Air Pollution: Prior Indoor Air Quality Problems at the National
Institute of Environmental Health Sciences (Letter Report, 03/12/98,
GAO/RCED-98-69).

Pursuant to a congressional request, GAO provided information on the:
(1) quality of air inside the National Institute of Environmental Health
Sciences (NIEHS) building when it was occupied in 1981; (2) health
effects associated with exposure to formaldehyde; and (3) current
management practices at NIEHS for air handling and air monitoring.

GAO noted that: (1) NIEHS does not have data showing what the air
quality was inside its new facility during the first 5.5 months that the
building was occupied; (2) however, in response to some employees'
concerns, the agency began monitoring the air in September 1981; (3) the
agency found that formaldehyde levels ranged from 0.1 to 0.34 parts per
million (ppm), well below the Occupational Safety and Health
Administration's safety standard in effect in 1981; (4) officials of the
NIEHS said that during the first 5.5 months, they made adjustments to
the air handling system to balance the air flow and introduce more
outside air to help alleviate the respiratory problems that some
employees were experiencing; (5) formaldehyde is a known irritant; (6)
short-term exposure to formaldehyde at concentrations as low as 0.41 ppm
can irritate the eyes and the respiratory tract; (7) such effects
usually pass quickly, however once exposure ends; (8) according to the
National Institute for Occupational Safety and Health, short-term
exposure to very high concentrations of formaldehyde at levels of 14.1
to 14.3 ppm has produced cancer in the nasal passages of laboratory
animals; (9) because it is carcinogenic in animals and is known to
damage genetic material in cell cultures, formaldehyde has been
classified as a probable human carcinogen; (10) however, examination of
epidemiological evidence has not demonstrated a firm relationship
between formaldehyde and cancer in humans; (11) the NIEHS' current
managers are more aware of the need for adequate air handling systems in
buildings and for routinely monitoring indoor air levels to protect
employees from exposure to indoor air pollutants than managers were in
1981; (12) for example, prior to a recent move into a new laboratory
module at Research Triangle Park, the agency took a number of steps to
ensure the quality of the building's indoor air, including improved air
handling and monitoring measures; and (13) the manufacturing standards
for building materials and office furnishings are more stringent today
to ensure that the off-gassing levels of chemicals such as formaldehyde
are much lower than in the past years.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-98-69
     TITLE:  Air Pollution: Prior Indoor Air Quality Problems at the 
             National Institute of Environmental Health Sciences
      DATE:  03/12/98
   SUBJECT:  Carcinogens
             Occupational health standards
             Hazardous substances
             Air pollution control
             Working conditions
             Federal office buildings
             Office equipment
             Health hazards
             Federal employees
IDENTIFIER:  Research Triangle Park (NC)
             
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Cover
================================================================ COVER


Report to the Honorable
Lauch Faircloth
U.S.  Senate

March 1998

AIR POLLUTION - PRIOR INDOOR AIR
QUALITY PROBLEMS AT THE NATIONAL
INSTITUTE OF ENVIRONMENTAL HEALTH
SCIENCES

GAO/RCED-98-69

Air Pollution

(160410)


Abbreviations
=============================================================== ABBREV

  GSA - General Services Administration
  EPA - Environmental Protection Agency
  IG - Inspector General
  NIEHS - National Institute of Environmental Health Sciences
  OSHA - Occupational Safety and Health Administration
  ppm - parts per million

Letter
=============================================================== LETTER


B-279071

March 12, 1998

The Honorable Lauch Faircloth
United States Senate

Dear Senator Faircloth: 

The National Institute of Environmental Health Sciences (NIEHS), the
component of the National Institutes of Health that does research on
environment-related diseases, moved into a new facility at Research
Triangle Park, North Carolina, in April 1981.  Soon after the agency
occupied the facility, some employees began complaining about the
quality of the air, primarily in one of the facility's five modules. 
Even though considerable time has passed, some employees continue to
believe that the quality of the air--specifically, the level of
formaldehyde emissions--in the building in 1981 has caused them to
have continuing health problems.\1

In response to your inquiries, NIEHS and the Inspector General (IG)
of the Department of Health and Human Services issued two letter
reports in 1997 addressing some aspects of the employees' complaints;
other questions, however, remained unanswered.  Accordingly, you
asked us to (1) determine the quality of the air inside the NIEHS
building when it was first occupied in 1981, (2) identify the health
effects associated with exposure to formaldehyde, and (3) describe
the current management practices at NIEHS for air handling and air
monitoring.  This report describes the results of our work. 


