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Environmental Policy Working Grouphttp://www.pelb.gov.hk/iaq/conunent.htmI NDOOR AIRQUALITYProfessional Bodies' Comments on Draft Consultation PackageAir Conditioning and Refrigeration Association of HConsumer Counr.ilHong Kong Council cm Smoking and HealthHong Kong Association of Certification LaborHong Kong Institute of ArchitectsHong Kong Institute of Engineer (Chemical DiscLtd.Hong Kong Institute of HousingHong Kong Institute of Occupational and Environmental HHong Kong Institute of SurveyorHong Kong Occupational safety and Health AssociationHong Kong Productivity CouncilHong Kong Polytechnic UniversityHong Kong University of Science and TechnologyHong Kong- College of Community MedicineHong Kong Radiation Protection SocietyHong Kong Thoracic Society (T,tH)Occupational Safety and Health CouncilVocational Training ConnHI

AIR mfl/TE* mTEftfiflTionfiL umiTEOUnit 1-2,1/F, Fu Hong tod 8Jdg., t Hok Yuen St. East. Hunghom, Kowiooa Hong Kong.M *tl:($52)27640307Date:Reference:Sept. 21, 1999.F990798/0921/99Envrionmental Protection Department,33/F Revenue Tower,5 Gloucester Road,Hong Kong.Attn: Dr. Alain Lam(Air Policy Group)Dear Sir,Re:Indoor Air Quality Consultation PaperWe refer to the captioned consultation paper from your department addressed to ACRA. We havereplied with our opinions through ACRA to Planning, Environment & Lands Bureau.We would like to highlight to you the following main points we suggested:1. The need for immediate legislation to speed up the process of IAQ implementation. We are talkingabout a problem which can cause death! There is no point in waiting for 3 years to enact anordinance.2. Simplification of channel for enquiry by the public It is hardly imaginable for the public toapproach ten government departments on IAQ problems.3. For HK environment, our IAQ standard should be higher than other countries owing to itspopulation density. ASHRAE 62-89 should be taken as a minimum standard.4. Government should take the lead to implement IAQ pilot plants and also for mock up purpose.5. Laying down practical standards or guideline on key parameters.6. There must be worked examples of solutions for renovation of existing buildings for IAQ standard.7. For any company providing IAQ services such as design, installation and servicing, they must belicensed and shall bear legal liabilities of their work and certification.8. EPD shall provide training to qualified persons working in IAQ business and in developer firms.9. Incentives must be provided to developers or property owners for implementing IAQ in the form ofrelaxation on Rates or tax. Also, we suggested the exclusion of plant room areas from plot ratioto give more flexibility for plant design, energy recovery etc.10. There should be a clear identification of duties and roles of the developer, architect, designengineer and contractor and certifying bodies with respect to design, installation, servicing andcertifications.11. Duct cleaning: This is only a temporary measure and is contradictory to the requirements of IAQobjectives. Duct cleaning should only form part of the pre-treatment work for IAQ objective andshould be done only once.AIR fflft/TIft HVAC PRODUCTS

w>s^«® ma/riftMfllftinTiftflftTIOnftL LimiTiDfUnit 1-2,1/F, Fu Hong Ind. BWg.,1 Hok Yuen St. EosT, Hunghom, Kowtoon, Hong Kong. Tei.® Si 1(852)27640307Fox 11 H: (S52) 2363 7336We also have made the following suggestions on the technical aspect:A. Macro aspect::There should be clear-cut classification of IAQ standards in the following categories:1. Scheduled premises such as restaurants, canteens, cinemas, discos, funeral parlours etc.2. Shopping arcades3. Offices4. Hospital & Clinics5. Public Utilities6. Workshops or factoriesB. Micro aspect1. The controlled area must Have i2. Intake air must be treated with high efficiency fitters and through central PAU.3. Filter efficiency must be over 93% with auto-cleaning feature to avoid human factor mistakes.4. Filters must be of long-life design (say over 1000 days) with permanent mounting to eliminate filterby-passing problems.We believe to physically implement good IAQ, we need a proper tool: a new air-conditioning systemwhich should be of a completely new design aiming at IAQ standard. If conventional systems arestill used, we can never produce the effect we want.We must stress that legislation Is inevitable. However, we are not pushing developers to spendmoney to attain IAQ objectives. We convince them by the returns they will get in terms of savings inenergy and manpower, increase in productivity and increase in customers etc. Of course, our goalis for Health.As an international city, we should take Health as our top priority. We are already late in IAQimplementation. Without immediate legislation, we see nobody will take action. Two years later, wewill see the same sick buildings and nothing will happen. EPD will still be pushing IAQ issue, butonly becoming a clich6. Is this the scenerio we want to see?Yoursfaiilifutty, ~ :r .........For AIR MASTER INTERNATIONAL LTD.ffy Winston Y.S. CHEUNGManaging DirectorCc Mr. Charles Wu (Environmental Protection Officer, IAQ)uc*oo*Ho:M07i Coftlflcat* No FM 33887HVAC PRODUCTS

10-SEP-1999 17:09 COMMUNITY MEDICINE* HKUI ««*«•*ft*MO K0lp« COUNCIL OM SMOKING JUIP If IAUN*• 852 2855 9528 P.01•To r :: Dr Alain Lam, Air Policy Group, EDP: '< ':• (Fax: 2827 8040)cc !• ; ; MrGL^ungJP(Acti^: Dr M Chan, JP (Director of Health) (Far 21360071)Kroii;: AJHedleyDate :: 10 September 1999Consultation OP door Air Quali;.: • . :> Hfe Guidelines derived front the Grovermnfffit's Cops• •• on Tff door Air PoOurion in Offices A Public Places 199S : *Tfaaxjk you for your letter of 3 August 1999 and the invitation to comment on the tfraft"Gukknce Notes for the Management of Indoor Air Quality in Offices and PublicPlaces" August 1999. . -on Smoking and Hetlth appreciates the opportunity to do this from .theviewpoint of the need to prevent passive smoking in the general population. .consultation document was discussed at the Council Meeting on 9 September.I regret to have to.state hcsre that, in its present form, the section in the draft guidelines(4.1:1 page 53), on the prevention of passive smoking, is totally unacceptable. It Msfar slfcort of the type of document which is needed to underpin the present and futureprotection of indoor air from contamination by second band smoke..1 i111* Councils' positionThe; Cpyndl cannot support the current draft in hi present form but will readily offer;to wxrk with the Environmental Protection Department to develop a state-of-the-art .rbbu$ '' statement on the hazards of passive smoking and the measures needed to avoid.Defideadet in the draft guideUnef. ,.», • ^ . < . **theidefidcncies in the present statement can be briefly summarised as follows:* . *-' The statements on the hazards associated with exposure to second hand smote.:.and resultant passive smoking are very badly worded and as a reiult ar£ambiguous, confusing, incomplete and likely to mislead if they are adopted asguidelines for policy and implementation. We are prepared to provide adetailed critique.statement on steps required to provide protection fromsmoke contain some of the elements needed for an effectivei (ASZ) ZASA. AAiT Z&tMPACSIMItit16:58 + 852 2855 9526 39* B1

10-SEP-1999 IV s 09 COMMUNITY MEDICINE* HKU + 852 2855 952B P. 02» it is clear from this document that Hong Kong requires a ;up to date and independent review 1 of the hazard of passive!/'smoking and its prevention.-ll^-ij^jor :adults in the home, pregnant women, thewgent need to ban smoking in theworkplace leisure and shopping, centres and eating places, including the :'protection of all workers in the catering and hospitality industry,: : The.rappxt which you have translated into guidelines is also very dated and ;:4'penat reflect the full spectrum of health risks which are now fullyin the world's literature. A provisional list of sources ofinform&tipn on the issues of second hand smoke, passive smoking and its•:I&ev!efltlon is appended.in Hong Konglip Cioiiricil on Smoking and Health maintain? regular monitoring of: '«; ;^id)tmiological and toxicological studies, reviews .and other reports on secbnd-. '*;hand s&toke, '•I ';tj»e eatiinates of injury to the health of both non-smokers and smokers,•; : legislation worldwide on prevention of passive smoking and ;+: evaluations of the implementation of no-smoking policies, including the obstaclestip achieving effective legislation and its implementation, and how these barriers: ,. myl be overcome, '.• i . . *tbf need for validity and independence :'"-'' *'• 'confidence in the present statement in the draft guidelines becausefifcrst, we believ* it is incomplete and incompetent in scientific terms. Second, webelieve that the team of contractors which undertook the original studies qnd Wrote^consultant's report had a long history of close association with the tobaccoIndustry, This is not an acceptable basis on which to formulate independentguidelines for long term policy on the prevention of passive smoking.'forward * ]"•*.; »• * . , .thfere it considerable expertise in Hong Kong on the epidemiological and publitnealtti .dimensions of passive smoking. This expertise is recognised worldwide^^pliyp, iti r^ipnal and global strategies for the prevention of tobacco related disease^through the Western Pacific Regional Office of the World Health Organization and •the ; Asia Pacific Association for Tobacco Control.• • . * * « • • :&tou% |tom several expert sources is avafliMe to the Hong Kcmg Government,topughthe Environmental Protection Department, on the formulation of new, :i^eritifit«Uy founded public health measurei to promote a imoke-free indoor airpolicy in the SAR.+ 852 2855 S62S 99%

10-SEP-19B9 1?:10:, *»;«,»».««* ACOMMUNITY MEDICINE* HKU * 852 2955 9528 P.03K; is'widely Recognised throughout the world that vohnttary codes have felled to'. protect public places and workplaces from the hazard of passive Hong.Kong's present legislation on many aspects of indoor air quality ii either weak or mm*existent The : aection which attempts to address this in the draft guidelines is likely tohave no beneficial impact on the present situation.1$* present statement should be discarded and an entirely fresh approach takca to thedevelopment of guidelines, together with supporting documents and other references,which will meet Hong Kong's needs for indoor air which is free from tobacco smoke.AJHedkyJP\0310-SEP~i999"'' llfiS'se +85228559528 99?t

