A breath of fresh air

A paper relating to living and working for prolonged periods of time in carbon neutral buildings Michael R Ettinger

Chartered Member of IOSH

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 1

A breath of fresh air

Index to contents 1.0 Introduction 1.1 Definition of carbon neutral 1.2 Abstract 2.0 Evaluation 2.1 Regulations 2.2 MVHR systems 2.3 Mould 2.4 Air quality 2.5 Public buildings and institutions 2.6 Air tightness of ductwork 2.7 Cleaning, servicing and maintenance 2.8 Pets in the home 2.9 Outbreak of fire 2.10 During Construction 2.11 Historical data 2.12 The development of risk assessment. 2.13 Long Term effects of mechanical ventilated buildings 2.14 On going costs for Carbon Neutral Homes 2.15 Fuel poverty 2.16 Carpets and other floor finishes 3.0 Recommendations 3.1 Carbon neutral dwellings a good idea. 3.2 There is a better and safer way forward for saving energy 3.3 Other comments 3.4 EU/UK and International standards 3.5 Alternative ways of saving energy 3.6 Consultation 3.7 Further research 3.8 Monitoring 4.0 Discussion / Summary 5.0 Reference 5.1 Further reading 5.2 Qualification 5.3 Conflict of interest

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 2 A breath of fresh air 1.0 Introduction There is a lot of momentum for developing carbon neutral buildings as a way of conserving energy in the home and work place, promoted by the EU and our UK government, passive energy companies, architects and environmental organisations who believe strongly that this is the only way forward to ensuring a sustainable energy supply for future generations and also to ‘save the planet’ from CO2 emissions. The UK governments carbon neutral proposals are driven by the Climate Change Act 2008 and the EU Energy Related Products Directive (2009/125/EC and the recently upgraded part L of the UK Building Regulations 2013. The aim is for all new UK dwellings to be carbon neutral by 2016 and all non domestic buildings to be carbon neutral by 2019. An impact assessment published by the Department for communities and Local Government ‘Changes to Part L of the Building Regulations 2013’ sets out in some depth (88pages) the rational for energy and financial costs and savings supported by graphs and tables, there is a small section on ‘Health and Wellbeing’ that amounts to around 200 words (sections 4.59, 4.60 & 4.61) as you might expect this issue is not top of the governments list of priorities.

1.1 Definition of the meaning ‘carbon neutral’ A carbon neutral building is a building that puts no more carbon dioxide into a building than it takes out, hence the building it is said to be ‘carbon neutral’ and as such will limit carbon emissions into the atmosphere by saving energy consumption. A noble and worthy objective that pushes environmental building design to the edge of what may be practical and more importantly, good for our health.

1.2 Abstract Carbon neutral buildings, a good idea but not the best way forward, this papers objective is to draw to attention the impact of living and working in carbon neutral buildings over a prolonged period which rely on mechanical ventilation systems that provide us with the air we breath in an enclosed environment. The paper identifies many potential sources of contamination that habituate buildings with recommendations for reducing risk of illness from their presence. In particular during the design stage when contamination risks can be identified and eliminated and during occupation, when cleaning servicing and maintenance play a vital roll in ensuring clean healthy air for the lifetime of the building. The paper suggests alternative ways to save energy and makes the case for a ‘health and wellbeing, risk assessment’ for people with varying life styles when occupying carbon neutral buildings and the need for relevant information on the benefits and risks of this new ‘enclosed space life style’ to be in the public domain and open to debate. The paper makes the case for further research and monitoring carbon neutral buildings over specified periods of time to ensure the occupants health and wellbeing is maintained. The following section ‘Evaluation’ identifies areas where our health may be compromised in achieving carbon neutral goals. I also suggest that during the buildings life the expenditure of additional energy and financial costs invalidate the claim that these buildings remain carbon neutral. The cleaning, servicing,

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 3 maintenance and replacement requirements and costs for carbon neutral buildings are reviewed in this paper.

Key words Carbon Neutral Climate Change MVHR Mechanical Ventilation Heat Recovery systems Fuel Poverty Volatile Organic Compounds Volatile manmade Compounds Mould Lung diseases

2.0 Evaluation

Insulating buildings up to the nines and making sure they are air tight, whilst fuel prices are allowed to rise as a deterrent to energy use, (around 10% increase in energy costs in the UK at the time of publication of this paper) take us into uncharted waters in terms of health and wellbeing with the likelihood that carbon neutral buildings may over the lifetime of the building damage our health, by how much if at all, no one really knows. Until people have lived and worked in sealed airtight buildings for most of their lives breathing mainly mechanically ventilated air from an MVHR system we will not know, even then it will take time to evaluate the data and make any further recommendations.

For sometime concerns have been highlighted by Scientists, Engineers and many manufacturers in the Ventilation and Air-conditioning industry not overly concerned with design requirements of MVHR systems but regarding installation, commissioning cleaning and maintenance of the systems that need to have a long shelf life, as long as the buildings themselves, 50 ,75, 100 years, not a very long time when we think of the buildings we presently occupy, many old buildings are in perfect condition and still serve us well, but 50 ,75, 100 years is a long time for vital mechanical equipment to function 24/7 perfectly.