--------------------
\1 Formaldehyde is a chemical widely used in building materials, in
household products, and as a component in other chemicals; it can be
released into the air by products containing it. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The National Institute of Environmental Health Sciences does not have
data showing what the air quality was inside its new facility during
the first 5.5 months that the building was occupied.  However, in
response to some employees' concerns, the agency began monitoring the
air in September 1981.  The agency found that formaldehyde levels
ranged from 0.1 to 0.34 parts per million (ppm), well below the
Occupational Safety and Health Administration's safety standard in
effect in 1981.  Officials of the National Institute of Environmental
Health Sciences said that during the first 5.5 months, they made
adjustments to the air handling system to balance the air flow and
introduce more outside air to help alleviate the respiratory problems
that some employees were experiencing. 

Formaldehyde is a known irritant.  Short-term exposure to
formaldehyde at concentrations as low as 0.41 ppm can irritate the
eyes and the respiratory tract.  Such effects usually pass quickly,
however, once the exposure ends.  According to the National Institute
for Occupational Safety and Health, short-term exposure to very high
concentrations of formaldehyde--20 ppm--is considered to be
immediately dangerous to the life and health of humans.  Long-term
exposure to formaldehyde at levels of 14.1 to 14.3 ppm has produced
cancer in the nasal passages of laboratory animals.  Because it is
carcinogenic in animals and is known to damage genetic material in
cell cultures, formaldehyde has been classified as a probable human
carcinogen.  However, examination of epidemiological evidence has not
demonstrated a firm relationship between formaldehyde and cancer in
humans. 

The National Institute of Environmental Health Sciences' current
managers are more aware of the need for adequate air handling systems
in buildings and for routinely monitoring indoor air levels to
protect employees from exposure to indoor air pollutants than
managers were in 1981.  For example, prior to a recent move into a
new laboratory module at Research Triangle Park, the agency took a
number of steps to ensure the quality of the building's indoor air,
including improved air handling and monitoring measures.  Also, the
manufacturing standards for building materials and office furnishings
are more stringent today to ensure that the off-gassing levels of
chemicals such as formaldehyde are much lower than in past years.\2


--------------------
\2 Off-gassing is the continuous emission, over a period of time, of
gaseous pollutants, such as formaldehyde, from building materials and
furnishings. 


   BACKGROUND
------------------------------------------------------------ Letter :2

When the air quality problem occurred at NIEHS in 1981, far less was
known about indoor air pollution than is known today, and there was a
strong emphasis on energy conservation.  As a result of the emphasis
on energy conservation at that time, building engineers at facilities
across the country had reduced the air exchange rate of air handling
systems and initiated other conservation measures.\3 NIEHS began
moving employees into its new facility at Research Triangle Park,
North Carolina, on April 11, 1981.  The facility was constructed in
five modules, each with its own air handling system.  Modules A and B
were administrative spaces; modules C, D, and E were laboratories. 
According to NIEHS officials, the laboratory modules required their
air handling systems to make a 100-percent exchange of the air,
whereas the administrative modules had varying amounts of fresh air
added, depending on the outside temperature.  Shortly after moving
into the new facility, some employees in module A began complaining
of respiratory problems and eye and throat irritation.  Most of the
complaints came from the second floor of module A, where most of the
administrative employees had office space.\4 One employee went to the
hospital on April 20, 1981, complaining of respiratory problems, and
a subsequent worker's compensation claim attributed the illness to
her work environment. 