10-SEP-1939 17:10 COMMUNITY MEDICINE. HKU +852 2855 9528 P.B4«•*.*;•*.*,«««.«The reaources available to support the devdopment of guiddfoftf indud*'*• US, American'! for Non-smokers Rights Organisation: Smoking. end Ventilation47W&MJ& md Safety Ewoutive: UKApprwtdCod* qf Practice (ACOP) My 29j;' how the healtib and safety law should apply to* US^kan^ndc^r A^I^gulatiomi Asthma Campaign: Smddng in the workplace^VK^^^m^ni: Scientific Committee on Tobacco and Health (SCOTS)V*~ ^13^^; * [r'i. !i.. *•"•.'»'{Ha&k Cellular The Cost of Smoking in the Workplace^ t^C Gdvcmmcnt: Healthy Workplace Initiative ,* US : Centre for Disease Control; Making your workplace mokejree» " . • . * . *>:EUropeanHealth and Safety: Workplace Health and Safety Directive 89/654 EEC'?. -fiio^eanlfcalth and Safety: Pregnant Workers Directive 92/85/EECvUKSfealth and Safety Executive: Guide to Passive Smoking in the Workplace:*..*• i; * , •' UK; Department of Health: Smoking in Residential Care Establishments .* A$HRAB statement on the exclusion of smoking in indoor areas: a reversal of .' • • • " ' " 1999 . : . ..> WHQ Air Quality Guidelines fbr Europe; 2 nd Edition: Environmental TobaccoSmokeTOTA. P.'04"10-SEP-1999 IS'Sa +95228559529 99* P.B4

IrtenongCertification Laboratories Ltd.C.M.A. Suiting 1/R, S4-66 Corsasughf Roid (taml Hong KongTlx- 63S26 MAFTS HX Tel: Pa*s 2S41 4541Ogrftof: ADM/3/3 YourRef.:Planning, Environment & Lands BureauEnvironment Division9/F Murray BuildingGarden RoadCentralHong KongDear Sir/Madam,nf "Menajnnv1999 September 9Thank you for your letter of August 3 inviting comments from dieAssociation of the captioned.Attached please find our comments for your reference and consideration.We would appreciate if you could send us updated information on. thedevelopment of the issue in due course. Should you have any queries, pleasefeel free to contact me at tel no. 2542 8618 or Mr Fergus Au at te] no. 2542 8620.Yours sincerely,Natalie Keungfor Secretaries

09-SEP-1999 10s 38 FROM TO 28278040 P. 02/02"* * m.The Hong Kong Association of Certification Laboratories Lid.Comments m EFD's Coasuhation Paper on "Managing fadoor Air Quality 81 aad"Guidance Notts for the Mraagemtnr of fiadoer Air Qualify in Office* and Publk Places"1. We welcome and applaud the Government to take lead in m quality fl&Q)problems in offices and public places. The Issue has been gaining public inrecent years and appropriate action has to be done property and quickly.2. We also agree to the broad approach to tackle the IAQ issues thwugh ^ob&ntary selfregulationapproach combined with a certification system to declare the level ofcompliance to the IAQ objectives.3. While we appreciate the need to set different levels of IAQ objectives in order toencourage participation by property owners to improve their buildings IAQ, we havestrong reservation to set the proposed Level 3 IAQ objectives at the OccupationalExposure Limits (OELs). As pointed out in Section 3,1 of the Guidance Notes for theManagement of Indoor Air Quality in Offices and Public Places (page 21), IAQ objectivesare intended to protect a more diverse target population which may include children, theaged and infirm, and people with chemical sensitivity. In our views, the proposed Level3 IAQ objectives ftil to offer such protection to building occupants. It should be notedthat the Occupational Safety & Health Ordinance (OSHO) already requires fiillcompliance with the OELs and so it seems inappropriate to set IAQ objectives at OELs inthis voluntary regulatory system of IAQ management. Moreover, when such Level 3objectives are set for the public, it would misdirect the public to aim at this level ofobjectives and be satisfied with such level though it is suggested in the Guidance Note toencourage achievement of at least Level 2 objectives (page 24), In $rA*r to M* «* pM^ir. t

20 September! 999The Hong Kong Institute ofPlanning, Environment & Lands BureauEnvironment Division9/F Murray BuildingGarden RoadCentral Hong Kongyour ref: EP2UL3/29 VIIAttn: D? Alain LamDear Dr LamCONSULTATION ON MANAGING INDOOR AIR QUALITYWe rafaf to your letter dated 3 August 1999 inviting our comments on your "ConsultationPaper on Managing Indoor Air Quality" and dran "Guidance Notes forth* Managing ofIndoor Air Quality in Offices and Public Places". While expressing our support to thepromoteon theof healthy built environment in Hong Kong, we have the following commentssultatlon paper as well as the draft guidance notes: '•Coneutta Ion Paper on "Managing Indoor Air Quality"lAO 1 ifnrmAtirtrt C*ntMi foara 3QVJ3affionstraKf!fl snvifoftmentaliv fcsflflfisihlfiWhtshoof osupporting tha setting up of an IAQ information, we envisage that the Centred include documentation of good local practice on designing healthier indoormment for various building types (in addition to the information on the practiceer countries).We so envision that the Centre itself is potentially an Innovative and excitingdem nstration project ~ showing excellent indoor environmental quality throughvario j$ effective architectural and E&M design strategies on IAQ management Atthe ame time, the Centre is anticipated to address other environmental concernsuch as energy efficiency and resource conservation from a holistic perspective ofsusts nable design,The esign of the Centre can be stimulated through idea competition, which canforth promote the IAQ awareness among the building professionals.CaQVJft !nad /naCflmmltfyiant findWe ppredatr that the Government is preparing to take the lead in assessing theIAQ 9f all government buildings. Wa urge that the government commitment shouldbe odended to include the. government-subsidized projects such as universitycam us buildings.To ffrnty demonstrate the commitment, the IAQ objectives should be also targetedato ipHance with at least the Level 2 (and preferably the Level 1 for new endrenc ition projects).At h ast for the new and renovation projects, we strongly encourage the start ofImplementing the IAQ Objectives by the Government without dday, and not laterthan .he Second Phase (2000J.\J^**ti**^5>ti»llf?* till lilt KTfi:isiiesas rai:Hffaofi,lHf33M+652 2234 9106 99X p.ai

23-SEP-1999 19-'07 FROM Tn ^TO 8040 P. 02/03Tfw Hong Kongof"Guidance Note for the Managing of Indoor Air Quality In Offices & Public Pieces"The current scheme only cover* offices and pubiie pltcaa that are aneioaad araasprovided with MVAC for human comfort but e&ecluding buildings far domestic use,car parking and public transport interchange, etc. Tha following two aspects shouldba clarified in tha Quldanca Notts:Tha environmental merit* of naturally ventilated buildings should barecognized from an IAQ perspective. Whenever tna contact and tha fanctionallow, we should conaldar designing naturally vantiiatad tradings at tha atart(with supplemental support of MVAC systam tor optional uaa only If necessary),Totally saaiad buildings with haavy dependence on MVAC systems unlikelyrepresent the way forward towards sustainable developmentTha action plan extending tha consultancy study on JAQ management Inothor major building typaa; such §s tha domestic and tha partially endoatdpublic places (such as public transport interchanges)[qdqor Air Qmiflfy f)ht^^f r\/ /|>aelkifi IV Pawidwinq h•, tit^f KtfijlavijrimOgenym******* 0.1 *i« **Ti

23-SEP-1999 19s 07 FROMTO 28278040P.03/03Th® Hong Kong Institute ofTwo (2) distinct sub-sections ahould be provided to distinguish between thespecinoatien of building material* and the aspects of office maahlneiy selection.In the 2nd paragraph, Vood" b mentioned, There is a wide range of natumi,untreated wood products wnn different emission characteristics, tome discussionson this aspect are recommended, rather than fostering an oversimplifiedimpression that natural materials generally have no or negligible emissions. On theother hand, commonly used finishing material such as carpet and paints should beIncluded as emmples where appropriate,On the choice of materials, the dran ON merely recommends building professionalsthemselves to cany out research and test on products, Howtw, with a view toeffectively promoting batter (AQ, the Govammant should take the lead In developinglocal database of building materials with emission classification so thatprofessional*, developers, building managers, and.even the publlo can more raadilymake appropriate choice of haetthy matarials,The classification of materials and products, a worthwhile process as recognized byother countries as part of the healthy building labeling schema to generate incentive,certainly takes time and effort for a committee or the like to develop thaclassification. Tha committee members should Include representatives ofresearchers and various construction parties. The HKIA is willing to support thistask towards a betterment of indoor environmental quality in Hong Kong.Yours sincerelyRita Cheung (MSfRAftktMf ^Registrarc.c.BLA ChairmanAM«iiMrilT>NilfWiiaBart|tUal^lim ^loor. on« Hysan Avtnut.; Mr Tung 0>*t M** CNif juirMPt. Htag KJ^BmmirM^ ^fCAA^ifftf AfCMIiCtl IM^ONrfTil.'IS18:50 •^852 2234 9136TOTAL P.03

02-SEP-1999 10531 FROM TO 28275040 P.10/12fi* (852) 2S9S -4446 ^ * (852)25777791******THIINSTITtfTION OF90 WDndC«Mft Hot Great Gwga Stoat Causeway ioy MKT« 016212891 4M4 Fax (852) 2577 77*1Dlr®ctof a«n*raSPtMechS fCliSg RrtrtR RMgt REAmt PASHRAC31 August 1999Plaimiogp Environment & Lands BtutsauEnvironment Division9/FMunayBtdldingGarden RoadCentralHongKotigAttn: Dr Alain LamEnviionmoitalDear Siron Managing Indoor Air QualityThank you for your letter of 3 August 1999 inviting the H&E to comment on theabove captioned paper. Our comments are set out in the attachment for yourconsideration*Thank you for your attention,Yours faithfidiyIrPKKwokSecretaryGeneralEnccc: Ir Dr Gordon McKay, Chainnan, Chemical DisciplineFMORARYVWIKKICftWILLMONNiaMllO.DOCft02-SEP-1999 10:02 * ff+85223141721 P.18