What happens if the MVHR system becomes unbalanced, breaks down or is not cleaned or maintained properly over the lifetime of the building, or the dwelling is a second home, occupied perhaps 4 weeks in a year or following a death or illness and becomes unoccupied, an empty air tight building, with the MHHR running on minimum if at all or the building over heating in hot weather. I don’t believe the living conditions and health implications of air tight buildings have been fully thought through in particular dwellings, residential care homes and prisons where the occupants might spend most of their time (24/7} in an enclosed air tight environment.

We have known for a long time that sick building syndrome can be created by enclosed buildings and a reliance on ventilated air and air-conditioning. It is a very complex subject, made more complex by the presence of Volatile Organic Compounds and Volatile manmade Compounds ( both chemicals) which are in the air that can vaporise and form that turn into liquid or solid compounds of various toxicity. It is suggested that VOC’S are generally present in greater numbers indoors than out doors. Meanwhile the EU and the UK government plough forward

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 4 with ever increasing requirements to achieve carbon neutral buildings, with mechanically ventilated air, highly insulated, temperature controlled air tight buildings as the mainstay and way forward. Even when there is known concern over the long term performance and maintenance of MVHR systems and dispute over the impact of climate change the development of carbon neutral buildings they do not pause. Each day that’s passes, carbon neutral buildings become more and more of a reality with UK regulations and EU directives on further requirements for air tight buildings leading the way.

There is no place for dogma and intransience in design, especially if it compromises our health and well being. At the time this paper is being written, the Australian Government is changing direction away from the exacting requirements of carbon neutral buildings, Germany is reviewing the maths whilst pro climate change environmentalists try their best to explain why the computer models and global warming projections are not confirming their original predictions, our health and wellbeing maybe at stake, its time for the UK Government and the building industry to pause and review where we are going, before it is too late.

I suggest warm sealed, environments are the perfect place for toxic volatile compounds to be released into the building, mite’s bugs, , flies, cockroaches also enjoy a warm enclosed environment where they can live feed and breed.

There is also the prospect of mould growth often associated with VOC’S and all they brings to the table not to mention the ingress of pests, rodents setting up home in ducts and ceiling voids and the like.

I don’t believe that those who champion carbon neutral buildings, in particular dwellings would have us believe that ‘mechanically circulated air’ is better, safer than ‘naturally ventilated air’ that enters buildings through windows and doors and stops buildings over heating. Cold fresh air is invigorating to our being, it kills off the bugs, reducing their breeding habits.

As long ago as 1984 the world Health Organisation warned that up to 30% of new and refurbished building were subject of concern and complaints as to the occupants well being and poor ventilation. New air tight dwellings and offices discourage the use of circulating fresh air through traditional doors and windows, as when open they will give rise to letting in cold fresh air, resulting in higher fuel bills when a constant temperature is required. MVHR system can only work properly when the doors and windows remain closed. MVHR systems can become unbalanced when doors and windows are left open for long periods of time, (hence the need for air tight buildings). For many people the positive propaganda surrounding the development of carbon neutral dwellings and the installation of MVHR systems sound eminently sensible as well as exciting and is taken on board especially when backed by the UK Government.

Whatever material measures we take to insulate our buildings, provide more efficient energy systems the easiest way to control carbon emissions in the UK is by ensuring the current population of 64million people remains stable, if the governments prediction of their being 73million people living and working in the UK by 2025 then no amount of airtight MVHR buildings will counter the increase in

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 5 carbon emissions. The result should the population reach 73 million people living in the UK is likely to be more people suffering from various forms of sick building syndrome created by contaminated air.

2.1 Regulations There are several regulations current in the UK which oversee design and installation requirements for buildings and associated Mechanical and Electrical services. The principal regulations include

The Health and Safety at Work Act 1974, The Planning Acts The Construction Design Management Regulations 2007 The Workplace Health and Safety at Work Regulations1992 The Consumer Protection Act, The Building Regulations 2013 The Management of Health and Safety at work Regulations 1999 PAS 2060 provides guidance and standard for achieving carbon neutral activities in manufacturing, industry and construction.

These Acts of Parliament and Regulations interact with each other and make specific points in particular for designers and manufactures to address and comply with. The Construction Design Management Regulations in particular identify the need for risk assessment at the design stage for all construction projects, for the designers to ‘design out’ potential risks for the buildings occupation and use. Replacing materials and faulty building systems that may cause injury or illness to the end user is evaluated by risks assessment and the material or system replaced with safer material and or system is a specific requirement of the CDM regulations.

A good example of reducing risk for the end user, would be:-

The requirement for all glazing within a new or refurbished building to be safety glass as required by the current Building Regulations..

The banning of asbestos products in buildings is another good example.