According to the U.S.  Consumer Product Safety Commission,
formaldehyde is normally present at low levels, usually less than
0.03 ppm, in both outdoor and indoor air.  Moreover, homes or offices
furnished with products that release formaldehyde into the air can
have levels of more than 0.03 ppm.  The Occupational Safety and
Health Administration's (OSHA) occupational safety standard for
formaldehyde in 1981 was 3.0 ppm; the current standard is 0.75 ppm. 
Indoor formaldehyde levels can vary greatly, depending on the type of
building materials and furnishings used, the length of time that
these materials have had to off-gas, the temperature and humidity,
and the amount of fresh air brought into the building.  Indoor
formaldehyde levels can be reduced by using materials that contain
less formaldehyde, airing the materials out before allowing employees
into the space, and increasing the amount of fresh air brought into
the building.  Although formaldehyde levels can also vary with the
temperature and humidity, these factors are controlled in an occupied
building and, thus, may not have much effect. 

In response to requests from your office, two letter reports were
issued, one by NIEHS and the other by the Deputy IG of the Department
of Health and Human Services, addressing issues involving complaints
by employees that they may have become ill after being exposed to the
air in the new facility.  NIEHS' report, dated March 31, 1997,
addresses the events and health effects that may have been caused by
exposure to formaldehyde when the new facility was first occupied in
April 1981.  The IG's letter report, dated August 15, 1997, addresses
NIEHS' (1) grievance procedures and treatment of employees, (2)
compliance with appropriate policies and procedures regarding
employee complaints, and (3) venting and other practices to ensure
proper ventilation before the facility was occupied. 


--------------------
\3 The air exchange rate is the amount of outside air brought into a
building by the air handling system.  Increasing the air exchange
rate requires an air handling system to cool more air from the
outside in the summer and to heat more air from the outside in the
winter. 

\4 Because module A was the focus of the employees' concerns, our
work concentrated on that module.  However, NIEHS conducted air
quality monitoring and adjusted the air handling systems in both
modules A and B. 


   THE QUALITY OF THE AIR INSIDE
   THE NIEHS BUILDING IN APRIL
   1981
------------------------------------------------------------ Letter :3

NIEHS does not have data showing what the air quality was inside its
new facility when employees began moving into it on April 11, 1981,
or during the first 5.5 months that the building was occupied.  NIEHS
officials said that such monitoring for airborne contaminants was not
common practice at the time.  They also said that during these 5.5
months, the air handling system was adjusted to improve the air
distribution in module A to help alleviate respiratory problems that
some employees were experiencing because it was not immediately
recognized that indoor air contaminants could be originating from
within the space.  In response to the concerns of some employees,
NIEHS contracted with the School of Public Health at the University
of North Carolina to monitor the air throughout modules A and B and
to analyze the results to determine the quality of the air.  The
initial testing began in September 1981.  At our request, an indoor
air expert at the Environmental Protection Agency (EPA) extrapolated
the range of possible formaldehyde levels in module A when the
employees first moved into the space in April 1981.  He concluded
that those levels were probably higher than the levels measured in
September of that year. 

The initial monitoring, which took place on September 28 and 29,
1981, found that the formaldehyde levels on the second floor of
module A ranged from 0.1 to 0.34 ppm--well below OSHA's standard in
effect in 1981.  Subsequent monitoring between January 20 and March
1, 1982, by the School of Public Health and others showed
formaldehyde levels that were no higher than 0.044 ppm.  The monitors
were placed on top of desks, in closed wooden bookcases, and in other
locations and attached to the clothing of some employees. 
Formaldehyde levels, however, may have been higher when the employees
first moved into the space than when the measurements were taken
because research shows that formaldehyde levels in enclosed spaces
decrease rapidly during the first few days to several weeks.  The
contractor also sampled the air in modules A and B for 22 other
organic substances and detected minute amounts--less than 0.1
ppm--for 10 of these substances, such as benzene, toluene, and
trichloroethane.\5 According to the contractor, the level for each of
these substances was well below the standard in effect at the time. 
An air quality survey done by the National Institute for Occupational
Safety and Health for NIEHS in March 1982 reported that the primary
source of the formaldehyde was the particle board in the office
furnishings. 