02-SEP-1999 10J31 FROM TO 28278040 P. 11/12;HONG KONG INSTITUTION Of ENGINEERS* ******W '"'' ' ' ' . ' . • " ' • .. , - , .Articles missing into sentence.Indoor air pollutant* - ozone, solveais, pe^cides/fimgicides» plastic* additivesP A, section 14: "...an omnibus ImifUckkR..." (?)p.6, section 25, Selfrregukrion: "...are required to employ suitably qualified personnel tothe indoor- if ffs a, self-ftgulation a^^- who dctannines what a suitabLs qualification is?p .7, section 26: "...combined ^ith a certification ay^tem-..".-who is permitted to issue the certificates and on what basis * i.e. how is-an assessort;stanaard of workevaluated?Table 2: are fungal spores and Icgionella combined with bacteria and/or RSP? Should TSP be included onthe bajds of eye/ikin initadon?Whit about Chlorine, C102 from ihddor swimming pools?Goidaact N««» on Management af Indoor Air Quality1 . Introduction ' • . ' ,. . " . . , _ • .•,-.-• -.•..- '• . '•• . : •• •••' ":.- .-'p. 1, section 1^ * Deftoinona: I suspect that indoor swimming pools may need special consideration. .2. Background • - . : • " . • • . ' ' •• ' "•'• "'. .•""""'"• .p,13, ty liiotiB definition i*e VQCs "dxetoiodly unstable"?- hasn't CCM been banned from use in HK? . . . . ,. repeat df ccart/y tto same infonnation three times for xylenct (eon4ensis the tlueetotoone : li xylen« 11 )- possibly missini stymie, plartcisers, fire retardents, alcohOls/etfacdt/amaiies/est«^ (solvcats),hydrocarboas (ipray.caiis), ammonia (bleach?), aldehydes/organic acids- 1 suggest you consider adding:l)'Methyl-cthyl-keioxie (M£K) as it is a coimnbn adhesive /paint splvem ;.2) Trichloroethane or Dfchlotoinethanc (methylene chloride) whifihever iftiatd wort extensively in HongKong3) Polybrominated diphenyl ethers - fire retardants (see reference below)p. 17: He-write the first paragraph on Radon.p.18: Body odora - not only deodorants but also peflfai^miyha^At the bottom^f die page the section on bacteria gets a bit technical,p.20, top: "^viiusei do not survive long in MVAC systems.-. 1 ' - basis?Other Air Conttminants:Cooking in high twnperature oil may produce cairnnogenic pyrcncs as well as noxious /nuisance odouza.Smoke from incense burning,..?p.21 , section 3.1, second parigraph: does this imply that all schools should be aiming for Level 1 IAQ..... ' •p.22, top: are icre many occupational hygene professionals mH^The datp in Tables 3-2 and 3-3 need to be checked against similar overseas IAQ limits, .p.27, section 3,4 - Assessment Methods: perhaps a typical complete example could he provided in anappendix (number of saroplei, number of repeats, intervals between repeats, Ukely statisticalsignificance,*.,)p.30-31: GC for TVOO - surely, in order to use a GC* the user needs to know how many and what VOCsarc present m order to be able to calibrate &e GC (even if it is for TVOC*) - but I would noed to lookupthe * details ' " of the method ' to confirm ^nfirrn this. The last two sencetjcea should cither be ren^something like "OC/MS can provide qualitative identification wpr5vided by GC/Fffi 41 - the reference to the approved method is (as long as the method k readilyavailable in Hong Kong).10:02 > 652 2314 1721 / P.19

02-S6P-1999 10532 FROM T0 28278040 P. 12/12p32;saetion 3,4X7: is NO.a-probtemisWefl'asN02?p34: Is radon readily ad*brb*d by activated carbon?p.40, section 4,233:1 do not thrak that che last sentence adds any useful information. Source?section 4.23.4, Ga* Filters: does activated carbon actually catalyse die conventon of ozone to oxygen andthe conversion of hydrogen sulfur (sic) co sulfur (sic) at ft reasonable speed at room temperature? Source?p.*?, Table 7.2:^Congestion..,": If many occupants Ire aftected, it may be an irrational response.While this *z£&y* be correct .in some instances, it is Contentious. 1 would suggest th&t the "iccationalresponse" hypothesis should only be Investigated after a proper assessment has drawn a blankp.69, top: surely sn anemometer would pro vide a better method for measuring the ftir flow rats than a tracergas (possibility of more IAQ GompUin^ if possible pollutants are introduced for testing purposes..?)p.79, sscticn - Authorised Analyst: an up-to-ditc assessment of the qualification may be necessarysection 9.13«2 t

.**SEP 22 '39 ll:20RM THE HKIE 4852 2577 7791P.1/10TUTlONOFENdNEKS() in BK1/L3/29 VH22 September 1999(FaxNo:2827S040)i EciviroBincnt A Lands BureauDivision9/F Murray BuildingGarden Road, Central(AttarDr Alain LamAg. Principal Environmental Protectioii Officer)Dear SirConsultation Paper on Managing Indoor Air QualityWe refer to our previous letter of 31 August 1999 regarding the above consultationWe have received further comment* fiom our Building Services Division,Environmental and Mechanical Disciplines on the above document «*irt would IjVp toforward to you for your «jxmderation. The comments are set out in the enclosedYours fkithfoUyBBCccIT Dr Gordon McKayx**2S-SEP-1999 11* +852-2577 7791 P. 01

THE -;HfCIE :^-H352 2577 '7791iBMHH^^•A. Gt&eni CwLThe Building Serviowt Divisim of He HKJB fidly npports ibe gmmimieQt'spoHcy to imi»ove IAQ for the beaMi of tbe publie wi& the accaMisnioiHowever, we should aware that we should not atbw easy r^guMoM to exercisover-stringent control of IAQ with the result of higher building ©smstoisdonand mstntenance costs to the detriment of HKSAR ability to compete.2. Above all ether comments made in Ais paper in tbe seme of imposttanoe, the.major drawback andfawdwDpiacyof the Coniultaticm Psspct and Ou^aocse Notesare reflected by their failure to address tbe preventive policy, measures andexecution procedures. It is agreed by everybody tfcatpr^^than remedy. Anticipating the proMcms and avoiding them ftom occurrencein the fiHure by aSL m«ms axe tbe responsibilities of every citioen, and fix Hieprofessionals, their added responsibdlities and e

fiEP:22"*99-; ll*ElflM THE HK2E *852 2577 7791 '• . ' P,3/10system designs and drawings relevant to IAQ shoxild be ««ifiBd by the RPE' id jiobBrftted tt Btifi^^6. The qualified bmMiBg services nd modtumictl eao^M^s areeducated and trained by pmctiamg az&d ^coatfewtB pitoftsaiosialto provide quality indoor air eixvizoismast acceptable torecognised standaids - e.g. ASHRAE Staodatds 62-89, by appropriate designsof MVAC systems and the stringent supervision of the .Installation aad testingaad comniisjdo&iag of these systems, lite quality indoor air egvironnafiat caa>only te acbicvad ty tii^ comprahmahm md gmt^hlfe upeerf^repair of the MVAC installaticma, provided they are undertaken, administeredand ccsrtified by the Registered Pro&wooal^WesuggesttheMVAC system for each buMxig be inspected an^and the certificate submitted to BD orEPD,&Technical Comvusat o& Consnitetiion Faper1. Indoor Air Quality ClassesTable 2 6f the Pq?« suggests 3 diJ3fCTcntclas^ The objectives listedunder Class 1 are very stringent and should not be incremented at this earlystage, pending acc^^of implications, eto. Instead of treating ^ nx^ stringClass 1, 4csc objectivos should be treated as long tenns targets whic^subject to periodic review. .The presem proposed Class 2 objectives^Similariy,the present Class objectives should be renamed Class 2. This arrangementwould attract better acceptance by the industry and would provide betterincentive. No office owner would like to spend money to be certified to be1 IAQ parameters to be measured for certification^^I^^a. Ozone -ru>t normally a proUem.b. Fonnaldehyde - aftmctionof the tenants' decoraticm/faraishing, not thebascbuildiog.c. TVOC -not commonly a pro Wcm if CO2 &RSP figures are OK with goodventilation.t^lfflfl1' " . . . - . . ' • »3. The qudity of outdoor air taken into a bmldinf after treatment by the MVACsystem or Ito supply »r distributed to each part of fl» boildhag thould be''P.B3

*s5EF22 *99 UsaSfiM THE HKXE*8S2 2577 7791 P. 4/184&w rfbeieotfti^€X Co&iiBeiats1.The ON shodd co^^ mKkrgrox^ or midti-storey imparks, restauianti andft tbooiM abo ^pply tolight industry buildings and officc/indtaitxy conatposrite buildings wbexc officeworks and light industry operatic are carried out2. Table 3.2Level 1 of tto itcommo^cd indoor air quality should be applied, after the 3years trial period, to the buildings or parts of buildings Were the occupantshave veary long aad&ignific^3. For offices and commercia! public places, adequate outdoor air flow rates andeffective air cleaning/filtration will definitely enhance the IAQ objectives.Attention should be focused on the detection of COX KSPt room teacopttature,and outdoor air quality aftw treatment4. For buildings without central MVAC^^the requirement of providing minimum and traded outdoor air quantifies shouldbe specified for fufcrol5. BD or EFD should formulate a policy to require the buildings now insutenissicm and approval stage to meet tbe IAQ objectivefi with an agreeableeffective date,6. Codes of practice and practice notes should be issued to the consultants,contractors, RPE 1 s and architects to include IAQ detection systems into thebuilding managfiinent ^rstems or maintenance mmagement systenas should Hiebuildings have cither of them. Minimum but adequate detection parametersand points ahould cmly be provided to avoid inramiifag 1fae building cost cutmaintenance e^to our ability to cooq>cte withoverseas economies.

tvSP.2 '99' ll-ESftM 1HE*KXE +652 25777791 • P.5/10••;•-.

