A Comparison of the Approaches in the Implementation of Good Indoor Air Quality Practices in Malaysia

Transcription

1 A Comparison of the Approaches in the Implementation of Good Indoor Air Quality Practices in Malaysia Anuar Mohd. Mokhtar* Department of Occupational Safety & Health, Malaysia *Corresponding SUMMARY Malaysia has applied different approaches to ensure the adoption of good practices in managing indoor air quality. A voluntary code of practice on indoor air quality was published in July As a result of a review in 2008, an industry code of practice was introduced in 2010 replacing the 2005 code of practice. The industry code of practice emphasizes on risk assessment, investigation of complaints, providing information and training, and control of sources as strategies to prevent sick building syndrome. Under this industry code six chemical contaminants are controlled, as well as biological agents, temperature, humidity, and air flow. The industry code of practice on indoor air quality is quasi-legal, in that it can be used in a court of law as an evidence of compliance with the requirements of the Malaysian Occupational Safety and Health Act 1994 with respect to ensuring the safety, health and welfare of workers and other person at the place of work. With the introduction of the new industry codes of practice, the indoor working environment is expected to improve in future as the requirements are no longer voluntary. KEYWORDS Risk assessment, VOC, Offices, Moulds and bacteria, Sick Building Syndrome. 1 INTRODUCTION In 1996 the Malaysian Department of Occupational Safety and Health (DOSH) published a guideline that gives guidance on safety and health of workers at the office. The Guidelines on Occupational Safety and Health in the Office recommended standards on indoor environmental quality including standards for temperature, humidity, ventilation, smoking, exposure to ozone and lighting (DOSH, 1996). Although this guideline was in existence since 1996, its existence was not publicized and its use was voluntary. In Malaysia, the control of indoor air pollutants at workplaces is regulated under the Occupational Safety and Health Act 1994 (OSHA) (DOSH, 1994). OSHA is an act that is based on self-regulatory concepts. Under section 15(1) of OSHA it is the duty of employers and self-employed persons to ensure the safety, health and welfare at work of all his employees. Section 15(2) elaborated further on this general duty where employers must among others: a) provide information, instruction, training and supervision to ensure the safety and health at work of his employees; b) maintain any place of work in a condition that is safe and without risks to health; and c) provide and maintain a working environment for his employees that is safe and without risk to health, and adequate as regards facilities for their welfare at work. Under Section 17 of OSHA employers & self-employed persons have duties to ensure a person (other than employee) who might be affected is not exposed to any health & safety

2 risk both on his premises and within the vicinity. Another provision is Section 18, where an occupier have a duty to ensure that any person other than his employees using his premises, or any plant or substance provided for use is safe and without risk to health. (An occupier is a person who has management or control of the place of work, i.e. duty on building owner or building management). Although the OSHA does not lay out the specific requirements, section 37 of OSHA provides for the promulgation of industry codes of practice to provide guidance of persons in complying with the requirements of the provisions of OSHA including indoor air quality issues. In July 2005, the Minister of Human Resources launched the Code of Practice on Indoor Air Quality (COP IAQ 2005) (DOSH, 2005) to introduce good industrial hygiene practices inside non-industrial buildings to prevent undesirable effects associated with working indoors, specifically prevention of sick building syndrome. In 2010, an Industrial Code of Practice on Indoor Air Quality (ICOP IAQ 2010) (DOSH, 2010) was introduced replacing the COP IAQ The ICOP IAQ 2010 was introduced to enhance the compliance of building management/owner with good indoor air quality practices and to improve indoor air quality in all non-industrial workplaces served by mechanical ventilation and air-conditioning (MVAC) system including air cooled split units(dosh, 2010). This industry code of practice on indoor air quality was made to provide guidance on improving the indoor air quality to avoid discomfort and/or adverse health effect among employees and other occupants of an indoor or enclosed environment by a) setting minimum acceptable exposure limits for chemical and biological contaminants; and setting acceptable values for specific physical parameters; b) describing the mechanism to identify, evaluate and control these indoor air contaminants; and c) specifying other appropriate occupational safety and health measures. The ICOP IAQ 2010 can be viewed or downloaded from DOSH s web portal at The objective of this paper is to examine the change in the Malaysian government s approach on the implementation of indoor air quality policy at the workplace from voluntary to semimandatory. 2 MATERIALS/METHODS In this study the COP 2005 was compared with the ICOP IAQ 2010 published by the Malaysian government in terms of their philosophy and rationale, application, focus, and standards. Another relevant publications cited in this study is the Hong Kong s 2003 Guide on Indoor Air Quality Certification Scheme for Offices and Public Places (Government of Hong Kong, 2003) that was made reference to by the DOSH IAQ committee when drafting the ICOP IAQ RESULTS Tables and Illustrations A comparison between the ICOP IAQ of 2010 and the COP of 2005 is given below: Table 1: Comparison between the COP IAQ 2005 and the ICOP IAQ 2010 COP IAQ 2005 ICOP IAQ 2010 Application Applicable only to indoor Apply to indoor workplaces served by workplaces served by centralized centralized air-conditioning system and also

