United States Access Board

IEQ — Indoor Environmental Quality Project

Original post here.

The Architectural and Transportation Barriers Compliance Board (Access Board) is an independent federal agency devoted to accessibility for people with disabilities. The Access Board is responsible for developing and maintaining accessibility guidelines to ensure that newly constructed and altered buildings and facilities covered by the Americans with Disabilities Act and the Architectural Barriers Act are accessible to and usable by people with disabilities.

In November 1999, the Access Board issued a proposed rule to revise and update its accessibility guidelines. During the public comment period on the proposed rule, the Access Board received approximately 600 comments from individuals with multiple chemical sensitivities (MCS) and electromagnetic sensitivities (EMS). They reported that chemicals released from products and materials used in construction, renovation, and maintenance of buildings, electromagnetic fields, and inadequate ventilation are barriers that deny them access to most buildings.

Americans spend about 90 percent of their time indoors, where concentrations of air pollutants are often much higher than those outside. According to the U.S. EPA Healthy Buildings, Healthy People: A Vision for the 21st Century,

"Known health effects of indoor pollutants include asthma; cancer; developmental defects and delays, including effects on vision, hearing, growth, intelligence, and learning; and effects on the cardiovascular system (heart and lungs). Pollutants found in the indoor environment may also contribute to other health effects, including those of the reproductive and immune systems." (p. 4).

"The report further notes that ‘Most chemicals in commercial use have not been tested for possible health effects". (p. 8).

There are a significant number of people who are sensitive to chemicals and electromagnetic fields. Surveys conducted by the California and New Mexico Departments of Health and by medical researchers in North Carolina found 16 to 33 percent of the people interviewed reported that they are unusually sensitive to chemicals.

  • In the California and New Mexico health departments’ surveys, 2 percent to 6 percent reported that they have been diagnosed as having multiple chemical sensitivities C. Miller and N. Ashford, "Multiple Chemical Intolerance and Indoor Air Quality," in Indoor Air Quality Handbook Chapter 27.8 (McGraw-Hill 2001).

  • A California Department of Health Services survey has found that 3 percent of the people interviewed reported that they are unusually sensitive to electric appliances or power lines. P. LeVallois, et al., "Prevalence and Risk Factors of Self-Reported Hypersensitivity to Electromagnetic Fields in California," in California EMF Program, "An Evaluation of the Possible Risks From Electric and Magnetic Fields (EMFs From Power Lines, Internal Wiring, Electrical Occupations and Appliances, Draft 3 for Public Comment, April 2001" Appendix 3.

Individuals with multiple chemical sensitivities and electromagnetic sensitivities who submitted written comments and/or attended the public information meetings on the draft final rule, requested that the Access Board include provisions in the final rule to make buildings and facilities accessible for them.

The Board has not included such provisions in their rules, but they have taken the commentary very seriously and acted upon it. As stated in the Background for its Final Rule Americans with Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities; Recreation Facilities

"The Board recognizes that multiple chemical sensitivities and electromagnetic sensitivities may be considered disabilities under the ADA if they so severely impair the neurological, respiratory or other functions of an individual that it substantially limits one or more of the individual’s major life activities. The Board plans to closely examine the needs of this population, and undertake activities that address accessibility issues for these individuals.

The Board plans to develop technical assistance materials on best practices for accommodating individuals with multiple chemical sensitivities and electromagnetic sensitivities. The Board also plans to sponsor a project on indoor environmental quality. In this project, the Board will bring together building owners, architects, building product manufacturers, model code and standard-setting organizations, individuals with multiple chemical sensitivities and electromagnetic sensitivities, and other individuals. This group will examine building design and construction issues that affect the indoor environment, and develop an action plan that can be used to reduce the level of chemicals and electromagnetic fields in the built environment."

This report and the recommendations included within are a direct outgrowth from that public comment process. The Access Board contracted with the National Institute of Building Sciences (NIBS) to establish this Indoor Environmental Quality Project as a first step in implementing that action plan.