22 '99 ll'SaflM THEWKIE +952 2577 7791 . P.6X10''deliver a paliciilar JAQoialdoor.B- < "Gnidaace Notes for tihe MMm^mmt^flMm^ Air QuaB^r in Oflfeaand PiftLLIGeneralThe Giaidahce Note (GN) provides a veiy thottg^^procedure for practical Indoor Air quality (IAQ) level itqaxraDtiot Usatrecommended by Bnvirtasmmtal Protwtion Dqmtment (EPD). The entiredocouient also coirioins tiie technical and adininurtntive conxpittxiQr in IAQ2. Specific2-1 Section 2 (Background)This section provides a very detail category for various contaminate that existsin indoor environment It is suggested to include the relationship of eachcontaminate with other relevant parameters, say evaporation rate due tochange of air flow, temperature, other effects due to change of relativehumidity etc.2.2 Sections (lodoor Air Quality Objectives)This section clearly stated the desired IAQ requirement 4at sets out by EPD.To encourage the build^ owners to evaluate and assess ind^is preferable to quote practical and existing ryamplrs in HK. In addition tothe above, the achievable of these IAQ objectives are depend on the outdoorair quality, which is unlikely to be complied for certain area in the presentoutdoor environmoit It is also suggested EPD to consider other subjectiveassessment method, say the subject624989.23 Technical Aspect2.3.1 Table 3-2 of recommended IAQ objei^ivefl does not specify the averaging time.Itshc^bdlH^defined in HKAQO. It should be noted th^very moch dijBfen»t --ia^^ySffAC system will nonnally be gwitdbcd offmjittiQM2.3.2 Someof^poINiatotedbnologic^y undetectablc for p^'"•': ''' too short ' . " :..• . '. ; v ../. " •:•' ' v '•: "'. •: '.2577 7791


v -SEP 22 '39THE. HKIE-*B5B 2577. 7W1.'P.8/1023I^pelOToei^^, >-(b«ei*)^IniiMfeffi^^of vkw, if the benefit eamot outweigh the costfor m IAQ aasessmest (the fee %fl be iaflie order of tens of thousand fer theMl IAQ somyX ^ pogtamme eflfec^vttm seems to be questionable.The IAQ maasgem&at Gtoup doold ccattMer to wndict a cost-ad«bemfitanalysis fw tfae evafessiioii of ^oesaisws to :2.9*2 The higher the IAQ class die office acMeves, ttse Mgha the cost ofm*$ «tw«iK^ ^r^ fttftnitoigg will he. Not difficult to seali^ tot fee cost willbe shifted to the rental fee to tenants. The high rmttl cost woidd beprohibitive t0 KWW small «» Qettmf an IAQ certificate may not beii^a

^ 22 *99 li:2SflM THE HOE «S52 25777791'fiiT.. . ,.,«, „..• • ' , • • . ' • ' ! *>•* ?.;• . .. '.. such as indoor air quality. Forinstaoce, it would be rather meanicgle^ if a large amount of natural resourceshas to be consumed to achieve the reconraended IAQ objectives set out intable 2 of the consultation p^Hat Other &ctcn such as energy ccaisirmption,waste fflimjiyff iffatiffli « . . w/ shcnild riiy 1 be tttkro ^^o ooosiderxtion forperformance.a consultant in Hong Koog h^g already formulated asimilar guidance (namely, the Hong Kong Building EnvirornnerxtalAssesament Method (HK-BEAM) to designers, owners and operators forbuildings practices wfaicbthe adverse effect on the global andlocal environments while promoting a healthy indoor environment It wouldappear to be more effective if some collaboration can be established with theHK-BEAM in formtdating an integrated standard for the eovironmentalB, Consuteataoii Paper en "Mamaging Indoor Air Qnafity"1. Page l,Souit^ of Indcw Air PollutionOne of ^the sources teadBngtoj^Therefore, indoor air quaEty measurement should not be canied out for*w^fjjflg cm^plf^?« ^fti W? objectives whcai fte Air pollution indexexceeds 100.1 Pagel2 l Table2 'The units of someparametwAs the conversionfectors fix«oa the unit of ppb to ugto 1 for differaot pollutanta depend ondifferent meastmngttoriM)Wthat these p48522S?7 7791 - • P.09

VvSEF22 '99 ll:26flM THE HKIE 4652 2577 TTSlP.10/10; : . v • • • ' " • . . • ' • . '.'•.. • ' . • . 'V::^S^£S 'fT%J*T '"ft.'/!' • • . ' V ••'.""•''' • ' ' " • ' • • - . • ' '• ' ^^•vn^^l>'T? ! 'H^1'^^oH- ', • ... ..':- : .-v.;. •... . •*i vih^j^*^^^^/' 1 ^i M v; ' . . . ""•»':•-. """*' ' '' •-••*" : '••';• ^^r'•^•••• % '--- • •...;:.-. v ; • •._•---;s- ;>•v, ki *,^# v.^^v^^^%^ r,.^, . , ....• • . \-M;^.Tf^:^J v:.;^^^^^ ;; : .-:?^iO '..''TJrJ : '-*h • : ' •'"; • . ' ' ' • ' ' . • ' • • .€TritoM»N^w(GN>fer»«MC«»«^; «i*i^ i^i;* '^v'*-~- ; - ;*• "'.'y*''^'."• •-:'of the Imildmg at a itter stage iratM isx& Tot applicabk to the offices issideijcidbistn^J» slso instdkd wifePlease refer to our oommeatlniiectkmB,ptE«.2above.'22-SEP-1999 •••11^6 ; ' - 1 ,-*0S2;;257?' ; -7?9i- P.

THE HONG KONG INSTITUTE OF HOUSINGG. P. O. Box 9735, Hong Kong21* September 1999Planning, Environment & Lands BureauEnvironment Division9/F Murray BuildingGarden RoadHong KongDear SirsConsultation on MiThank you for your letter of 3 August inviting our comments on the aboveConsultation Paper.We are in support of Government's intention and detennination to improve indoor airquality in buildings. However, we have some reservations that Government shouldleave the responsibility of managing indoor air quality; particularly the control andmitigation process, to building owners and property managers. We consider thatthere should be an Authority to oversee the enforcement and control issues pertainingto the management of indoor air quality and address disputes and complaints as wellOverall indoor air quality management strategy should be comprehensive but weanticipate difficulties in implementation particularly concerning complaintinvestigation and mitigation measures. As given in paragraph 8.6 of the GuidanceNotes, the level of complaints may be affected by subjective judgements. Therefore,the level of effective mitigation is also subject to individual satisfaction. In thisrespect, property managers can only rely on the Authority to evaluate theeffectiveness of mitigation measures.Please do not hesitate to contact our Mr K L Wong (Tel: 2839 7888) or Mr C H Fan(Tel: 2579 8214), the Chairmen of the Professional Practice Committees of CharteredInstitute of Housing (HK Branch) & Hong Kong Institute of Housing if you requireany further clarification on the views from the two Institutes.Yours sincerely,HONG KONG INSTITUTE OF HOUSINGAlbert SoPresidentC:\HXmEPD.docTOTflL P.0128-SEP-1999 09:42 +85222349106 P- 01

Hong Kong Institute of Occupational and Environmental HygieneA member offotcmatidflai QtcuptiStMiai KygiPlanning, Environment and Lands Bureau,Environment Division,9/R, Murray Building.Garden Road,Centra), Hong Kong.Fax; 2234 910610 September 1999Dear Sirs,Consultation on Managing Indoor Air QualityThank you very much for inviting the Hong Kong Institute of Occupational andEnvironmental Hygiene 10 comment on the captioned paper.Attached, please find the comments from our institute for your consideration.If further information is required, please feel free to contact the undersigned at 27665993.Thank you very much for your attention.Yours sincerely,sidentInstitute of Occupational& Environment Hygiene

10-SEP-1999 17:57 FROM TO 28278040JComments on IAQ Guidelines & Consultative PaperL While it is a good idea to establish IAQ information centre to provide informationand reference to interested parties, it is difficult to see how the proposed voluntaryIAQ certificate system can get wide acceptance without making it a legalrequirement2. Paragraph 21 - che use of 'high class" to describe IAQ levels at Level 1 standardscould be mis-leading in many senses. It is suggested to use the term 'health 1 orthe like.3. Paragraph 21 - the criteria for defining various IAQ Levels should be able toprovide people with a sense of inter-relationship*. For example, while Level 2 issaid to 'provide protection to the public .....', with similar line of descriptionadopted for Level 3, the description for Level 1 should also following the samepattern and wording in description, such as 'protection 1 , 'health and safety' , etc.4. There should be incentives included in the scheme to persuade building owners toadopt the IAQ guidelines rather than jusi Voluntary 1 .5. Paragraph 25 - it is important to ensure adequate supply of 'suitably qualifiedpersonnel to assess the lAQ' parameters. Does EPD have any statistics on thecurrent manpower status for that category of professional in Hong Kong?6. Paragraph 26 - on the issue of certificates, is there mechanisms to control orregulate the authorities to ensure that the certificate issuing process is not affectedby improper influence?7. Paragraph 26 - is the certificate good for what "unit 1 of premises? Each unit inthe building? Whole floor? Whole building? There should be consideration thaithe premises in a building may have different uses.8. Paragraph 31 - the scheme may be adopted by a few of class A commercialbuilding which have tenants from multi-national establishment. In that case, fatbuilding owners may ask for a higher rental return with the certificate* It isdifficult to see similar incentives available for owners of less proper buildings.9. Paragraph 34 - why government buildings are allowed to meet a lower standardof Level 2 and Dot Level 1 ? Government should take the lead in this program.cf Notes for MatngynitJflt of IAO1. Paragraph 1.6 and Table 1-1 - it is agreed that the duties of building owners maybe modified by contractual agreement. In such cases, it can avoid confusion andargument by clearly indicating that exact party responsible for IAQ. if buildingowners or building managers are relieved of their duties by contract2. Table 1* 1 - what is the responsibilities of occupiers/tenants of the building?3. Paragraph 2.6.3 - with available lexicological information on ETS, why doesn'tEPD ban smoking in buildings? In fact, it is envisaged thai the prohibition ofsmoking can greatly improve the IAQ in most buildings.10-SEP-1999 17:40 BS2 2764 0421 99* - . •10-SEP-1999 17540 495222349106 '