NIEHS officials said that adjustments were made to balance the air
flow and introduce more outside air in module A during the first 5.5
months to alleviate respiratory problems that some employees
reported.  According to the officials, because the air was not being
monitored during this period, the levels of formaldehyde that the
employees were exposed to are unknown.  The officials also said that
in the early 1980s, air quality measurements were not usually made
when employees first moved into buildings because indoor air quality
was generally not recognized as the serious health concern that it is
today. 

We asked the indoor air expert from EPA to use NIEHS' air monitoring
data to extrapolate a range of possible formaldehyde levels in module
A when the employees first moved into the space in April 1981.  The
expert said that the limited amount of data available made it
difficult to estimate the possible formaldehyde levels for the period
before NIEHS began monitoring the air.  However, with the available
data as input for a formaldehyde decay curve,\6 the expert's
mathematical extrapolation showed that the initial formaldehyde
levels probably ranged between 1.2 and 7.5 ppm when the employees
first moved into module A--higher than the levels measured in
September 1981.\7 In light of his knowledge about formaldehyde
off-gassing from building materials and office furnishings, and the
variables that can affect the rate of off-gassing, he said he
believed that the actual levels were near the lower end of the range
and were probably less than 2.0 ppm, which would be below the
occupational safety standard that existed in 1981.  Moreover, he
stated that the formaldehyde levels probably declined quickly during
the first few days to several weeks and continued to decline over
time.  NIEHS officials, however, do not believe that initial
formaldehyde levels can be accurately modeled because of the multiple
variables that could have affected the concentrations.  They said
that the lack of reliable information on such variables as the amount
of formaldehyde in the materials when manufactured, the temperature
and humidity conditions during the period, and the air exchange rates
makes any extrapolation results highly suspect and speculative. 
Given such uncertainties, they believe that the initial formaldehyde
levels were probably at the lower end of the extrapolated range
because the furnishings had been installed some time before module A
was occupied in April 1981. 

The General Services Administration's (GSA) guidelines recommend that
air handling systems in buildings be tested to determine if they are
operating in accordance with specifications.  Although the GSA
guidelines in effect at the time called for test and balance
certifications to be prepared before buildings were occupied, the
Health and Human Services Regional Office Facilities Engineering
Corps that was responsible for overseeing the building's construction
did not have the certification for module A signed until September
29, 1981, 5.5 months after employees moved into the module.  NIEHS
officials said that they adjusted the air handling system during the
first 5.5 months in an effort to alleviate the employees' discomfort. 
However, an April 27, 1982, memorandum from NIEHS' Health and Safety
Manager said that the air handling system could not have been in
proper balance on September 29, 1981, as certified, because the
agency continued to adjust the system to improve the air flow and the
air exchange rate after the certification was signed.  A time line
summarizing the key events during the first several months of
occupancy is in appendix I. 


--------------------
\5 According to NIEHS officials, the 22 organic substances were a
standard set of chemicals for an air quality screening, and it was
not unusual for some trace amounts of these chemicals to be detected
because some of them are used in inks and office supplies. 

\6 A decay curve is a graphic representation of the way formaldehyde
is emitted from materials (off-gassed) over time. 

\7 This range was calculated using the generally accepted certainty
level for scientific calculations of 95 percent.  In other words,
given the available data, it is 95-percent certain that the actual
levels of formaldehyde fell within this range. 


