midsummer, automatic temperature control
strategies shut outside air dampers in order to dedicate
cooling capacity to removing facility heat gains rather than
conditioning outside air.
The addition of humidification equipment to meet the
intent of the ASHRAE Standard 55-1992 may result in
deleterious microbial activity if the equipment is not
properly operated and maintained.
Professionals who use ASHRAE Standard 55-1992 must
understand that the temperature range recommendations
are “operative” temperatures which include a radiative
component. Simple dry bulb temperatures will not suffice
if measuring space temperatures near a cold or hot wall
where the occupant is experiencing a radiative heat
exchange with the wall.
10. Daylight and Views (Credit 8)
Create indoor environments which enhance occupant productivity
and comfort by providing natural light gathering windows with well
thought-out views to the outdoors.
Credit 8.1 (1 Point): Achieve a minimum Daylight Factor of 2%
(excluding all direct sunlight penetration) in 75% of all space occupied
for critical visual tasks, not including copy rooms, storage areas,
mechanical, laundry, and other low occupancy support areas.
Credit 8.2 (1 Point): Direct line of sight to vision glazing from 90% of
all regularly occupied spaces, not including copy rooms, storage
areas, mechanical, laundry, and other low occupancy support areas.
Credit 8.3 SLC (1 Point): Provide glass with high daylight
transmittance (50% 0r higher) and low shading coefficients on north
facades. Provide glass with low daylight transmittance (50 % or
lower) and high shading coefficients on east, west, and south
facades, and/or provide shading devices, ie: overhangs, light shelves,
or vertical fins, (resulting in a minimum daylight factor of 3.0 % on the
work plane at a depth of 15 feet) yielding day lighting availability to a
depth of 30 feet.
energy savingswasted energy
electric lighting need is reduceddependance on fossil fuels
more productive work
guidelines for designers
nationally recognized level of sustainability
good green design
quantifiable environmental performance
minimum Daylight Factors
a healthier populace
more comfortable surroundings
direct line of sight to vision glazing
1. Salt Lake City has the best of opportunities for utilizing design
approaches that take advantage of natural daylighting.
2. From the Great Salt Lake to the Wasatch Mountains to the
Oquirrhs, there are beautiful views that give us a visual
connection to the great outdoors.
3. As important as the views out, is the natural light coming in.
4. Both these features enhance our feeling of well being as well as
reducing the use of energy.
5. Design features such as roof monitors, skylights, light shelves,
reflective surfaces and redirected day lighting contribute to
good interior natural lighting.
6. Salt Lake designers already have experience meeting
environmental design criteria if they have worked on state
7. Experience has shown that designers need no other impetus
than the requirement to meet sustainable criteria.
8. Salt Lake needs only to issue environmental design criteria and
builders, developers, and designers will create sustainable
projects with well conceived, natural, controlled day lighting
providing great views.
1. Leadership in Energy and Environmental Design, Green
2. Harvard Business Review, Magretta, 1997
3. EDA Architects
4. GSBS Architects
5. Environmental Design Guidelines, Utah State Building Board
6. Utah Division of Facilities Construction and Management
7. Utah Natural Resources Department, Energy Office
1. Often in both new buildings and in remodeling projects,
existing conditions such as adjacent buildings, mature
landscaping or geographical features may demand
creative design solutions to introduce daylight and give
2. Special care needs to be exercised to control heat gain
when using large expanses of glass, i.e. the Delta Center
designers, by rotating the building 45 degrees, use a
great deal more energy than if it had been orthogonal to
the street grid.
1. The DABC Admin Offices and Warehouse at 1625 S. 900
W. illustrates the use of light shelves.
2. The University of Utah, University Services Building
shows roof monitors.
3. The University of Utah, Rice-Eccles Stadium
demonstrates the importance of views.
4. The Bennett Federal Building at 125 South State is being
retrofitted with light shelves and shading devices.
5. The State Natural Resources Building at 1594 West North
Temple is an example of shading devices and light
6. Saint Thomas More Catholic Church at 3015 East Creek
Road shows shading devices and light shelves.
11. Security (SLC Plus Credit) (Note: The IEQ workgroup
recommends that the scope of the “Security” credit be
broadened to include other security related HPB issues such as
water and be incorporated into Salt Lake City guidelines as a
The horrific attacks of September 11, 2001 coupled with the bio-
terrorism attacks in Florida, New York, and Washington D.C. have
made homeland security a very important “fact of life” for all
Americans. Salt Lake City, as the host city for the Olympic Winter
Games of 2002, is experiencing what it means to be in the highest
state of readiness for acts of terrorism and other disasters.
Protection of skyscrapers and other buildings is among the top ten
actions needed to protect America (reference 24). In that regard,
building security, as it relates to other High Performance Building
attributes, is deemed a new dimension in building performance- one
that should receive attention and credit.
Clearly, there is a connection between building security and IEQ.
Intentionally delivered chemical or biological warfare agents, toxic
industrial chemicals and materials, or combustion products from a fire
are unwanted, acutely hazardous indoor air pollutants. Dealing with
such attacks, once delivered, has everything to do with controllability
of systems. Clearly, the building HVAC system is central to building
security as it relates to IEQ.