3 Standards Assessment Strategy Legal air-conditioning system Acceptable limits for 5 chemical contaminants No standards for physical hazards No standards for microbial contaminant Dependent on limited number of assessors for investigating all cases of IAQ complaints Focused on assessment. Control strategies were generalized. Act as guidance, voluntary and not enforceable by law those using air cooled split units Acceptable limits for 6 chemical contaminants Standards for temperature, air flow and humidity Standards for bacteria and moulds Services of registered assessors required only for cases where the IAQ problem or solution is not obvious Focused on prevention and control measures. ICOP can be used in a court of law as a proof of compliance with relevant requirements of the Act The IAQ assessors need to be registered with DOSH and basically these are in-house assessors or outside consultants. Table 2 lists the number of IAQ assessors registered with DOSH from the introduction of the COP IAQ in 2005 until the end of Table 2: Registered Indoor Air Quality Assessors (August 2005 to 31st December 2011) Year In-house Assessor Consultants Total Total (Source: Department of Occupational Safety and Health, Malaysia, 2012) A comparison of the indoor air quality standards between those set out in the COP IAQ 2005, ICOP IAQ 2010 and the Hong Kong s Guide on Indoor Air Quality Certification Scheme for Offices and Public Places 2003 is given in Table 3. Table 3: Comparison of the IAQ Standards of Malaysia and Hong Kong Hazards Parameters COP IAQ ICOP IAQ HK Guide* Physical Temperature ( C) <25.5 Relative humidity (%) <70 Air flow (m/s) <0.3 Chemical Respirable particulates (mg/m3) Formaldehyde (ppm) Carbon monoxide (ppm) Carbon dioxide (ppm) 1,000** 1,000** 1,000 TVOC (ppm) Ozone (ppm) Biological Mould (cfu/m3) Bacteria (cfu/m3) ,000 Note: 1) All airborne concentrations are 8-hour time weighted average values, unless

4 otherwise indicated. 2) * indicates Standards for Good Class under the Hong Kong s Guide on Indoor Air Quality Certification Scheme for Offices and Public Places ) **indicates Ceiling value-the airborne concentration not to be exceeded at any time A total of twelve IAQ complaints were received and investigated by DOSH from 2007 until 2011 and these are summarized in Table 4 below: Table 4: Indoor Air Quality Cases reported to DOSH (2007 to 2011) Case Year Premises Complaints/Finding No Government office, Selangor Mould growth, offensive odour Government office, Perlis Dust and vehicles exhaust gases Airport Office, Sarawak Offensive odour Courthouse, Negri Sembilan Allergic reactions to insulation material Patrol boat, Perak Poor ventilation Government office, Negri Sembilan Mould growth Government office, Johor Vehicles exhaust gases Government office, Kuala Lumpur Poor ventilation Office at a factory, Selangor Poor ventilation Government office, Kuala Lumpur Mould growth Hospital building, Johor Mould growth Government building, Melaka Mould growth (Source: Department of Occupational Safety and Health, Malaysia, 2012) 4 DISCUSSIONS The Philosophy and Rationale The ICOP IAQ 2010 was introduced due to the shortcomings of the 2005 Code of Practice on Indoor Air Quality (refer Table 1) and also the need to improve on the adoption of indoor air quality practices among building owners, building management and employers at workplaces. The COP IAQ 2005 heavily emphasised on the carrying out of indoor air quality assessments by registered assessors. Under the ICOP IAQ 2010, the emphasis is on taking preventive actions and mitigating the indoor air quality situations. Where the issue and the solutions are obvious, there is no need for the building owner or building management or employer to call in a registered assessor to resolve the issue at hand. They can by themselves identify the source of the indoor air quality complaints and take the necessary corrective measures. By adopting this approach, reliance on the assessors will be minimised hence reducing cost and encourages compliance with the ICOP. The ICOP IAQ 2010 was also necessary to enhance adoption of good industrial hygiene practices in the non-industrial indoor workplaces as it has a legal basis as provided for by sections 37 and 38 of OSHA. Section 37 provides for the Minister (of Human Resource) to approve industry codes of practice and publishing it in the government Gazette. Section 38 of OSHA provides for the use of an approved industry code of practice in legal proceedings as admissible evidence whether a person has contravened or failed to comply with a relevant provision of OSHA. In this respect the ICOP IAQ 2010 need to be complied with unless the person has ensured safety and health of person in an indoor workplace by any other ways superior or at par with that stipulated in the industry code of practice.