   HEALTH EFFECTS ASSOCIATED WITH
   EXPOSURE TO FORMALDEHYDE
------------------------------------------------------------ Letter :4

The short-term effect of formaldehyde is irritation of the eyes and
respiratory tract--in particular the nose and throat and, possibly,
the lungs with concentrations as low as 0.41 ppm.  Because
formaldehyde changes quickly into other compounds when it contacts
tissue, other body parts, by and large, are not adversely affected by
inhaling formaldehyde.  Surveys of the known research show there is
no evidence that short-term exposure to formaldehyde affects the
musculoskeletal, cardiovascular, immunological, neurological,
reproductive, developmental, endocrine, renal, or hepatic systems of
the human body, while only "a few .  .  .  vague" gastrointestinal
effects have been found.  Moreover, the effects it has on the eyes
and respiratory tract usually pass quickly once the exposure ends. 
Furthermore, predominant research results have found that people with
asthma react no differently to formaldehyde exposure than do those
without asthma.  According to the National Institute for Occupational
Safety and Health, short-term exposure to concentrations of 20 ppm of
formaldehyde is immediately dangerous to the life and health of
humans. 

Long-term exposure of laboratory animals to formaldehyde at a
concentration of 2.0 ppm has not been shown to produce nasal cancer. 
But at concentrations of 14.1 to 14.3 ppm, studies have shown sharp
increases in cancer of the animals' nasal linings.  Studies of
long-term exposure have also shown that the occurrence of cancer
increases as the concentration of formaldehyde increases.  Even
though it has not been unequivocally proven that long-term exposure
to formaldehyde has the same effect on humans, the results of the
tests on animals have raised concerns that it may affect humans.  A
number of epidemiological studies that examined the incidence of
cancer in certain population groups have been done, primarily with
groups that have had long-term occupational exposure to formaldehyde,
such as morticians and pathologists.  These studies have not produced
clear evidence that long-term low-level exposure can cause cancer in
humans.  While many studies have found no or uncertain correlation
between formaldehyde and cancer, others have found that the incidence
of some cancers increases from exposure to formaldehyde.  However,
all of the studies that have shown an association had methodological
shortcomings.  According to The Toxicological Profile for
Formaldehyde, "The overall conclusion to be drawn from these and
other studies is that there is not a firm relationship between
formaldehyde and the induction of cancers in humans."\8

The three agencies that are responsible for determining whether
substances should be categorized as carcinogens--that is, as
cancer-causing substances--have placed formaldehyde in an
intermediate classification because of the clear evidence that
formaldehyde causes cancer in the nasal linings of laboratory animals
and the limited evidence from the epidemiological studies of humans. 
The agencies and their classifications of the effects of formaldehyde
on humans are as follows: 

  -- International Agency for Research on Cancer:  Probably
     carcinogenic to humans;

  -- National Toxicology Program:  Reasonably anticipated to be a
     carcinogen; and

  -- EPA:  Probable human carcinogen. 

EPA did a risk assessment of formaldehyde in 1987 and updated the
assessment in 1991.  The overall result of the update was that EPA
reduced the estimated risk of cancer for humans by a factor of 50
(i.e., EPA decided that the risk of cancer from formaldehyde was not
as great as it had originally thought).  Much of this reduction
occurred because of a change in the way that EPA estimated the
effects of exposure to formaldehyde.  The earlier method measured the
concentration of formaldehyde in the air being breathed, whereas the
current method uses a more direct measure of the way that
formaldehyde affects tissues.  This method estimates the levels of
formaldehyde at the site where it most often comes in contact with
tissue, such as the nasal lining, by measuring the compounds in the
tissue that were produced by the exposure to formaldehyde. 

In discussing this change, EPA explained that it was desirable to
have a complete biological understanding of how cancers were caused
by a substance and that this change in method recognized a
significant step in that direction.  However, because it was not yet
completely understood whether or how cancers in humans might be
caused by formaldehyde, it was still necessary to extrapolate the
risks to humans based on data from animal studies.  EPA's decision
was significantly influenced by the fact that formaldehyde has been
clearly shown to be genotoxic--that is, it causes various kinds of
chemical damage and mutations to genetic material--in laboratory
microorganisms, tissue culture tests, and some animal tests, which
makes it particularly suspected of being a carcinogen. 


--------------------
\8 The Toxicological Profile for Formaldehyde, U.S.  Department of
Health and Human Services, Agency for Toxic Substances and Disease
Registry, Public Health Service (Atlanta, Ga.:  Sept.  1997), p. 
233. 


