A Guide for the Workplace: Forewords

This document is a crucial guide to creating a safer and more productive environment for people affected by environmental sensitivities. It is also a guide to improving indoor air quality for all employees and therefore prevent related indoor air quality problems. It is not only our legal duty, but also our human responsibility to ensure that our fellow workers are provided with an accessible physical environment, as well as one which is open, accepting and free from the harassment so often experienced by people with this disability. Many of these guidelines are not very difficult to implement, if we care.

Michel Joffres, M.D., Ph.D.
Director of Research, Nova Scotia Environmental Health Center
Associate Professor, Department of Community Health and Epidemiology, Faculty of Medicine, Dalhousie University

Occupants in the modern office building have placed their trust in a team of professionals to provide them with a safe, healthy, and comfortable work environment. The architect, engineer, builder, interior designer, property manager and operator all have critical roles to ensure the provision of accommodation with good indoor air quality (IAQ). "Acceptable indoor air quality" is defined as air "with which a substantial majority (80% or more) of the people exposed do not express dissatisfaction". [American Society of Heating, Refrigerating and Air-conditioning Engineers (ASHRAE) Standard 62–2001]. Under ‘continuous maintenance’, ASHRAE Standard 62–2001 has added new addenda recognizing the importance of building and system design, construction, commissioning, operation and maintenance in achieving acceptable indoor air quality.

Let's start with a few true statements: contaminant source control is the most effective way of achieving good IAQ; heating, ventilating and air-conditioning (HVAC) systems must be properly designed, operated and maintained; accidents and failures will happen and an appropriate remediation protocol should be followed which includes good communication; and while it may not be feasible for general ventilation to assure the protection of the most susceptible occupants from all contaminants, there are policies and techniques that can be implemented to reduce the risk of exposure.

The ventilation rate, which is defined as the amount of outdoor air mixed with the supply air, simply dilutes existing indoor pollutants. For good IAQ, it is more effective to avoid or control sources of indoor contamination. It has been demonstrated that most problems in buildings occur because of internal pollutants rather than from insufficient ventilation.

Industrial hygiene practice and the use of "threshold limit values" (TLVs) are not appropriate standards for IAQ in offices. These thresholds are to avoid "adverse health effects" for industrial workers who usually know what chemicals are present and can take protection against exposure. There are also thousands of chemicals present in the office environment, and very few (under 500) have been studied or regulated. It is therefore prudent to control all chemical emissions in the office environment.

While IAQ parameters are measured in the low parts per million range, persons with environmental sensitivities may react to chemical concentrations in the parts per billion range, or even lower. These ranges are below the level of detection of most instruments.

The transition of our economy from an industrial to a knowledge-based workforce underlines the importance of a comfortable and productive workplace. The revised Canada Labour Code and the regulations made under it (as of July, 2000) require that buildings conform to ASHRAE standards, that HVAC systems be properly designed, operated, inspected, tested, cleaned and maintained, and that IAQ investigations be carried out where “the safety or health of an employee in a work place is or may be endangered by the air quality". The anticipated actual net benefits of these revisions in terms of reduced morbidity and mortality are estimated to be $166.6 million over the next 20 years. IAQ assessment protocols and guidelines already exist and have been applied by Public Works and Government Services Canada since 1986.

How can the IAQ be improved for employees with environmental sensitivities? The concerns identified by the person involved should be the basis for the appropriate course of action to be undertaken. It should be noted that it may not always be possible to identify specific triggers due to the large number of potential incitants in our modern office environments and the possibility of synergistic factors. Such a situation may require an iterative approach – eliminating the most likely irritant in consultation with the affected employee and then following up with further actions as needed.

Each situation should be handled on an ad hoc basis, with the cooperation and support of all stakeholders.

The provision of good IAQ and a healthy and comfortable workforce is very cost-effective. Controlling pollutants, understanding the effects of exposure and improving the interior environment for all occupants is a mission for all of us. We must acknowledge heterogeneity and that all people have different degrees of sensitivity and susceptibility to the environment. Accommodating employees with environmental sensitivities is good practice and benefits all society.

Tedd Nathanson, P. Eng.
Manager, Indoor Air Quality, Environmental Services
Public Works and Government Services Canada

More than fifteen years ago, I chaired a committee on environmental sensitivities established by Ontario's Ministry of Health. The committee included two eminent teaching hospital physicians and a highly respected epidemiologist. We issued a report that identified existing, publicly funded means of diagnosis, and accepted various methods of patient management, including avoidance of offending agents.

Equally important in our minds were measures, such as income support, that would provide concrete assistance to members of this vulnerable group and reduce the risk of preventable harm. To this end, we recommended that financial and social support services be awarded on the basis of the extent of a patient's disability, rather than on the basis of a particular diagnosis. This would reduce the risk of depriving patients of support simply because medical professionals might be unable to differentiate between the myriad possible causes. We also called for further research and the development of services to support that research, while also helping those who were experiencing a wide range of very difficult symptoms. We did not feel that more research was needed before these and other measures were introduced to protect patients from being caused harm through inappropriate labelling or the denial of reasonable accommodation.

In the years immediately following the report, several positive steps were taken in response to the recommendations. Public support systems became more accepting of these individuals' needs. At the federal level, departments and agencies began addressing unhelpful attitudes about this disability, not only within the departments and agencies themselves, but also within doctors' offices, medical associations and the broader community. Health Canada organized conferences, distributed documents and publicly supported recommendations to protect patients from unnecessary harm. The Department of Justice and Canada Mortgage and Housing Corporation funded self-help groups to support citizens with environmental sensitivities.

Regrettably, over the past few years, that initial momentum has been largely lost, and many of the earlier recommendations seem to have been forgotten. An ongoing, legitimate, but separate debate about medical approaches is again obscuring protection issues and returning us to the situation that prevailed when the report was written.

Thus, it was with pleasure that I read this workplace guide, Accommodating Employees with Environmental Sensitivities. Its authors have worked hard to provide concrete advice on how a workplace might accommodate employees with this disability. While not all suggestions will be applicable to every workplace, much that is proposed here can and should be done to create a more accommodating work environment, keeping in mind recent developments in human rights jurisprudence. Employers are now required to organize their workplaces so that discriminatory barriers do not exist. I think that the suggestions in this Guide for accommodating employees who have environmental sensitivities will help employers eliminate barriers in the workplace, up to the point of undue hardship. I am particularly impressed with the proposals in the Guide for approaches that make employees partners in the development and implementation of an action plan to deal with this issue in the workplace.

I congratulate those whose hard work produced the Guide and I encourage employers and employees to take advantage of this readable and practical publication.