10-SEP-1999 17:57 FROM TO 28278040 P. 03/044. Paragraph 3.3 - if the GN is not intended to cover industrial buildings, why needto have Lave! 3 included in the rating system? The more complicated the ratingsystem, the more will be the confusion,5. Paragraph 3,3 - it is not true that smoking is prohibited in many buildings andtherefore nicotine monitoring is not required in the assessment. Most commercialbuildings, where the ON will apply, do not ban smoking. The same is true forrestaurants and designated eating areas in shopping malls. Hence, the reasons fornot including nicotine monitoring is not strong enough.6. Paragraph 3.3 - fungal counts is different from bacterial counts in term of sourcesof problem and thus the monitoring for this category of parameters should not beomitted7. Paragraph 3.3 - air movement can determine whether the occupants are'comfortable' or not and therefore, should be required especially for Level 1certificates.8. Table 4-1 - the nature of carcinogenic compounds listed in Table 4-1 should bespecified,9. Paragraph 9.1.3,1 - the second category of authorised analyst includes personswith relevant qualifications; and has been an Approved Signatory of an accreditedlaboratory for more than 2 years. It is proposed that the 2 years of signatoryshould be on relevant areas of testing such as environmental or chemical testingrather than to include all areas of testing to be authorised analyst10. Paragraph 9.13 J - the first category of authorised analyst include suitablequalifications with 2 years relevant testing experience in laboratory. It issuggested that the 2 years of testing experience in laboratory should be replacedby 'in laboratory or in monitoring of IAQ parameters 1 . The reason being that theuse of detector tubes are allowed for some tests and it is known that detector tubesneed no further laboratory works to obtain results. Hence, it is appropriate tomake the change.11. Paragraph 9.1,3,1 - the first category of authorised analyst should includeappropriate degrees in Biochemistry if Biology has been included together withMicrobiology.12. Appendix B - the inclusion of registered safety officer (RSO) as qualifiedpersonnel for IAQ assessment would be in doubt. It is suggested that only thoseRSO who have had attended approved training courses on IAQ can be included asqualified personnel. For similar reason* 'person with IAQ assessment training'should mean a formal certificate awarded by examination and not just attendancecertificate.10. The whole idea, of doing something on indoor air quality and (he general directionof the documents are agreeable,1L It may not be necessary to classify IAQ levels into three classes since industrialbuildings are excluded from the application of the guidelines. Level 3 which is onCKJCupaUorxtl cxposurei and which are most corrOTOnly occurred in industridbuildings can be dropped to simply the picture.Ift^KSSl?.* ^>^4 9106 P-03

.0-SEP-1999 1?:S7FROMT0 rn 3P99fi0a0 P. 04/042827804012. There should be some kind of incentives to building owners to join intothe project voluntarily.13. Because there are i wide range of TVOC and each may have differenttoxicological properties and safety standards, if may be necessary to citerecommended levels for individual chemicals.14. Government buildings should be able to meet Level 1 standards as a goodexample to the general public.5S. Cam must be exercised in identifying appropriate professionals to undertake IAQassessment The details of training courses of the professionals should be studiedOnly those which have actually included an acceptable indoor air quality trainingcomponents can be accepted For example, there should be hesitation to includeprofessionals with general safety training and who had not gone through trainingcomponents on IAQ as qualified IAQ assessors. The same opinion also applies toprofessional engineers who have no training on IAQ,16. There may not be adequate training courses on IAQ to accommodate demands bypeople who wish to enter into the professions.10-SEP-1999 17*40 +852 2234 3106TOTAL P.04P.04

26/10 '99 16:39 852 2868 4612 HKIS Pg. 02THE HONG KONG INSTITUTE OF SURVEYORSSuite 510 Jardine HOUW, 1 Connaught Plaea, Central, Hong Kong Tel: (852) 2526 #67$ Fax: (852) 2868 4612SB: (862) 2526 3679 HSflK^fSKft 2868 4612hMp:/A«fl»w.hW8.org.hk20 September, 1999MrKASaIkeId,JPDeputy Secretary (Environment)Planning, Environment & Lands BureauEnvironment Division9/FM;iiray BuildingGarden RoadCentral, Hong KongBy FAX (2234 9106} ap $y PtetDearMrSalkeldConsultation Paper on Managing Indoor Air Quality (IAQ)Thank you for sending us the captioned Consultation Piper aa well as a set odtGuidaiice Notesfor the Management of IAQ in Offices and Public Places (the GN) for our comtiicat.We welcome Governments initiatives as set out in the Consultation Paper $n *ldressing theIAQ issue which is an important attribute to human health and woxk proclii^il^. ' We alsoacknowledge the overall complexity of the subject of IAQ in terms of legajl ^iax^BWMJc, publicunderstanding, technical details, implementation and enforcement. Inevft^, 1 fecre will becost burden to building owners or tenants if they arc required to comply w&laid down in the GN. Having said that we My support the po^level of IAQ in Hong Kong and are prepared to extend our assistance in aOT^mglhe IAQobjectives and standards; in particular through our members' professional j^iticw'in.Tpropeitydevelopment, building design, construction, leasing, property management mAs regards the content of the Draft GN, we would set out our w(1) The success of the self-regulation scheme and certification system tt^.djqpcnd on anumber of factors among which are how likely the measurements t&e| ty. ^buildingowners can comply with the objectives and owners 1 degree of copt$

26/10 '99 16:40 852 2868 4612 HKIS p g . 031.2 Close monitoring on or control over tenanfg choice ofpremises, fitting out material they use etc. is practicallywhen it involves legislative issues such as fire andstraight forward,age of theare more1.3 The source of some pollution like bacteria, TVOC, fonnalcE^Ni 5&SP etc. areusually generated by tiie tenants.(2) The assessment scheme should be based on the responsibility of awhat they can practically control Our suggestion is to take mfollowing parameters and locations:owner andneoti on theiFresh air quantity supplied to every occupied space.Quality of the fresh air (to make sure fresh air intakes are ndt itar any pollutantsources).iiivviviiRSP at supply ducts and return air ducts to ensure thai th^jfflte* sore beingoperated and maintained properly.CO 2 at return air plenums/ducts to ensure in general, an appropriatefresh air has been supplied to the tenants.unt ofFormaldehyde or TVOC at return air plenums/ducts and pilbfie ijlws.to ensureno excessive sources of those pollutants are being ga&n^fy^owners and in general, enough fresh air has been provide^ to, dilute thosepollutants.Radon at public areas to ensure enough ventilation has been iioiridodito diluteany radon gas,Building owners to cany out detailed investigations.measurements indicate that there is a problem or when ocreceived.the abovehave t>cen...7P326-QCT-1999 16:37 85228684612

26/10 '99 16:40 852 2868 4612 HXIS Pg. 04(3) The GN suggested various methods to take the^methcxls may come up with dif^^only one measurement method so that there can be 230 confimoncompared with what Le. we compare apples with apples*vjiat'is being(4) Only a few Orade A office towers may have the r to If tbebuilding owners find the assessment impractical for them to acMe^^thcy" : will justignore it Given the low proportion of woxkers woridng in those Ora^e A offices, tbeproportion of workers benefiting from the scheme would be minimal -(5)(6)The degree of influence of the tenants' committee is a toy to theBut we doubt that the influence of the committee members will havethe actual procurement or fitting out decisions of their company.iiidi bearing onIt appears from the GN that the EPD is not prepared to establish a Igst of alternativematerials and suppliers for less pollutant-emission materials. We befeyc that this kindof list is critical to the success of improving IAQ as this will -*e marketcompetition and will generate a force to produce IAQ fiimdly ij . Alsoinformation to the committee members is important as they neei to mow whatalternatives are available and how to obtain them. Suppliersincluded on this list(7) We suggest that the EPD should registered the IAQ committees.the effectiveness of the programme and also provide a channelinformation and getting feedback*monitoringof(8)Extensive training workshops should be carried out by the EPD ft irain the IAQcommittees on the details of the GN. We would expect (hat most W toe committeemembers will be laymen in IAQ especially those fiom tenants.We obsove that smoking is still amqor source of indoor air ix>tf^restaurants and entertainment premises. The GN should therefore tkj jsctatfhing moreon fliis problem...JP426-OCT-1999 16*37- 852 2868 4612 98X P.04

26/10 '99 16:4! 852 2868 4612 HKIS Pg. 05Page 4(10) We understand that the HK-BEAM, which is a similar voluntary scqaae,' has alreadyincluded IAQ among other environmental issues. Why not adopt

H HE 4? 4r % 4THE HONG KONG OCCUPATIONAL SAFETY AND HEALTH ASSOCIATION^ _^ f jj. _ .«. ^ (Incorportedwi^LM^UaiMy)21* Anniversary, 21 st CenturyEnvironmental Protection Department(Branch Office)33/F, Revenue Tower5 Gloucester RoadWanchai, Hong KongOurRef:CSU-99-058September 10,1999Mr. Patrick M BURKEmmmmm(1998 Jt 1999Attention: Dr Alain LamDear Dr Lam,fillConsultation on Managing Indoor Air QualityWe have pleasure in submitting our opinions on the captionedsubject as enclosed.In general, we support the proposed IAQ objectives andimplementation program, and appreciate the effort of yourDepartment in making known to the community the hazards ofpoor indoor air quality, and in devising the improvement program.Yours sincerely,r n~fWaiYmWONfl^President (/soft*G. R O; Box 7100, Central, Hong Kong.Tel: 2332 9210 Fax: 2770 0542 E-mail: hkosha@hk.supennetHomepage address: http://www.hk.3Uper.net/-hkosha5§fr Ml AHONORARY ADVISERSThe Hon. Yiu Chung TAM» JPMr. Raymond A BATES, JPProf. Yiu Chung CHENG&. Dr. The Hon. Raymond C T HOMBE.SBStJ.jpMr. Yuk Lira YIPProf. TP LEUNG JPIr. James BLAKE, QBE, JPThe Hon. Sai Chit HO, QBE, JPProf. Ngok LEE, JPDr. KM Hung SHUENHonorary Legal AdviserMr. Patrick M BURKEHonorary AaditorMr. Paul MP CHANBxecvtive C0vnett (1998 Jk 1999)Pntidettt Mr. Wai Yin WONGVtePrtsldeat Mr.IvmnKWLAMHan. Secretary Mr. Victor C L KWONGHon. Tmtasnrer Dr. Twmy Y F TS ANGMembersDr. Alex K W CHEUNGMr. Yiu Kucn KAMMr. Chi Sing LAMMr. AndyHYLOMr. Chi Ming LAWMr. Danny KH MAMr. Danny C W TONOMr. Scorpio W C WONGMr. Yum Yin WONGMr. Chung -Vfcen YEUNGMr. Nelson K C YUInmtdUte Past PntsidtntDr. Alex KW CHEUNG