The requirement for a fire risk assessment that ensures that in the event of a fire occupants can evacuate safely and fire compartmentation reduces the risk of a fire spreading.

Where high risks of injury or illness to our health cant be ‘designed out’ at the design stage of a project because they are integral to the product being supplied the regulations require that additional control measures are put in place to reduce the risk of injury and or illness to low negligible. The Construction Design Management Regulations and The Consumer Protection Act, require the (end user) occupants of the buildings to be provided with information on the risks associated with the safe use, cleaning, servicing and maintenance of the building for its duration.. A big ask when we are considering the potential risks associated with buildings and services which have a life of anything

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 6 between 70 to 100 years plus, the typical life of many existing buildings they seek to replace. It might be deduced that this ask is un-reasonable and cannot be assessed properly but not being able to assess risks fully is in itself part of the risk assessment procedure. There are many on going issues which may arise in the life time of the building which could pose a threat to our health. It could be argued that some of the issues apply equally to buildings that are not carbon neutral and rely on fresh air from natural ventilation, this I think misses the point in that the design of carbon neutral (airtight) buildings relying mainly on mechanically ventilated air may, making health issues more likely over the full length of the buildings life and also question the financial and energy savings claimed for this type of building

2.2 MVHR systems MVHR (Mechanical Ventilation and Heat Recovery) systems are basically a simple and ingenious way of controlling the amount and quality of air taken into a building with the added bonus of taking the heat from the used air which is re-cycled back into the building. What could be better, it has opened the way for big savings on use of energy and in theory provides a better controlled environment for its occupants. Thousands of MVHR systems of varying size and performance have been installed in the UK. Saving energy is big business with home delivery kits readily available for the DIY enthusiast, the basic systems starting at around five hundred pounds. Some systems for dwellings are designed to provide ventilated air to lounge, dining and bedrooms and extracted through kitchens, utility, toilets, wet rooms, bathrooms and en-suite with the MVHR unit often located in the loft space drawing air in and extracted out through pipes and ducts taken through the roof or at high level to and from the MVHR unit. This sounds good, the warm/hot air rises making its way through the house ensuring stale/foul wet air from the rooms is not extracted through habitable rooms, a good idea but doors to kitchens, utility, toilets, wet rooms, bathrooms and en-suite bathrooms are usually kept closed making the free flow of ventilated air less likely. Leaving a 12mm gap at the bottom of the door is one answer but this does not help proper air circulation in bedrooms as the air would be drawn across the floor at low level to toilets and bathrooms. It would be churlish not to acknowledge that the best ‘state of the art MVHR systems’ which may also include ‘’ cooling provide a clean comfortable environment to live and work in, in some cases superior to the natural ventilation systems of many existing buildings, though without cooling for the summer season there is a risk of the building over heating. Many MVHR systems installed will be good, some will be average whilst others will be very basic without cooling and have a short shelf life. Half way through the life of a carbon neutral building that relies on a MVHR system to provide fresh air, it may not be clear which system you have place, how well it has been maintained and if it still performs to the original specification. With any new technology, it will be a while before we know what impact this new eco life style will have on our health, good or bad.

2.3 Mould Mould spores are everywhere and if they get a hold within a building they can be very difficult to eliminate. Their presence usually goes un-noticed until they have a foothold. It is known that when present within a building they can cause illness especially to people suffering from Asthma, are chemically sensitive or have weak

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 7 immune systems. Figures indicate that there are 250 to 300 million asthma suffers world wide, a large number.

Randy Penn’s research and paper ‘Mould: Volitile Organic Compounds & Mycotoxins: A primer for home owners ‘ on the extent of illness caused by mould and the release of organic VOC’s and toxins created by moulds in our homes, make for sober reading. Germicidal UV light can inhibit mould growth (check the web site for American Air and Water) for information on UV light systems.

Mould has the potential to become a real problem in airtight carbon neutral buildings especially if the relative is high or the building suffers from plumbing, condensate leaks or condensation, in theory the MVHR systems are designed to control humidity to a low level. However research has indicated that dry air can also be a source of irritant to those with ENT issues, such as dry cough, dry skin, blocked nose, sore eyes and it has been suggested in the USA that it is easier to pick up a flu bug in a dry air environment. In addition to UV light systems it is claimed that earth to air heat systems can reduce bacteria and mould when installed and working properly, though it has been found that radon gas can affect below ground pipe-work for this type of MVHR system.