   NIEHS' CURRENT MANAGEMENT
   PRACTICES FOR MONITORING AIR
   QUALITY
------------------------------------------------------------ Letter :5

NIEHS' current management is more aware of the need to have adequate
air handling systems in buildings and to better monitor indoor air
levels to reduce employees' exposure to indoor air pollutants.  For
example, before moving into a recently completed laboratory module at
Research Triangle Park, NIEHS initiated a number of health and safety
measures to ensure the quality of the module's indoor air, including
improved air handling and monitoring measures and the use of less
polluting building materials and furnishings.  In addition, according
to EPA officials, the manufacturing standards for building materials
and office furnishings are more stringent today to ensure that the
off-gassing levels of chemicals, such as formaldehyde, are much lower
than in past years. 

NIEHS completed the new module at its Research Triangle Park facility
in August 1996.  According to NIEHS officials, the project engineer
was responsible for keeping track of the building materials used in
the construction and furnishing of the module and for ensuring that
the materials did not contain excessive levels of pollutants, such as
formaldehyde, that would cause indoor air quality problems.  NIEHS
officials also said that they ensured that the air handling system
installed would meet the air exchange rate for the new laboratory
space (i.e., 100-percent exchange) recommended by the American
Society of Heating, Refrigeration, and Air-Conditioning Engineers,
Inc.\9 Before the new module was occupied by employees in 1996, NIEHS
conducted several air monitoring tests of all areas of the building
to ensure that the air handling system was functioning properly and
that any off-gassing of pollutants from the building materials and
furnishings was below OSHA's standards.  Even after employees moved
into the new module, NIEHS' Health and Safety Branch continued to
perform some air monitoring to ensure that air quality problems did
not occur.  According to NIEHS officials, these improvements have
reduced the number of complaints from employees about the air quality
in their work space. 

NIEHS' air monitoring procedures for existing space have also changed
since the indoor air quality problems occurred in 1981.  According to
NIEHS officials, current procedures require the Health and Safety
Branch to perform an indoor air quality assessment whenever an
employee complains about the air flow or air quality, whenever
renovations to an area result in the use of new building materials or
furnishings, or whenever the building management staff suspects that
the air flow or air quality may not be correct.  Furthermore,
according to NIEHS officials, the air exchange rate recommended by
the American Society of Heating, Refrigeration, and Air-Conditioning
Engineers, Inc., for administrative space (i.e., 20 cubic feet per
minute) is currently being used for the older modules A and B at the
facility.  Also, according to NIEHS officials, some adjustments, in
addition to those done as part of routine maintenance, are still
being made today as the agency responds to complaints about the
indoor air.  The officials said they believe that the continued
complaints are the result of employees' heightened awareness of
indoor air pollution and not to formaldehyde off-gassing. 

According to EPA officials, the manufacturing standards for building
materials and office furnishings are more stringent today than they
were in 1981 to reduce the off-gassing of chemicals such as
formaldehyde.  As federal agencies became more aware of indoor air
pollution problems in the early 1980s, EPA and other agencies worked
with the industries that make many of the materials used in office
spaces--such as furniture, particleboard and wallboard, and
carpet--to reduce the amount of chemicals used in the production of
their products.  Manufacturers have met these new standards by using
less formaldehyde in their products and by using other materials to
encase products that contain high levels of pollutants to prevent the
off-gassing of these chemicals.  In some instances, manufacturers
suggest that their products be aired out before they are installed in
an office building or that the building be aired out before it is
occupied. 


--------------------
\9 The Society is an international organization that writes standards
and guidelines in its field of expertise--which includes indoor air
quality--that describe recommended practices for the design and
installation of equipment. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :6

We provided copies of a draft of this report to the National
Institute of Environmental Health Sciences (NIEHS) for review and
comment.  The agency generally agreed with the information presented
but took exception to the section dealing with the mathematical
extrapolation showing the probable range of formaldehyde levels when
employees first moved into the new building.  The agency does not
believe that it is possible to accurately model what the formaldehyde
levels were in April 1981 because of the multiple variables that
could have affected the levels and the lack of reliable information
from 1981. 