Hong Kong Occupational Safety and Health AssociationTo : Environmental Protection Department1. BackgroundOpinions on Managing Indoor Air QualitySeptember 10, 19991.1 The Association was invited by the Environmental Protection Department (EPD)to comment on the following two documents:(a) Managing Indoor Air Quality-- A Consultation Paper, and(b) Draft Guidance Notes for the Management of Indoor Air Quality in Officesand Public Places.1.2 The Hong Kong Occupational Safety and Health Association is a learned societyestablished in 1977 with the objectives to promote the development ofoccupational safety and health in Hong Kong. Crarently, we have about 450individual members and 55 company members. The majority of the individualmembers are safety professionals, Registered Safety Officers, and professionals inother disciplines who are interested in promoting occupational safety and health.1.3 The Association views that Indoor Air Quality (IAQ) greatly affects the health ofpersons in workplaces, and that IAQ is one of the factors for occupationalaccidents but is not easily verifiable and is seldom addressed by the accidentinvestigators.2. Comments2.1 The Association generally supports the policy and implementation program forimprovement of IAQ as proposed in the Consultation Paper. However* we haveopinions as set out in the following paragraphs for the consideration of EPD.2.2 It may not be necessary to classify IAQ levels into three classes since industrialbuildings are excluded from the application of the guidelines. Level 3 which ison occupational exposures that are commonly occurred in industrial buildings canbe dropped to simplify the picture.23 As the quality of intake air and the maintenance of air filters in the air conditioningsystems are two crucial factors to the IAQ, but are relatively less technical and lesscostly to be handled by the building management, the checking and, where

necessary, modification of the intake points of outdoor air, and Hie frequentcleaning of air filters should be placed in priority in the educational and legislativeprograms.2.4 Renovation works and pest control activities will cause acute effect to poor IAQ,and may lead to a disaster to the occupants. Strict controls to these two kinds ofactivities which are commonly carried out in buildings should be legislated andenforced in priority.2.5 There should be some kind of incentive to encourage building owners to join theproject voluntarily.2.6 As there are a wide range of Total Volatile Organic Compounds (TVOC) and eachmay have different toxicological properties and safety standards, it may benecessary to cite recommended levels for individual chemicals.2.7 Government buildings should be able to meet Level 1 standards as a good exampleto the general public.2.8 Care must be exercised in identifying appropriate professionals to undertake IAQassessment The details of training courses of the professionals should beexamined. Only those which have actually included an acceptable indoor airquality training components should be accepted For example, there should behesitation to include professionals with general safety training and who had notgone through training components on IAQ as qualified IAQ assessors. The sameopinion also applies to professional engineers who have no training on IAQ.2.9 There may not be adequate training courses on IAQ to accommodate the demandby people who wish to enter into the professions.3. CONCLUSIONSWe generally support the proposed IAQ policy, strategy, and guidance notes.However, further consideration by EPD is required in respect of the criticalcomponents of IAQ; the likelihood of disaster caused by poor IAQ; the costeffectivenessof improvement measures to be taken by building owners; thecompetence of IAQ assessors; and the provision of IAQ training, as detailed in theabove paragraphs.WYWong, jpfeadent

FR'OM* sHKPC TO t +852 2827 8040Hong KongProductivity Council«*&S*C*ftEnvirenmcnut Management DW«!onOur E-mail:HKPCA)102AflSC/199909/99906rfi6* September 1999 By Pax Only(Fax.:22349tW)Planning, Environment A BureauEnvironment Division9/F, Murray BuildingGarden RoadCentralHong Kong jDear Sir,'• iConsultation on Managing Indoor Air QualityReference is made to EPD's letter re£ () b EP21^captioned subject. jWe are pleased to enclose our comment on the consultation documents foryour kind consideration.Thank you for your attention.Yours sincerely,for Executive!ent Divisionc.c.:Dr. Alain Lam-EPD (Fax: 28278040)14:59 652 2786 5603 95X P. 01

FROM :HKPC TO s +852 2827 8040 1999.03*06 14:48 #324 P. 02/02Gmsutoticm on Managing Indoor Air Q^llty-Comments framHKPC1.3.iWe welcome and applaud the Government to take lead in tackling indoor air quality(IAQ) problems in offices and public places. The issue has been gaining publicattention in recent years and appropriate action has to be done properly and quickly.iWe also agree ito the broad approach to tackle the IAQ issues through voluntary selfregulationapproach combined with a certification system to declare the level ofcompliance to the IAQ objectives.iWhile we appreciate the need to set different levels of IAQ objectives in order toencourage participation by property owners to improve their buildings IAQ> we havestrong reservation to set the proposed Level 3 IAQ objectives at the OccupationalExposure Limits (OELs). As pointed out in Section 3.1 of the Guidance Notes for theManagement of Indoor Air Quality in Offices and Public Places (page 21), IAQobjectives are intended to protect a more diverse target population which may includechildren, the aged and infirm, and people with chemical sensitivity. The proposedLevel 3 IAQ objectives totally fail to offer such protection to building occupants. Itshould be noted that the Occupational Safely & Health Ordinance (OSHO) alreadyrequires statutorily full compliance with the OELs and so it seems inappropriate to setIAQ objectives at OELs in this voluntary regulatory system of IAQ managementWorse still, w&en such Level 3 objectives art set for the public, it would misdirect thepublic to aim at this level of objectives and be satisfied with such level. If that is thecase, the whole purpose of the IAQ management system would break down. It issimply not sufficient to make a bare statement just to encourage achievement of at leastLevel 2 objectives (page 24 of Guidance Note).effort to impmvmgr TAQ ftf offiMn mA pnhlie plicM. we thtrtfnr* •iiyqrit to dtltttL*yJ a nhjerfivi* fnmpletely and «*t fh* minim urn reqiifrmifetit to achieveTI»We agree to set professional qualification requirements on Authorized Analyst andCompetent Examiner. The proposed qualification requirements aw appropriate.iThe proposal to set up an IAQ Information Centre is welcome. If resources allow, wesuggest setting up the Information Centre in first phase so that it can be in line with thepublic education and publicity campaign. We believe that the public education andpublicity campaign will be more effective if an IAQ Information Centre has already beenin operation. '7.We agree to require all government buildings to conduct annual inspection and certifytheir compliance with the Level 2 objectives. If resources are available, we hope to seesuch action being implemented as early as possible.• . iWe suggest including total fungal count in the parameter list for IAQ objectives becausefungi can leadlto adverse health impacts and fungal count cannot be adequately reflectedby bacterial count.Prepared by Hong Kong Productivity CouncilDate: 6* Septembcrl999Environmental Management DivisionHong Kong Productivity CouncilHKPO0102/MISC/l99909/99906rOPagel06-SEP-19i9 14*59 852 2768 5608 95* P.02

n« HONG KONGPOLYTECHNIC UNIVERSITYftffl Att U«H*4e K«« cFACSIMILE TRANSMISSION*#*»&,>mm?£**!?"CtaM-kiwisj,0! J^iMtAMliTljffiy •«•"Mr-A fa iP-I^m — -»_—_Fax No.:7234t9lQfi* ——TOtfMimt (SttlFrom: T>r ^""^3 Q lf ADate: r^qpt^nn^rQ, TQM j^j.No of pages (including this one):Dear Sir.Comments on the Consultation on Managing Indoor Mf Qi M^fYEnclosed please find my comments on the above document.L(i)(ii)(iii)RSP setting at < 20 ug/ni 3 (8 hr avg.) for Level 1 is really hard to maintain formost of indoor environment especially public places such as shopping mall,theaters, etc.I suggest to put < 100 ug/m 3 for level 1Besides airborne bacteria, fungi should also be included in the IAQ objective.Under Table 4-1, classficauon of emission rates for carcinogenic compounds, it isreally expensive and complex to certify 5 ug/mVh for carcinogen compounds.There will be some problems to define which compounds are carcinogen, some ofcompounds are suspected carcinogen (not confirmed), I suggest to delete this itemand just use TVOC for a screening purposes OR define specific copounds such asbenzene, toluene, etc.Sincerely,Air-Lab-In-Charge and Asistant ProfHong Kong Polytechnic University