2.4 Air quality In addition to volatile organic compounds ( created by moulds) present in modern buildings, there has been a lot of research into air quality and the presence of man made products that release volatile compounds within buildings and the imbalance of positive/negative in buildings. Air ionisers have been around for a long time and it is known that a build up of positive ions and toxic VOC contaminates in a building do little for the well being of the inhabitants. The air we breathe comprises 78% nitrogen, 21% oxygen and 0.4% carbon dioxide and 0.6 of other trace elements that include methane, nitrous oxide, , hydrogen and minor amounts of noble gases, which are charged with negative and positive ions. The ideal make up of the air we breathe in buildings is for an equal balance of negative and positive ions between a temperature of 19 to 21 degrees centigrade. Invigorating high quality air is often found by waterfalls, the seaside and on mountains where the air is considered freshest and the positive and negative ions in balance. Where installed in buildings negative ions created by an air ioniser bond with positive ions in the air, which can be contaminated with dust, pollen, smoke and other allergens. The bonded ions create a form of dirt which is too heavy to float around in the air and fall on to the ground or furniture surfaces where it can be removed in the cleaning process. Ironically it is claimed that buildings with high insulation interferes and inhibits natural air circulation, ionisers help redress the balance. Ionisers can be built into air-conditioning systems some with dust collection trays and their use should be a consideration for all buildings that rely on mechanical ventilation and air conditioning in sealed buildings, in particular hospitals and care homes where studies have shown that infections can be eliminated where ionisers are used to purify the air. Studies in America have found that many furniture and upholstered products are sprayed with a flame retardant chemical which can vaporise into the air we breathe. Organic and or man made VOC’s would be present whether the buildings were naturally or mechanically ventilated however in

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 8 mechanically ventilated buildings toxic vapour might be inhaled more directly where occupants sit stand work or rest in the direct path of the air flow, or in small rooms where the concentration of toxic vapours may be higher, or when the MVHR system is switched off. Consideration should also be given to installing UV-C lighting into domestic MVHR systems though more research on purification and controlling bacteria and VOC’S from man made products that release VOC’s. I suspect we are induced to a feeling of ‘well being’ when we sit in our newly built airtight, insulated homes knowing that as well as being warm and cosy we are saving money with reduced fuel bills but nothing is free and there may be a hidden cost, ‘our health’.

2.5 Public buildings and institutions People in schools, hospitals, institutions and prisons can spend a long time in an enclosed space, as do many people that are ill and/or infirm, these people 300,000 alone in care homes along with their carers are probably at higher risk than people in their own homes and offices as it will always be senior staff that open a window or more likely close it to conserve fuel waste in the MVHR controlled buildings. People serving time in prison along with prison warders and supporting staff face similar higher risks especially if the MVHR’s doesn’t work properly and when the furnishings are treated with fire retardant spray. Mark Mendel’s paper ‘Indoor Factors and Symptoms in Office Workers: Findings from the U.S. BASE Study 2008’ makes interesting reading and identifies that we might benefit from less mechanically cooled in the summer and less mechanically heated air in the winter perhaps the opposite of what we would expect in offices. The findings indicate that over cooled office in summer and over heated office in winter, correlate with increased symptoms. It is fair to say that un-heated buildings especially in winter have an adverse effect on people’s health. Marks paper also identifies the significance of relative humidity can effect the air quality illustrating how complex mechanically heated and cooled ventilation design has become. Office buildings by their nature will have more air movement created by people moving around in the building than say people who spend most of their time in their homes where over heating and cooling in an airtight environment may have a negative impact on their health. Marks paper calls for further research. A recent article in a national newspaper reported that harvest mites and insects enjoying life on a grassed eco school roof, had invaded the classrooms below, gaining access through the ventilation system. There’s a moral somewhere here about roof gardens, eco and carbon neutral houses but not everyone gets it. ‘They don’t go together’.

2.6 Air tightness of ductwork Air tightness of ductwork is essential for the MVHR ducting system to work properly and eliminate contamination within the system which might cause ill health to the occupants of the building, this alongside cleaning is the biggest problem associated with carbon neutral buildings, dwellings in particular where leaky ducting built into floor, ceiling voids and in the roof space is concealed from view. The International Energy Conservation code suggests the best way to test for leakages in ducting is by pressure testing. The IECC also brings to note that pressure imbalances in the ventilation system can alter the quality of the air in the dwelling and in some occasions dangerously so leading to the observation that design is a complex science that needs to be fully understood with regard to MVHR systems.

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 9

2.7 Cleaning, servicing and maintenance There is equal concern regarding the maintaining and cleaning duct and mechanical air systems properly. Ducts can be round, square, rectangular, rigid and flexible, usually of metal but boarded material is also used, all of which have a bearing on duct performance, cleaning and maintenance of ducts. This is a central issue to the use of MVHR systems, to ensure compliance to a high standard cleaning, servicing and maintenance I suggest needs to be mandatory, how often is made more complex where the occupants smoke, have large families, are unemployed, without an income, the very poor, elderly and infirm, those that have asthma or are chemically sensitive and suffer chronic illness, people who are house bound and people who keep pets are at greater risk of becoming ill from an enclosed environment than people who work away from home and spend a good deal of time out of doors. Equally it will be the poorest people who will find the cost of maintenance of MVHR systems to high to meet. Tables 1, 2 & 3 identify the criteria for the exposure to risk.