While we agree that there are many uncertainties that make modeling
formaldehyde levels in April 1981 difficult, enough is known about
the various factors to do a simple mathematical extrapolation along a
decay curve to show that the possible readings would have been higher
than those measured in September 1981.  For example, factors such as
the type of materials in the building did not change significantly,
and the air exchange rate in September should have been higher than
in April.  These, as well as other physical factors, point to the
concentrations of formaldehyde being higher in April than in
September 1981, but since monitoring was not done in April, there is
no way of knowing exactly how much higher.  All of the agency
officials we spoke with from NIEHS and EPA agreed that the levels of
formaldehyde at the facility in April were higher than in September. 
Opinions differed, however, as to how much higher the levels were,
but there was general agreement that they were likely to have been no
higher than 2.0 ppm.  NIEHS stated that the initial levels were
probably below 2.0 ppm because higher exposures would have caused
significant eye irritation in most people and most employees first
occupying the space were able to tolerate their indoor environment. 
We added NIEHS' views as appropriate.  Appendix II contains the full
text of the agency's written comments. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :7

Our review included interviews with NIEHS officials, current and
former NIEHS employees, and scientists and experts knowledgeable
about modeling, air handling, air monitoring, and the exposure to and
the effects of formaldehyde.  We also reviewed available
documentation and air monitoring data compiled by NIEHS from
September 1981 through March 1982.  Because no air quality
measurements were taken in the new NIEHS facility during the first
5.5 months that it was occupied, we relied on extrapolations and
interviews to determine the most likely quality of the air inside
module A when it was first occupied.  We asked an EPA scientist, who
was identified by the agency as an indoor air expert, to use NIEHS'
air monitoring data from September 28, 1981, through March 1, 1982,
to extrapolate the formaldehyde levels when employees first moved
into module A.  To identify the available research on the health
effects of formaldehyde, we reviewed The Toxic Profile for
Formaldehyde (the September 1997 peer-reviewed draft) prepared by the
Department of Health and Human Services' Agency for Toxic Substances
and Disease Registry.  We also reviewed the April 1987 Assessment of
Health Risks to Garment Workers and Certain Home Residents From
Exposure to Formaldehyde, prepared by EPA's Office of Pesticides and
Toxic Substances, and the June 1991 update, Formaldehyde Risk
Assessment, prepared by EPA's Office of Toxic Substances.  We also
reviewed other technical literature on the health effects of
formaldehyde.  We performed our work from October 1997 through
January 1998 in accordance with generally accepted government
auditing standards. 


---------------------------------------------------------- Letter :7.1

As arranged with your office, unless you announce its contents
earlier, we plan no further distribution of this report until 15 days
after the date of this letter.  At that time, we will send copies to
the appropriate congressional committees; the Secretary, Department
of Health and Human Services; and the Director, Office of Management
and Budget.  We will also make copies available to others on request. 

Please call me at (202) 512-6111 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
III. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
 Protection Issues


KEY EVENTS IN THE MOVE TO MODULE A
AND THE MONITORING OF INDOOR AIR
QUALITY
=========================================================== Appendix I



   (See figure in printed
   edition.)

   Source:  National Institute of
   Environmental Health Sciences'
   files.

   (See figure in printed
   edition.)




(See figure in printed edition.)Appendix II
COMMENTS FROM THE NATIONAL
INSTITUTE OF ENVIRONMENTAL HEALTH
SCIENCES
=========================================================== Appendix I



(See figure in printed edition.)



(See figure in printed edition.)


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================= Appendix III

RESOURCES, COMMUNITY, AND ECONOMIC
DEVELOPMENT DIVISION

William F.  McGee, Assistant Director
Joseph L.  Turlington, Evaluator-in-Charge
Richard A.  Frankel, Technical Adviser
Philip L.  Bartholomew, Evaluator
James B.  Hayward, Evaluator


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