THEHONGKONG & r^vaiem**/UNIVERSITY OF * QeafVowrOoy5OENCE&TECHNOLOGYW.: (852) 2354 8650Planning, Environment & Lands BureauChristopher YJH. ChaoEnvironment DivisionAssistant Professor9/F, Murray Building Tel: (852) 23S8 7210Garden Road, Central, Hong KongE-Mail: meyhchao@ust.hkDear Sirs/Madam,September 6,1999HE: Comments on the Draft Guidance Notes for the Management of IndoorAir Quality in Offices and Public PlacesA consultation paper and a set of guidance notes on the captioned subject wastransferred from the School of Engineering at the Hong Kong University ofScience and Technology to my office for comments. I have carefully revieweddie consultation paper and the guidance notes and I am very pleased to notice thatthe government is willing to take an initiative step in setting up a framework forindoor air quality management in buildings. Some comments are attached herefor your consideration with the aim to make this framework and the set ofguidance notes more dear and effective in the implementation.1. The guidance notes propose a certification program for IAQ assessment inbuildings under a voluntary basis. I think the concept of self-regulation isgood. However, it is not dearly written down in the draft guidance notes howthis certification program will be conducted. The document has implied thatthe government will be the authorization party and two professionals aredefined for the certification purpose. One group is called Authorised Analystand the other group is called Competent Examiner. It seems to me thatAuthorised Analyst will be the one taking care of the quality control of thelaboratory testing work and Competent Examiner is the one who manages andimplements the assessment scheme. Including two professionals in the IAQassessment will make the cost for each test very expensive and I am worried ifthe majority of the building owners can afford it. In many IAQ measurements,

09-SEP-1999 10541 FROM TO 28278040 P. 02x05such as measurements of carbon dioxide, carbon monoxide or the variousthermal comfort parameters,, measurement is conducted on sites and I tMnkthe Competent Examiner can handle the quality control Other parameterssuch as TVOC, if the sample is analyzed in an accredited commerciallaboratory or in a research laboratory with track record in indoor air qualitystudy such as an university laboratory, the quality is up to a certain standard.My opinion in this is that we do not need two groups of professionals in the .certification procedure. 1 think these two groups of people are equallycompetent in participating in the certification exercise and the most importantpart is their track record and past experiences in "IAQ" study in "buildings",not whether they are laboratory scientists or professional engineers. The roleof other professionals defined in 9.1.1 and 9,1.2 is also not clear in thecertification procedure.2. It is not dear about whether all the premises inside the building are needed forassessment in the certification program. It is practically impossible if all thepremises are needed for detailed assessment as it will be very costly* In thedocument two concepts are laid down, i.e. screening test and detailedmeasurement, although in many areas description of when these twoapproaches should be employed is confusing. I suggest that simple screeningtest on carbon dioxide as an indicator of ventilation adequacy and walkthroughinspection on the general hygienic and maintenance condition areneeded for all premises. The competent person is then required to suggest tothe client which floor is needed for detailed assessment and for certificationpurpose, I believe that the competent person will not encourage the client toapply for a certification if most of the floors are in poor condition. He willonly do so if most of the floors or all of the floors are in good condition. Inthis case, the authority may specify in the document that detailedmeasurement results of a limited number of premises are needed in thecertification exercise.3. The document does not specify clearly whether all the 1AQ parambe met if a certain level is targeted at, even if it looks like that. Clarification is•09-SEP-1999 10:24 +852 2234 9106,

2|9~SEP-1999 10241 FROM T0 2827B040 P. 03/05needed in the document It is also not mentioned how often this assessment». .i* should be carried out in order to keep the certified level.4. Measurement of the parameters listed in the document i$ sometimes hard todistinguish smoking areas from nonsmoking areas. In some of my researchworks, I have noticed that some smoking offices passed all the Level 2requirements. However, we could still clearly identified the smell of ETS andour perception told us that those offices could hardly be considered asacceptable. The problem is that RSP and TVOC levels are correlated to ETSbut the correlation may not be as strong as what we thought before (philips K,Howard D.A., Bentley MC, Assessment of Environmental Tobacco Smoke .and R&spirable Suspended Particle Exposures for Nonsmokers in Hong KongUsing Persona! Monitoring, Environment International, 24(8), pp. 851-870,1998).5. Is 3.4,1 part of the requirement of 3 A2 on pages 27*28?6. On page 30, measurements at the mixed air supply and exhaust plenum aretechnically not feasible in many buildings. There is usually no provision inthe HVAC ductwork for you to put your sensors in and in most of thebuildings, clear location of exhaust plenum does not exist.7. On page 30, what happens if levels of the individual VOCs as shown in Table3-3 are acceptable but TVOC level exceeds the objectives, which is possiblein miny cases?8. It is noted that fungi measurement is not included. However, recent researchhas indicated that ftingi count has been related to a lot of "sick buildingsyndrome" related cases and VOCs can be emitted from many flingi matters(Bayer C, Crow £A., Fischer J., Causes of Indoor Air Quality Problems inSchools ~ Summary of Scientific Research, Department of Energy, USA,1999).09-SBM999 10:24 4852 2234 9106

09-SEP-1999 10541FROM:TO 28278040P.04/05Yt* •«.9. While alpha trick detector is used for radon monitoring, do we need to*. consider the evening profile and the morning profile,10. Appendix B specifies the skeleton for compliance with OSHO and I have thefeeling that the appendix indicates that CO* is the only parameter that isneeded unless high COa level is measured. Measurement of other parameterswill be subject to the professional judgement of the consultants themselves. Itimplicitly means that most buildings will only measure COa as it will be varycostly to measure other parameters. I am generally agreeing with this but the..final outcome really depends on the quality of the consultants4n judging ~whether other parameters are needed. In Appendix B, even though the levelof CO* for concern has not been listed explicitly, it has been implicitly leadingto 1000 ppm or something close to this level as ASHRAE 62-1989 has beenreferred to as the industrial standard to estimate the amount of fresh airsupply. This 1000 ppm COa level is inconsistent with the 5000 ppm DEL for *COa for the Level 3 compliance as shown in Table 3-2.11. Is subway concourse included in this document?12. Indoor air quality is a new area and a lot of new information is coming out Iwould suggest that update of the document is needed regularly. Meanwhilethe research effort in Hong Kong on indoor air quality is far away from beingsatisfactory when compared to other overseas countries. The governmentshould consider taking the leid in collecting research data which can be usedto fine-tune the standards and levels set in the guidance notes rather thandirectly copying overseas experiences. It should be noted that establishment ofa standard or guideline in an overseas country has actually gone through manylong-term research developments supported by the government. Hong Konghas been slow in this aspect and we should not still rely on our previouspractice of not collecting our own database but just look it overseas guideline.I would suggest that more resources should be allocated to the indoor airquality group at EPD for initiating the IAQ management program in HongKong. The program should be a comprehensive one including education and09-SEP-1999 10:24 4852 2334 9106 P«04

09-SEP-1399 10:41 FROM TO 28278040 P.05/05lesearch development. In fcet I am pleased to see that a lot of activities havebeen planned as laid down in the consultation paper.Sincerely,Christopher QuoAssistant Professor of Mechanical Engineering-The Hong Kong University of Science and Technology09-SEP-1999 10824 +852 2234 9106TOTAL P. 05P.0S

BONG KONG COLLEGE OF COMMUNITY MEDICINEFomdu CoUefe of lfe« Ume Xoac AndMiy of Mvdlctaefwrporattd wtih Kmittd KuttlilyDr. Alain LamPlanning, Environment & Lands BureauEnvironment Division9/F., Murray BuildingGarden RoadCentralHong Kong26 August 1999Dear Sir,Consultation on Managing Indoor Air QnalityThank you for your letter dated 3 August 1999" inviting mycomments to the consultation paper on managing indoor air quality (IAQ)and the guidance notes for the management of IAQ in offices and publicplaces.My comments are as set out below:1. The setting 3-level IAQ-It is inappropriate to compare workplace IAQ (level 3) withpublic place IAQ (levels 1 & 2) as both are different.02-SEP-1999 10J02 +85223141721 P.09

02-SEP-1999 10:27 FROM T0 28279040 P.02/12From your description of public place IAQ. in the consultationpapers, the major differences are -Public Place IAQWorkplace TAQ (PEL)(i) Aim comfort as well as health protection onlyhealth protection(ii) Target all people including adult employeesthe very young andthe aged which arenot present in theworkplace(iii) Use as a goal (something as compliance standardsto achieve or aspire (minimum standards forto and which the compliance with thecommunity should Occupational Safely &work towards) Health Ordinance andRegulation)To grade workplace IAQ (OEL) with public place IAQ is likegrading apple with orange. As the aim, use and target in thesetting of these two standards are different, workplace IAQ(OEL) should not be portrayed as an inferior one. There isno place in the world which groups public and workplace IAQtogether giving different gradings. It would cause confusionto both the duty holders under the Occupational Safety &Health Ordinance and Regulation and the general public.Instead of setting 3 different levels, other developed countries,such as Australia, are calling for harmonisation ofoccupational and public indoor air quality standards. Therehas been established practice of bonrowing occupationalstandards as a basis for indoor air standards because of thelarge number of well developed occupational exposurestandards. For example, ASHRAE in the standard forVentilating for Acceptable IAQ have used a concept of settingIAQ standards at one-tenth of ACGIH threshold limit values.02-SEP-1999 10:02 +85223141721 P-10

02-SEP-1999 10:27 FROM T0 28278040 P.03/12You may wish to refer to the paper published by E. Emmett,Worksafe, Australia entitled "Harmonisation of OccupationalPublic Health and Indoor Environment Air Quality Standards".A copy is enclosed for your easy reference.To complete the whole spectrum of IAQ for public places, it isessential to develop compliance standards (minimumstandards), so as to assist the employers in public premises todischarge then: legal obligations under the Air PollutionControl Ordinance. Level 3 IAQ should be replaced by a setof compliance standards for public pB^es IAQ.^ WorkplaceIAQ should be a separate category of air standards,2. Self-regulation:The idea of self-regulation is good However, the question ofwho are the suitably qualified personnel? There should be asuitable authority to register these suitably qualified personnel.In the Code of Practice (para,, vague terms such as"person with relevant academic and professionalqualifications" "2-years relevant testing experience inlaboratory" have been used. There is a need for aGovernment department or a central agency to act as aregulatory authority to determine whether the professionalqualifications and experience are relevant or not and to takedisciplinary actions for non-compliance with their professionalconduct and ethics.Yours sincerely,c.c. Dr. T.H. Leung (w/encl)Secretary, HKCCM(Dr.-WX.LO)on behalf of the Hong Kong Collegeof Community Medicine02tSEP-1999 10:02 + 852 2314 1721