The prospect of living and working in areas for long periods of time where the MVHR system, ducting and air filters have not been properly commissioned, maintained and cleaned or not cleaned properly and over heat in hot weather does not bear thinking about. New builds fall under the UK Building Regulations which have specific requirements for commissioning MVHR systems but refurbishment and upgrading existing dwelling the MVHR systems can be installed unregulated, purchased as kits from anywhere in the world.

The Building Regulations are there for a purpose, to ensure relevant standards are complied with, many private developers in the housing refurbishment sector may take the view that modifications to heating/ventilation and air tightness to older dwellings and also existing office accommodation do not require Building Control approval, a cost saving plus the freedom to install MVHR systems that suit the developer, who’s to know.

This is central to the problem, we won’t know if anything is wrong or our health is affected, until it happens and we become ill. We cant hear, see or touch bacteria or VOC’s in the air, it is possible for those with a keen sense of smell might detect stale air and or mould growth, but in the main if bacteria, moulds, VOC’S are present which cause us harm it is by stealth, when they enter our homes unseen and unexpected, an enemy that attacks our wellbeing.

2.8 Pets in the home Pets may become a major concern for occupants of carbon neutral dwellings especially if the MVHR system does not work properly or is not cleaned properly on a regular basis. There are about 10.5 millions cats, 10.5 million dogs and other pets including rabbits, gerbils, hamsters, caged birds etc. we like to keep in our homes. A warm dwelling is the perfect environment for flea’s mites and bacteria, pet dander, animal hair trapped in the carpet and bedding, hidden in ceiling voids ducts, those susceptible to bronchitis, asthma, allergies and are chemically sensitive are at greatest risk. Imagine a house with cats and no cat flap and the occupants in all day, where do they keep the litter tray, hopefully not the kitchen. Carbon neutral homes reduce fuel expenditure but the potential for mites and bed bugs feeding on pet dander will be will

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 10 be increased bringing illnesses with them, perhaps more so where under floor heating is used or if the building becomes over heated.

2.9 Outbreak of fire An issue which also needs to be addressed is the control of fire with in an air tight MVHR dwelling, where a fire alarm is linked to the MVHR system it shuts down in the event of a fire, containment of the fire would be increased as upon shut down of the system the fire would be starved of oxygen. All new non domestic buildings have fire alarm systems which are linked to the MVHR system and shut down automatically on activation of the fire alarm. If an MHVR system does not incorporate a linked fire alarm then the prospect of a fire spreading through a building, in particular domestic buildings when the ventilation system is still running might feed a fire and spread it quickly to other areas of the building through the ducting. Automatic shut down systems in the event of fire should be incorporated into all domestic MVHR systems for the lifetime of the building as well as for public and commercial buildings where they are mandatory. Requirements for testing/servicing fire alarm systems for the life of the building should be incorporated into the user and servicing guides and included into codes of practice for use with MVHR systems in domestic buildings.

2.10 During construction During building works there will be a time when the shell and internal walls, floors, first fix M & E have been installed including duct work, when there is likely to be no heating or natural ventilation into the building for installing fixtures, fittings and decoration when the building may still be drying out. At this time the empty building is vulnerable to mould, build up of dirt, bacteria and infestation though the newly installed and unused ductwork and other concealed areas of the new building and could be over looked in fast track programs. Testing and commissioning will indicate that the MVHR system is balanced, working properly and has been cleaned to defined requirements. These commissioning procedures are unlikely to identify how well the building has dried out which can take as long as 6 months to a year, or if mould and infestation has taken hold during this early period of the buildings life. Inspection and testing of the buildings dryness is essential at the time of completion if the building is not to suffer this fate. It is questionable if at this time the continued use of the new MVHR system would eliminate any mould, bacteria or infestation at the time of hand over, where a partly built new build is left unattended for long periods such as Christmas and New Year when the construction industry closes down for anything between two to three weeks, rendering the empty buildings open to infestation and pest attack and in particular mould growth.

2.11 Historical data When we look at buildings in this country we are struck by the number which are hundreds of years old and still perfectly fit for purpose, ironically many are government buildings occupied by our legislators. The UK has continuous changeable weather i.e. hot, cold wet then dry, older buildings are able to ‘breathe’ and consequently adjust more readily to changing climate conditions than new airtight buildings. For one thing older buildings with opening doors and windows the odd draught or two, adjust readily to climate conditions and importantly can dry out which inhibits mould growth. The longevity of these old buildings and the condition of their

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 11 repair speak for themselves, it is interesting that the Governments current impact paper (August 2013) identifies the new carbon neutral buildings as having a 60 year life, not much of a long term investment, after 60 years we will need to provide replacement buildings using precious materials, labour and energy consumption.