A broad and distinguished Steering Committee was established and met in January 2004 in Bethesda, Maryland, to review the project objectives. Subsequently four task teams (committees) were established to address specific issues in buildings related to Operations & Maintenance, Cleaner Air Rooms, Design and Construction, and Products and Materials. The following reports from these four committees offer recommendations for improving IEQ in buildings. They also list valuable resources and references to allow readers to investigate the pertinent issues in greater depth. The focus of the project was on commercial and public buildings, but many of the issues addressed and recommendations offered are applicable in residential settings.

Many volunteers worked diligently to create the recommendations in this report. These individuals are listed in the separate committee sections of the report, but special thanks go to the committee chairs: respectively

  • Hal Levin, Building Ecology Research Group;
  • Michael Mankin, California Division of the State Architect;
  • Roger Morse, Morse-Zentner Associates; and
  • Brent Kynoch, Kynoch Environmental Management, Inc.

Lastly, an enormous debt of gratitude is owed to four amazing individuals who made significant contributions to the work of all four committees:

  • Mary Lamielle, National Center for Environmental Health Strategies;
  • Ann McCampbell, MD, Multiple Chemical Sensitivities Task Force of New Mexico;
  • Susan Molloy, National Coalition for the Chemically Injured; and
  • Toni Temple, Ohio Network for the Chemically Injured.

The overall objectives of this project were to establish a collaborative process among a range of stakeholders to recommend practical, implementable actions to both improve access to buildings for people with MCS and EMS while at the same time raising the bar and improving indoor environmental quality to create healthier buildings for the entire population.

This IEQ project supports and helps achieve the goals of the Healthy Buildings, Healthy People project, which acknowledges that

"We will create indoor environments that are healthier for everyone by making indoor environments safer for the most vulnerable among us, especially children." (p.17)

Summary Recommendations

The recommendations in this report are only a first step toward the action plan envisioned by the Access Board. The NIBS IEQ committee offers several recommendations for further action.

  1. It is recommended that a follow-on project organize and convene one, or more, workshops to deliberate the issues and recommendations in this report.

  2. It is also recommended that a project be organized to develop a single guidelines document. Such guidelines would be built on refinement and coordination of the recommendations of the Design & Construction and Products & Materials committees in this report.

  3. This same, or a separate project, should develop new building code provisions to accelerate the implementation of improved IEQ.

  4. It is recommended that a project be organized to develop guidelines for the design of an "ideal space" for people with MCS and EMS.

The recommended follow-up projects should involve collaborative effort and funding from a range of organizations across the building community; e.g.,

  • American Institute of Architects (AIA),
  • Associated General Contractors of America (AGC),
  • Building Owners & Managers Association International (BOMA),
  • American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE),
  • Environmental Protection Agency (EPA)
  • The Access Board.

Steering Committee

  • Nicolas Ashford, Massachusetts Institute of Technology
  • Kathy Barcus, Clarke Construction Company, Inc.
  • Marilyn Golden, Disability Rights Education and Defense Fund (DREDF)
  • Harry Gordon, Burt Hill Kosar and Rittelmann Associates
  • Mark Jackson, Lennox Industries, Inc.
  • Brent Kynoch, Kynoch Environmental Management, Inc.
  • Mary Lamielle, National Center for Environmental Health Strategies
  • Ann McCampbell, Multiple Chemical Sensitivities Task Force of New Mexico
  • Claudia Miller, University of Texas Health Sciences Center San Antonio
  • Susan Molloy, National Coalition for the Chemically Injured
  • Roger Morse, Morse Zentner Associates
  • Larry Perry, Building Owners and Managers Association
  • Bruce Small, Building Inspections
  • Toni Temple, Ohio Network for the Chemically Injured
  • James Wasley, University of Wisconsin-Milwaukee
  • James Raggio, Access Board
  • Alexander Shaw, National Institute of Building Sciences


Access Board holds town hall meeting in Phoenix

June 11, 2018

The Access Board held a town hall meeting in Phoenix on May 23 that featured presentations by local speakers on various topics and a public “open mic” forum. It was held at Ability360, a Center for Independent Living. Board Vice Chair Karen Tamley and Executive Director David Capozzi opened the meeting with introductions and an overview of the Board and its work.