Hong ftong Radiation Protection Societyc/o Radioisotop* Unit, The University of Hong KongPokfulam Rood, Hong KongTel: (852) 2859 2547 Fax (852} 2559 5557Hon. Advisors36f!tH!!i&£tProf. H.K. Changm®&&Prof. Edward K.Y. ChenM&ftftProf. Y.C.Cheng£8*385Prof. Arthur K.C. LiProf. O.K. PoonDr. Alain LamActing Principal Environmental Protection OfficerEnvironmental Protection Department Branch Office33/F, Revenue Tower5 Gloucester RoadWan Chai, Hong KongSeptember 9,1999«**»**Hon. FellowsOr. Margaret Chan78£&f$$Prof. 23-qiang Pan&?:&»£Or. Hector T.Q. MaHon. Legal Advisor&*$&£Mr. Carson WenAuditorMr. Charles ChanExecutive ***** CommitteeChairpersonW3E*»W±Dr.M.Y.W.TsoVice-ChairmanWWIfdtDr. K.Y. CheungttttffcftHon. SecretaryDr. K.M. Mamm*Hon. TreasurerOr. J.K.C. Leung** MembersnwKwaMs. Joyce Leung^CtiftttdrDr.C.K.Man*f»SMCo-opted MembersMr. K.M. Cheng«*&&&Mr. Harry H.C. LaiDear Dr. Lam,Consultation on Managing Indoor Air QualityThank you for inviting the Hong Kong Radiation Protection Society tocomment on the Consultation Paper on "Managing Indoor Air Quality" and"Guidance Notes for the Management of Indoor Air Quality in Offices and PublicPlaces".We are impressed by the sophistication and details contained in thedocuments about management of indoor air quality. Since indoor air quality isrelated to many kinds of pollutants, and out of all the pollutants, only radon andits progeny are radioactive, we shall only comment on the issue of radon and itsprogeny from the radiological protection point of view*Radon and its progeny, like other common indoor pollutants, are mainlygenerated indoors for high-rise type buildings and therefore can be removedprimarily by improving ventilation. In this respect, we agree that the generalmanagement for indoor radon should be the same as for the other indoorpollutants. However, unlike the other carcinogenic pollutants, radon and radonprogeny exist everywhere, in workplaces and in dwellings. For this kind ofchronic exposure, it is advisable to adhere to the ALARA (As Low AsReasonably Achievable) principle.Although many countries and international authorities have adopted 200Bq m" 3 as their radon action level, there are countries that use a lower level, suchas USA adopting 150 Bq irf 3 for both existing and new homes. Since radonaction level has to be decided according to local factors such as geology, buildingdesign, social and economic factors, we would like to recommend the adoption of150 Bq m" 3 as the radon action level for future newly built buildings, whetherresidential or non-residential. The recommendation is based on the followingreasons.Mr.AndyH.K.LawIMWf±Dr.M.C.Wong

Hong Kong Radiation Protection Societyc/o Roc/foisotope Unit, The University of Hong KongPokfuhm Road, Hong KongTel: (862) 2859 2547 Fax: {852} 2559 5557mm®Hon. Advisors2-Prof. H.K. ChangProf. Edward K.Y. ChenProf. Y.C. ChengProf. Arthur K.C.UProf. C.K. PoonHon. FollowsOr, Margaret ChanProf. Zi-qlang PanDr. Hector T.G. MaHem. Legal AdvisorMr. Carson WenSlfcWAuditorMr. Charles ChanExecutive CommitteeChairpersonDr.M.Y.W.TsoVice-ChairmanDr. K.Y. Cheung**«* Hon. SecretaryDr. K.M. MaHon. TreasurerDr. J.K.C. LeungMembersMs. Joyce Leung1. We all live and work in crowded space. Simple calculation of therequirement for ventilation will show that the ventilation rate, ifmaintained, will be sufficient to reduce the indoor radon concentration tobelow 150 Bqm" 3 .2. By using the results of a territory-wide survey of indoor radon, we havederived a radon action level by balancing the protection cost (electricitycost for increasing ventilation rates) and the detriment cost due tooverexposure to radon and its progeny. With the continuous growth ineconomy, it is expected that protection cost will be cheaper while thedetriment cost will increase. The paper that describes the choice of actionlevel is attached for your reference.Indoor radon mainly comes from the concrete of the building and theirexhalation rate from the concrete should be more or less the same for differentbuildings. Since the indoor radon concentration is inversely proportional to theventilation rate, it is logical to use the indoor radon concentration as an indicatorof ventilation rate. By using simple grab samplings or radon sniffer, it will tellwhether the ventilation needs improvement or whether other indoor air pollutantsshould be measured.In addition to the above recommendation, we have noted some mistakesin the document "Guidance Notes for the Management of Indoor Air Quality inOffices and Public Places" and they are given below.p33 second last line. Does it mean long term and short term samplers instead ofpassive and active samplers?p.34 line 8. ICRP is not an international standard.Yours sincerely,Dr.C.K.ManCo-opted MembersMr. K.M.ChengMr.Hany.H.C.UiDr.M.Y.WongTsoChairperson,Hong Kong Radiation Protection SocietyMr. AndyH.lt LawWJWfcfcDr. M.C.WongMYWT/smEnc.

09-SEP-1999 14537 FROM TO 28278Q40 P. 01DEPARTMENT OP HEALTHCHEST SERVICE CENTRAL OFFICEHONGKONG**«« OUR HER: (62) in TBHHONG mm,Td; ($53)25726033isDirector of Environmental Protection(Attou: Dr. Alain LAM)Environmental Protection Department33/F, Revenue Tower,5 Gloucester Road,Wanchai, Hong Kong.Pax: (152)21346627Dear Dr. LAM,Consultation on Managing Indoor Air QualityThank you for your letter dated 3 August 1999 with documents related to the captionedsubject I dunk the Inter-departmental Indoor Air Quality Management Group has done avery good job in making the correct step forward in the control of indoor air quality.A few points which I would like to clariiy:(1) Concerning the 3-level IAQ objectives, will there be other levels to describe thesituation as not good/bad?(2) Concerning the certification system, will the owners and management of premises needto measure the indoor air quality daily and put up the results for the public'sinformation?Many thanks.Yours sincerely,Dr. CM TarnConsultant Chest Physician i/cOM.11HAII09-SEP-1999 14526 +852 2574 2439 99*TOTftL P.81P.01

10-SEP-1999 17:59 " FROM TO 2S278040 P. 01/01,-OCCUPATIONAL SAFETY & HEALTH COUNCILWE, Chlita Uoiccd Ontf*. 26 tfuMt «o«f .Nor* Kate*. ffeni K*a$.OH FAX: 2739 9779Mail mdfat plftfl/ftf)Planning, Environment & Lands Bureau * Date: 10 Sep 1999Environment Division9/F, Murray BuildingGarden Road, CentralHONGKONG(Attn Dr Alain Lam)Dear Dr Lamn "Manain T?idiir Air ulit Y \ - AI refer to your letter on 3 August 1999. On bebalf of the Council, I would like to makesome comments on the captioned paper. *1.It scons thai lifi Govcrxuniat inle^ Alsomany department* aie iavolvod in this I AQ program, it it the right time to establish clw guidelinestpplicable to an trades and occKioai l^pobKc^uUliketos^gddaiictnissiicd to uio fa offices and pMe pla^iiutusny purposes.2. Eivforccjpenr policyThe implementation of the IAQ program calls for the volnmaiy panitipirioA of bundingowners/managcmciiL Th£ consultation paper tiay also dlsdose the enfbrcemem policy by the variousdeparatituis in jexusxsil or during the irapleixur*'«4Cioii period.3. IAQ information, centreUis toodtohiveacoiiial sooareeof iof

19/F., Vocational Ilraining Council Tower, 27 Wood Road, Wanchai, Hong Kong.®:m^mYour Reference. EP21/L3/20 Vtt v - '_i^ M- - • • «•» ifate " • •"• • • • • '' " •3fc ® W mTelephone No. ., 2836 1915. 0030 me^T- 28380667 8 September 1999Facsimile No.m "•*

•I/ - ' ' . .Comments &a the Consultation Paper^Managing Indoor Air Quality**Over the past two decades, there has been a growing awareness of environmentalprotection in Hong Kong. People are recognising the need to conserve energy and tocombat pollution problems. Ten years ago, the Government released the 1989 White Paperon Pollution. Four years later, the Paper came under its second review, at which time theGovernment recognised the existence of indoor air pollution and the potential health risksassociated with it, e.g. Sick Building Syndrome. We are veiy pleased to see that theGovernment is proposing a new programme to tackle the problem.Establishing the Right ApproachMany other cities and countries are experiencing indoor air pollution problems similarto those facing Hong Kong and a wide range of measures have been implemented indifferent parts of the world. We believe that the way to improve IAQ should include a totalevaluation process of the built environment which involves planning, design, construction,operation and maintenance of buildings. In developing a solution for Hong Kong, theappropriateness and effectiveness of the preliminary exercise should be critically evaluatedbefore launching a full-scale programme. In formulating the final plan for an IAQmanagement programme, considerable attention should be given to the comments from thebuilding services and management industries as good IAQ relies heavily on the buildingCervices engineer, building mainten^Manpower RequirementsImplementation of the proposed programme mentioned in the Consultation Paperbrings with it a growing need for indoor air quality monitoring activities which in the longrun would require more competent personnelfor the labour-intensive activities in measuringindoor, air pollutants/Section 32 of the Consultation Paper mentions that thegovernment wilt invite VTC to provide training. We believe that the Department ofApplied Science, Institute of Vocational Education (Chaiwan), has expertise in monitoringIAQ and providing the training for personnel to perform the monitoring work listed in Table2 of the Consultation Paper. This can be in the form of a series of short courses, TheDepartment also offers a Higher Diploma course in Environmental Technology, withinwhich IAQ topics are included. The first cohort of graduates with exposure to IAQ topicswill be available in 2002.Environmental Technology SectionDepartment of Applied Science7 Sept 1999 -/*tV. . . , : *'8Rl*&

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