2.12 The development of a health risk assessment. I have already mentioned the requirement for risk assessment under UK law and regulations. The risk assessment tables have been developed to bring to mind that people of differing life styles and health spending different periods of time in carbon neutral buildings will be exposed to higher and or greater risks, something I don’t believe is made clear to the general public and occupants of these buildings. It is pleasing to read Richard Sharpe’s paper, ‘High energy efficient homes are associated with increased risk of doctor diagnosed asthma in a UK sub population, published by Environment International which identifies the potential increased risk of asthma in energy efficient homes. Their risk assessment is comprehensive and supported by sampling and recorded information, where as my risk assessments come from a different direction entirely and is based on observations and general awareness that a potential problem exists with living in energy efficient dwellings. It is important to understand that someone living in a carbon neutral home may then spend there working time in a carbon neutral workplace which might in effect double the time they spend in an enclosed environment.. More research and published data in greater detail by ‘experts’ is required for full risk assessment associated with our health and wellbeing occupying any carbon neutral building for long periods of time be it a home, hospital, office or school.

Qualification: The tables below relate to people of different ages and life styles spending prolonged periods of time (min 5 years) in a dwelling, of course the exposure to risk will increase as more time is spent in the dwelling.

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 12 Table 1 identifies the exposure to risk in carbon neutral buildings with a fully maintained MVHR system which includes cooling Description Occupancy Occupancy Occupancy Occupancy Occupancy 24/7 12/7 8/7 8/5 occasional Baby 3 - - - 1 Child 2 1.5 1 0.5 0.5 Teenager 1 1.5 1 0.5 0.5 Adult M 1 1.5 1 1 0.5 Adult FM 1 1.5 1 1 0.5 Elderly 2.5 1.5 1 1 0.5 person Disabled 3 2.5 2 - 1 person House 4 - - - - bound person Single 2 1.5 1 1 0.5 Person with pets Family with 3 2.5 1 1 1 pets Person with 5 4 3 2 1 asthma or allergy

Table 2 identifies the exposure to risk in carbon neutral buildings not properly maintained MVHR and without cooling

Description Occupancy Occupancy Occupancy Occupancy Occupancy 24/7 12/7 8/7 8/5 occasional Baby 5 - - - 1 Child 4 3 2.5 2 1 Teenager 2 2 1.5 1 1 Adult M 2 2 1.5 1 .5 Adult FM 2 2 2 2 .5 Elderly 4 3 2.5 2 1 person Disabled 5 4 3 - 2 person House 6 - - - - bound person Single 4 3 2 1.5 1 Person with pets Family with 5 4 3 2 1.5 pets Person with 7 6 5 4 3 asthma or allergy

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 13

Table 3 Identifies the exposure to risk in carbon neutral buildings not maintained properly and without cooling maintained MVHR system which includes cooling where bacteria, toxic VOC’s and mould are present.

Description Occupancy Occupancy Occupancy Occupancy Occupancy 24/7 12/7 8/7 8/5 occasional Baby 9+ - - - 6 Child 8 6 5.5 5 5 Teenager 6 5 4.5 4 3 Adult M 6 5 4.5 4 4 Adult FM 6 5 4.5 4 4 Elderly 8+ 7 6 5 4 person Disabled 7+ 7 6 - 4 person House 9+ - - - - bound person Single 7+ 6 5 4 3 Person with pets Family with 8+ 7 6 5 4 pets Person with 10+ 10 10 9 8 asthma or allergy

There are any amount of variations to the exposure to risk but it is clear to me that the impact on peoples health will vary depending on their age, health and life style play a part, together with how much time is spent in a carbon neutral dwelling, how well it has been maintained, whether the occupants keep pets and not forgetting people who enjoy a cigarette. The examples do not show the impact of the risk to our health if any that is for more eminent people than me to develop but show how diverse the risks may be. Young fit and healthy people who spend a lot of time away from their home mainly out doors may not understand the concerns of people who have too spend most of their time in an enclosed air tight environment. It’s not unreasonable for the difference for one individual’s risk to another to be ten times greater. The high and medium risks to our health are never acceptable and need to be reduced to low/negligible.

The exposure to risk are expressed as 0-2 low risk to health, 3to 6 medium risk to health 7-10+ high risk

2.13 Long term effects of mechanical ventilated air tight buildings on our health. To my mind the long term effect of consuming mechanically ventilated air in public buildings, the workplace or at home is not fully established, encouraging people to seal their homes, doing away with draughts to ensure they are ‘airtight’ will keep you warm and save you money but as I have previously mentioned, at what cost? The consumption of clean fresh air 24/7 is essential to our wellbeing inside the buildings we live and work in; mechanically ventilated air is not the same as fresh air.

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 14 Studies on ionisation make this point, the use of man made products, nylon, plastic, upvc, vinyl in the home and office contribute to an imbalance of positive ions to negative ions occurring equally some paints, furniture and upholstery sprayed with fire retardant compounds, household products and packaging can release VOC’s into the air, some of which are toxic with the resulting ill effects on the people with allergies/asthma are chemically sensitive and/or have weak immune systems. Enclosed airtight buildings which may overheat in hot weather might promote the release of VOC’s and the breeding of mites etc. what we don’t know is if this may be the case. We need to be concerned when letter boxes for example are removed from carbon neutral houses and relocated as mail boxes at the front of the dwelling to ensure air tight requirements, cat flaps I expect will also fall into this category and be phased out of new builds. Another area that needs to be addressed is buying to let houses, where the landlord may not be aware of the condition of the MVHR system or will not spend the money on regular cleaning, servicing and maintenance or are unaware of the wellbeing of their tenants, whom they may never meet.