Use of building security technology as related to IEQ is an emerging
practice. For example, researchers at the Pennsylvania State
University are working on “immune building” technology for bio-
terrorism defense (reference 24). Clearly, securing mechanical
rooms, blowers, compressors and air filters is crucial. Technologies
such as photo-catalytic air cleaning, originally developed to prevent
mold and mildew problems, are now proving effective for biological
warfare agents such as anthrax (reference 25)
There are no standards referenced for this credit. However, the
intent is to have building security, as it relates to IEQ, considered as
part of the building design, construction, and operation process. To
receive credit, a building owner would submit a written vulnerability
assessment, mitigation implementation, and consequence
management plan as part of the overall High Performance Building
Development of HPBI IEQ Recommendations:
The IEQ volunteer workgroup included: Dr. Joseph Martone, CIH,
QEP (workgroup leader/Battelle); Mr. Royal Delegge (Salt Lake
Valley Health Department); Mr. Archie Phillips (Architect); Ms. Sarah
Wright, CIH (Utahns for an Energy Efficient Economy); Mr. Lyn Felton
(Long Building Environments); and Mr. Lee Hathon (OSHA Technical
Center). Ms. Nina Dougherty (Sierra Club) and Mr. Jeff Burton
served as reviewers. Ms. Lisa Romney (Salt Lake City Corporation)
served as workgroup facilitator. Ms. Kim Fowler and Mr. Steve
Shankle (Pacific Northwest National Laboratory/Battelle); Ms Carol
Werner (University of Utah), Dr. Judith Heerwagen (Battelle), Mr.
Roger Evans (Salt Lake City Corporation) and Mr. Greg Rutledge
(Pacificorp) served as volunteer consultants to the workgroup
members. Mr. Tang Yang, a University of Utah student, assisted the
workgroup with recording and distributing workgroup meeting notes
and with other essential matters. Following the kick-off HPBI task
force workshop held on November 19 and 20, 2001, the IEQ
workgroup convened on many occasions between November 2001
and May 2002 to develop these IEQ recommendations for Salt Lake
1. Leadership in Energy and Environmental Design (LEED)
Reference Package Version 2.0, Chapter 5, “Indoor
Environmental Quality,” U.S. Green Building Council,
2. “Indoor Environmental Quality in Six Commercial Office
Buildings in the Midwest United States,” Reynolds, Stephen J.,
et.al., Applied Occupational and Environmental Hygiene, Vol.16
(11): 1065-1077, 2001.
3. “Greening the Building and the Bottom Line”, Romm, Joseph J.
and Browning, William D., Rocky Mountain Institute.
4. “Environmentally Responsible Guidelines,” Utah State Building
Board, May 17, 1996.
5. “Green College Dorm Evaluation Shows Super Energy
Performance,” Energy Center of Wisconsin, http://www.ecw.org
6. ASHRAE 62-1999, Ventilation for Acceptable Indoor Air Quality.
7. ASHRAE 129-1997, Measuring Air Change Effectiveness.
8. SMACNA IAQ Guidelines for Occupied Buildings Under
9. ANSI/ASHRAE 52.2-1999, Method of Testing General
Ventilation Air-Cleaning Devices for Removal Efficiency by
10. EPA Protocol for Environmental Requirements, Baseline IAQ
and Materials for Research Triangle Park Campus, Section
11. ASHRAE 55-1992, Thermal Environmental Conditions for
12. ASHRAE/IES 90.1
13. “Building a Sustainable Future- An Overview of Alternative
Materials and Methods of Construction,” Eisenberg, David;
Building Standards, September-October 1998.
14. “High Performance Building Delivers Results: Communicating
Productivity Benefits of Sustainable Building to Decision Makers
in the Seattle Development Industry,” Sustainable Demand
Project, Seattle City Light,
a.pdf, December 2000.
15. “The Business Case for Sustainable Design,”
16. Personal communication with Mr. Gaylen Rogers, DFCM,
17. “Model Standards and Techniques for Control of Radon in New
Residential Buildings”, U.S. Environmental Protection Agency,
EPA 402-R-94-009, March 1994.
18. Heerwagen, Judith H., “Green Buildings, Organizational
Success, and Occupant Productivity,” to be published in a
special edition of Building Research and Information, Vol. 28
(5): 1-15., London, UK.
19. Utah‟s Indoor Radon Program and radon database,
20. Personal communication with Mr. John Hultquist, Utah Radon
Program Coordinator, December 28, 2001.
21. “Radon Prevention in the Design and Construction of Schools
and Other Large Buildings,” U.S. EPA, Document #625-R-016,
22. Title III of the Toxic Substances Control Act, TSCA, 15 U.S.C.
23. “More Offices Gathering Dust,” Salt Lake Tribune, Page B-4,
January 3, 2002.
24. “Protecting America- what must be done,” Newsweek, Special
Report, pp 28-40, November 5, 2001.
25. “Air Cleaner Kills Anthrax”, news item provided by Hillary
Brown, December 2001.