The first two speakers addressed access for people with heightened sensitivites to chemicals and electromagnetic fields. Dr. Ann McCampbell, Co-Chair of the Multiple Chemical Sensitivities Task Force of New Mexico, described the debilitating physical reactions experienced by those with an acute sensitivity to various chemicals in the environment, aslo known as Multiple Chemical Sensitivities (MCS). These include chemicals used in fragrances, personal care products, deodorizers, cleaners, pesticides, wall and floor coverings, and building materials. Dr. McCampbell, who has had MCS for almost 30 years, also called attention to sensitivity to electromagnetism from cell phones, security equipment, utility meters, florescent lighting, and other sources. She noted that the prevalence of Electromagnetic Sensitivity (EMS) appears to be increasing.

Susan Molloy, M.A., an advocate for people with MCS and environmental illness for 35 years, discussed design recommendations that can improve access for people with MCS. These include installing fresh-air ventilation systems and operable windows, allowing more natrual light, avoiding carpet, and pesticide-free landscaping. To improve access for people with EMS, smart meters should be avoided or shielded. Molloy called attenion to an earlier project on indoor environmental quality that was conducted by the National Institute of Building Sciences with funding from the Access Board. She outlined findings and recommendations from the project, which are provided in a report that is available on the Board’s website.

The following presentations addressed ADA compliance in the cities of Phoenix and Tempe. Phoenix ADA Coorindator Peter Fischer reviewed recent initiatives by the city to enhance accessibility under its ADA Compliance Program. He noted that the city regularly surveys facilities for compliance with the ADA and that transition plans are continuously updated to reflect city projects and programs. Several Phoenix transportation departments have undertaken transition plans, including a city-wide program to install curb ramps and accessible pedestrian signals. Last year, over 2,000 curb ramps were replaced. Other city initiatives include a new committee on integrating accessibility in emergency planning and response, an annual awards accessibility showcase, and a “Save Our Space” campaign that enlists volunteers to help enforce accessible parking.

Michele Stokes, an ADA Compliance Specialist with the Tempe Office of Strategic Management and Diversity, noted an online resource the city has launched to collect data on accessibility issues on city property for self-evaluations and transition planning. It includes a newly launched interactive map with data from digital surveys of sidewalks, curb ramps, cross walks, bus stops and pedestrian signals that will help city planners with transition planning. The surveys collect data on running and cross slopes, changes in level, such as joint heavings, surface gaps, and other features along with geographic coordinates. The city also allows the public to report access issues online and offers other resources on local accessibility.

The final speaker, Bob Hazlett of the Maricopa Association of Governments, addressed autonomous vehicles and opportunities they may offer people with disabilities, including those with vision impairments. He noted that a lot of testing of driverless vehicles is done in Arizona which is becoming known as the place “where self-driving vehicles go to learn.” While it is not known when autonomous vehicles may fully take to the road, the potential impacts on public policy and planning at the local level are being assessed, including those pertaining to parking, infrastructure, public transportation, and cybersecurity, among others.

During the public forum that followed, members of the public raised areas where more needs to be done for accessibility. Many urged action to address access for people with MCS and EMS and described how exposure to certain commonly-used chemicals and to electromagnetic fields jeopardize their health, limit access to health care, housing, and other services, and lead to isolation. Some commenters submitted information on the subject and endorsed the work of organzations such as the National Center for Environmental Health Strategies.

Others issues noted included the need for entrance doors to be automated, hotel beds that are too high for transfer, access to casinos, and the lack of electronic shopping carts. The Board was urged to do more outreach and training on access to medical care equipment which remains problematic despite new standards the Board issued last year for medical diagnostic equipment.

In addition, concerns were raised about access for people who are deaf or hard of hearing. Several comments focused on the sound quality and availability of assistive listening systems in meeting spaces. They also addressed connectivity issues that impact video remote sign language interpretation in hospitals and the lack of communication access in pharmacies to instructions for taking medications.