2.14 On going costs for carbon neutral dwellings Its not unreasonable to question what the ongoing costs of maintaining carbon neutral might be over the life of the building (50, 70 or 100 years of servicing and replacement) whether these added costs challenge the energy saving claims of carbon neutral buildings and if the money and energy expended servicing and replacing, filters, ducting and MVHR systems might be better spent It would seem prudent to say the MVHR and ducting would need inspecting/servicing at least once a year with replacement filters, re balancing and re-commissioning. Over say a seventy year life of the building it might be assumed that the MVHR might be replaced three times, every twenty five years, ducting and grilles once or twice in the life of the building with filters cleaned at least every year and replaced between 1 and 5 years or less. Depending on where the service company is based the visits required and energy consumed in making replacement parts, labour and disposal of waste materials, the expense following original installation could be considerable over the life time of the building, inflation would increase the expenditure further. Every property needs maintenance but maintenance relating to the quality of the air we breathe day in day out is a vital requirement during the occupation of the building, if our health and wellbeing are not to be endangered. Locating MVHR systems in lofts where access is limited should be avoided. The MVHR system may have to be replaced at some time, equally the location of pipe-work below ground bring its own set of unseen problems and needs to take into account ground conditions, the proximity of Radon, tree roots and high water tables.

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 15 Table showing unit costs for cleaning servicing, replacement of MVHR system over 25, 50, 75 & 100 year cycle life of building.

Description 25 years 50 years 75 years 100 years MHVR SYSTEM & ELEC HEATERS Cleaning and servicing Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years 12 to 25 units 24 to 50 units 36 to 75 units 48 to 100 units of time of time of time of time Replacement Replace cost of Replace cost of MVHR + time MVHR + time FANS & DUCTING Cleaning and servicing Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years 12 to 25 units 24 to 50 units 36 to 75 units 48 to 100 units of time of time of time of time Replacement Replace cost of Replace cost of ducting + time ducting + time Cooling system Cleaning and servicing Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years 12 to 25 units 24 to 50 units 36 to 75 units 48 to 100 units of time of time of time of time Replacement Replace cost of Replace cost of ducting + time ducting + time FILTERS Cleaning - - - - Servicing - - - - Replacement Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years considered more cost 12 to 25 units 24 to 50 units 36 to 75 units 48 to units 100 effective to replace of time of time of time of time than clean GRILLES Cleaning Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years Every 1 to 2 years 6 to 12 units 12 to 24 units 18 to 36 units 24 to units 48 of time of time of time of time replacement Replace cost of Replace cost of ducting + time ducting + time Totals for cleaning and 54 to 112 units of 108 to 224 units of 162 to 336 units of 206 to 424 units of servicing, replacement time time time time not identified

Set against the on going costs are the energy savings over the same period of time, the table above only indicates time spent at a typical dwelling, other costs such as manufacture of replacement parts, travelling time and waste disposal are not included. No costs for cleaning and servicing filters has been shown it may be more cost effective to just replace the filters also in this example cleaning servicing replacement of underground pipe work has not been included for earth to air systems. The carbon footprint referred to in PAS2060 is to my mind obscured somewhat by the complexity of the on going cleaning/servicing/maintenance of these buildings, how they are used and by how many occupants. It is noted that the Governments impact statement set out to substantiate carbon neutral buildings identifies a life span of 60 years. This time scale makes the claim of buildings being carbon neutral less rather than more attainable. The likelihood is that cleaning, servicing, maintenance and replacement expenditure will out-strip the original construction cost over the life time of the building in terms of money and energy expended. But we need to be reminded that whatever the energy savings on-going costs they are not as important as our health.

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 16 2.15 Fuel poverty A recent paper ‘High energy efficient homes are associated with increased risk of doctor diagnosed asthma in a UK sub population, published by Environment International which identifies an important issue that was not in my original paper. The potential impact fuel poverty for people occupying energy efficient buildings. This is a really important and is intergral to the issue of the occupation of Carbon Neutral homes. i.e the potential for limiting the use of the MHVR system being used say at night, when out of the property, when on holiday so that condensation and dampness can occur. Of equal importance is the ability of people who suffer fuel poverty to pay for the essential cleaning servicing and maintenance of the system. I have already mentioned the importance of the MVHR system including concealed ductwork being thoroughly clean and maintained. I am grateful for have access to Richard Sharp and his team for bring this issue to my notice.