5 Applications This industry code of practice is applicable to all buildings or any part of the building or totally enclosed areas served by a mechanical ventilation and air-conditioning (MVAC) system including air-cooled split unit, where there are persons at work, except for a) domestic buildings; b) any area or any part of the building which is constructed, used or intended to be used for domestic or industrial purposes; c) any area or part of building where any chemicals hazardous to health are used for analytical, research or preservation purposes; or d) removal and disposal of asbestos containing materials. The ICOP IAQ 2010 is applicable also to offices that use air-cooled split units that were not covered by the previous COP IAQ For such offices, the ICOP IAQ 2010 recommends the use of equipment that provides adequate fresh air ventilation such as the use of Demand Control Ventilation (DCV) or extractors. Hence the indoor air quality in these offices are also addressed. Focus on Prevention The COP IAQ 2005 focused on the carrying out of indoor air quality assessments by assessors registered with DOSH. The number of registered assessors is small and there are only five consultants providing IAQ assessment services throughout the country (refer Table 2). Hence, heavy reliance on these assessors should be minimized if good IAQ practices are to be successfully implemented by building managers, owners or employers. This is addressed by the ICOP IAQ 2010 in that where the IAQ issues and solutions are obvious, such as visible mould growth, they could be dealt with either by the employer, building management or owner without having to engage the services of a registered assessor. The 2005 COP recommendations on control strategies were general in nature. The ICOP IAQ, however, put emphasis on regular inspections, cleaning and maintenance of the MVAC system by prescribing these tasks to be carried out at specific time intervals. Building owner or building management is recommended by the ICOP to use non-chemical water treatment for the cooling tower. Control measures need to be in place before or during the carrying out any renovation work, prescribed activities (any activity that could pose health hazard to the occupants, such as applying or removing floor coverings; applying wall coverings or painting or the application of similar coatings; or cleaning of carpets), or applying pesticides. The ICOP also recommended housekeeping and cleaning of floors as often as is necessary to prevent accumulation of dirt and to minimise the formation of airborne dust, and the prohibition of smoking indoors a means to maintain good indoor air quality. Standards The indoor air quality standards for the ICOP IAQ (refer Table 3) was broaden to cover not only chemical contaminants but also physical agents and biological hazards. The previous COP specified standards for five chemical contaminants, i.e. respirable particulates, TVOC, formaldehyde, carbon monoxide and carbon dioxide. The ICOP IAQ added in a new standard for ozone exposure. This ICOP IAQ 2010 was based partly on the COP IAQ 2005 and the Hong Kong s Guide on Indoor Air Quality Certification Scheme for Offices and Public Places The standard for temperature, however, was based on the Malaysian Standards MS 1525: 2001 Code of Practice on Energy Efficiency and Renewable Energy for Nonresidential Buildings (SIRIM, 2001). However the ICOP IAQ 2010 adopted the Hong Kong s

6 bacteria standard of 500cfu/m 3 for excellent class instead of the good class standard of 1000cfu/m 3. The need to include the standards on mould is long overdue as 40% of cases reported to DOSH (refer Table 4) are due to moulds. By having a broader and more comprehensive coverage it is hope that IAQ issues in Malaysia will be better addressed. 5 CONCLUSIONS The publication of a new industry code of practice on indoor air quality that is semimandatory in approach, more comprehensive in its scope of application, and focusing on prevention, augur well for the Malaysian indoor environment as Malaysia is moving towards a developed country status by the year ACKNOWLEDGEMENT I would like to thank the Director General of the Department of Occupational Safety & Health for assistance rendered by the Department in the preparation and presentation of this paper, and the financial support by the Department for the author to attend this conference. 6 REFERENCES DOSH Occupational Safety and Health Act Kuala Lumpur: National Printers Malaysia Berhad. DOSH Guidelines on Occupational Safety and Health in the Office. Kuala Lumpur: Department of Occupational Safety and Health, Malaysia. DOSH Code of Practice on Indoor Air Quality. Kuala Lumpur: Department of Occupational Safety and Health, Malaysia. DOSH Industry Code of Practice on Indoor Air Quality. Kuala Lumpur: Department of Occupational Safety and Health, Malaysia. Government of Hong Kong Guide on Indoor Air Quality Certification Scheme for Offices and Public Places September The Government of the Hong Kong Special Administrative Region. SIRIM Malaysian Standards MS 1525: 2001 Code of Practice on Energy Efficiency and Renewable Energy for Non-residential Buildings. Standards and Industrial Research Institute of Malaysia (SIRIM).