Indoor Air Quality and
Occupational Health and Safety
Legislation in Alberta
Background
• Workers desire healthy and comfortable working
conditions. When these conditions are not met, job
satisfaction, productivity and health may be compromised.
Indoor Air Quality (IAQ) considers the indoor environment,
including the makeup of the air and comfort factors such
as temperature and relative humidity.
Background
• Alberta’s Occupational Health and Safety (OHS) legislation
requires that workplaces be safe and healthy, but does not
require that workplaces be comfortable; however, there are
good reasons, such as enhanced staff morale and
productivity, to exceed the minimum legislated
requirements.
Background
When we think of IAQ issues we often just
think of the chemical hazards;
• CO
• CO2
• Ozone
• PMs
• Voc’s
• but other factors may be at play……..
Legislation
Does the Alberta Occupational Health and
Safety Code apply to Indoor Air Quality?
• Is it a work site ?
• Are workers involved ?
• What legislative recourse do we have?
Legislation
The Act;
Alberta’s OHS Act requires employers to ensure the
health and safety of workers at the work site. The OHS
Regulation and Code under this Act have been
established to define standards for protection from
specific hazards.
Obligations of employers, workers, etc.
2(1)
Legislation
Part 2 Hazard Assessment, Elimination and
Control
• Are IAQ issues considered a workplace hazard?
• If an existing or potential hazard to workers is
identified during a hazard assessment, an employer
must take measures in accordance with this section.
• What action?
Legislation
Part 4
16(1) Chemical Hazards, Biological Hazards
and Harmful Substances
• An employer must ensure that a worker’s
exposure to any substance listed in Schedule 1,
Table 2 is kept as low as reasonably achievable.
• What is Schedule 1 Table 2 ?
Legislation
Legislation
What are OEL’s?
• Based on the American Conference of Governmental
Industrial Hygienists (ACGIH) Threshold Limit Values
(TLV’s)
Legislation
Oel’s continued…..
• Reviewed by a committee
• Based on existing peer reviewed literature, from
toxicology, epidemiology, occupational medicine, and
industrial hygiene.
• Level of exposure a typical worker can be exposed to
without developing adverse health effects.
• Not fine lines between safe and dangerous
exposures
• Adopted as the legal limits for exposure
• Based on 8 hour work day for 40 years
Legislation
Scenario
• Alberta OEL for CO=25 ppm
– Ok for children?
– Individuals with pre-existing respiratory issues?
– Other factors?
• This is the legal limit for office environments/work
sites.
• Best practice vs legal minimum.
– 1/10th of the OEL typically with CO we concede 5
ppm as it is pervasive.
• http://capitalairshed.ca/edmonton-centre
Legislation
What are IAQ parameters for indoor air quality?
• Regulations
• Standards
• Guidelines
We do not mandate in law what is and what is not
acceptable for substances other than the limits required
by the OEL’s
We do make recommendations;
• 1/10th of the OEL
• Other substance specific guidelines
Legislation
Legislation
Legislation
What if there is no OEL?
Part 4
16(3) If no occupational exposure limit is
established for a harmful substance present at a
work site, an employer must ensure that a worker’s
exposure to that substance is kept as low as
reasonably achievable.
• What is as low as reasonably achievable ?
• Do most IAQ chemicals of concern have OELs?
Legislation
What is as low as reasonably practicable ?
• At first glance “reasonably practicable” looks like
a pretty subjective way of determining
someone’s guilt or innocence. However,
“reasonably practicable” is a legally defined term
that is assessed using the “reasonable person
test”.
Legislation
• What would a dozen of your peers consider
reasonable in a similar set of circumstances?
• Your peers would likely review what you did and
compare it against what they do in their own
operations. Some of them might do more, others
less.
• The result would be a balanced and wise
judgment that could be defended to others.
Legislation
Part 4
• Potential worker exposure
• 21(1) If a worker may be exposed to a harmful
substance at a work site, an employer must identify
the health hazards associated with the exposure and
assess the worker’s exposure.
• Define harmful substance………………
Legislation
Other parts;
Part 29, WHMIS;
• Training and documentation for controlled
products, cleaners, disinfectants.
• improperly stored controlled products?
Part 35, Biological Hazards;
• ALARP exposure, policies and procedures
Best Practice
Indoor Air Quality Tool Kit
• The goal of the Tool Kit is to help you understand typical
indoor air quality (IAQ) issues, and to suggest reasonable
solutions to common problems.
Scenario
• A yoga studio has recently opened up in an
industrial multi-unit complex with a host of other
tenants including an auto body shop.
• The employees are complaining about the smell
of paint, and report cold like symptoms
associated with the onset of the odour.
Scenario
What do you think can be done?
• Inspect the auto body shop and ensure they are
in compliance with schedule 1.
• Inspect the yoga studio and ensure there are no
confounders.
• Attempt to identify the source of entrainment,
(not our mandate).
• Assess the workers? (not physicians).
Scenario
Where things get confusing;
• The auto body shop is in compliance, workers are
wearing respiratory protective equipment when
required and the paint booth is compliant with the
code. They are not exposed to any chemicals above
the OEL’s.
• The workers at the yoga studio continue to complain
of health effects associated with the odour.
• The responsibility for ensuring the health and safety
of the workers falls on the employer, in this case the
yoga studio.
Scenario
The great conundrum,
• How can the yoga studio as the employer minimize their
workers exposure when they are not the source of the
hazard?
• What tools are available from a compliance
perspective?
These cases can spiral into a dark place!!
Moral
• When options are limited and the health effects are
real the situation can become emotional.
• The best medicine is prevention,
– Address worker concerns surrounding IAQ issues earlier
instead of later.
– Even is exposures are below the OEL’s there may be
resulting health effects.
– The OEL’s are only one tool for addressing chemical hazards
• Hazard assessment
• ALARA
– Explore your tools for rectifying the situation!!
Resources
Indoor Air Quality (IAQ)
• http://work.alberta.ca/documents/WHSPUB_GH014.pdf
Indoor Air Quality Tool Kit
• https://work.alberta.ca/documents/WHSPUB_gh015.pdf