2.16 Carpets and other floor finishes

Another point touched on in Richard Sharpes paper is the presence of carpeting as a floor covering which I would suspect would be of concern to the development of people suspectable to asthma in either new or modern buildings thought it might be more of an issue where air is mechanically blown into and extracted out of a room, there is also the issue of carpet and deep plie carpet harbouring bacteria, pet hairs contamination and other VOC’S. The use of vynal cusion floor ‘for example’ may be more hygienic and easier to keep clean though there is the potential of man made floor ing products releasing VMC’S into the enclosed atmosphere, it is potentially impossible to keep track of the different materials that make up a home regarding their impact on our health, the identification of carpet as being a potential issue has not been incorporated into my risk assessment but I think we can see that in a busy house with children pets, parents that smoke that perhaps suffer fuel poverty, there are the ingredients for the sealed home to challenge our health and well being, a man made carpet in this environment could be the tipping edge, much more research is required when these different fuel efficiency buildings and soft furnished are combined.

3.0 Recommendations There is a better, healthier way forward for new buildings that preserve the good aspects of passive energy saving design which includes natural air through windows that open and a less rigid airtight environment.

3.13 Carbon neutral dwellings a good idea. Like many new ideas carbon neutral designed dwellings sounds like a good idea, a while ago so did high rise building, and the development of nuclear energy dubbed ‘clean energy’. In practice carbon neutral homes are unlikely to work perfectly over the life of the building (say 100 years) if they are not built properly cleaned and maintained, and or replaced, in this scenario they are potentially dangerous and are being promoted by the UK Government which is low on consultation and dare I say lacking in ‘common sense’.

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 17 3.2 There is a better and safer way forward for saving energy in new buildings, some of which are already in place and include a Use of smart energy monitoring systems and integrated energy meters b Installing Solar Panels c Installing Heat recovery systems d Controlling wasted use of energy e Installing valves to radiators in each room. f Floor wall and roof insulation to a high spec g Rain water harvesting h Installing water meters j Wood burning stoves k Provision of permanent Fresh air, from opening windows m Passive trickle ventilation n Incorporating ionisers in MVHR systems p The use of UV light purification systems in air plenums and MVHR systems q Reduction in use of products fixtures and fittings and products which release VOC’s in to the air. r Where MVHR systems are installed weather proof louvres, grills should be used to ensure no ingress of rainwater into the building. s Where MVHR systems are installed the issue of air monitors should be standard with instruction on their use. t Testing and checking dryness of new building on completion as part of commissioning u Specific and mandatory on going cleaning, servicing and maintenance of MVHR systems should be developed v Air / smoke pressure tests at commissioning and for maintenance/servicing of duct systems. w Circular ducting is preferred to square rectangular ducting, bends and elbows kept to a minimum and ducting being no longer in length than necessary for the system to work efficiently. x Life expectancy of MVHR should be identified before they are installed with implications of replacement, for example, in roof spaces which are often difficult to access. y Incorporate methods to control fire in domestic buildings using MVHR systems z Windows with opening casements to + 1/20 of floor area of habitable rooms providing fresh air. aa The use of computers linked to MVHR systems to monitor, display air quality, air flow rates, humidity, performance of MVHR system, cleaning and replacement programs, accurate servicing and replacement records, problem solving and call out requirements.

3.3 Other comments a Reliance long term 24/7 on mechanical ventilation for our air supply should be reduced downwards. b Banning of letter boxes and cat flaps and providing air tight buildings should be ignored.

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 18 c Grassed eco roofs should be given a miss as they encourage mould, bacteria, pests and insects into the buildings. d Guidance on effects of ill health, use cleaning and servicing of MVHR systems be provided to occupants of carbon neutral homes , public and commercial buildings for the full lifetime of the building. e Installing MVHR by the DIY enthusiast and /or owner occupier should not be encouraged unless they have a comprehensive understanding of the systems being installed and qualified to undertake commissioning. f Procedures where building become contaminated, infested, requirements for deep clean quarantine, removal and replacement of fixtures and fittings need to be addressed in the user manual with strict guidelines on procedures required. There is an insurance issue here which also needs to be addressed. g The development of computers in environmental controlled building will grow quickly and can be a boon to monitoring the MVHR systems performance, the down side of course is that the computer system only works as good as the operator and occupants might become over reliant on the computer to control the environment and or occupants just not bothering, there is also the issue of computer glitches which may go un-noticed but in the main this is an area where the use of MVHR systems can be monitored properly. h Where MVHR systems are installed they need to incorporate cooling to ensure the buildings don’t over heat in hot weather. J Consideration should be given to the use restricted use of soft furnishings and carpets in carbon neutral buildings especially where there are occupants with dust allergies, asthma and other lung disease and or where the home is shared with pets which may give rise to the harbouring of dust, pet hair and bacteria which may be disturbed and circulated in the air by the ventilation system.

3.4 EU/UK and International standards Reference to EU, UK and USA Standards must be sought when specifying MVHR systems as many items which can be bought world may not meet with these standards but are less costly; we need to consider use of kite marked products. BSI publication PAS 2060 identifies the objects and requirements for being carbon neutral as an all embracing life style.

3.5 Alternative ways of saving energy Other ways forward to conserve energy use, include the use of UK grown bio mass, solar power heat recovery systems, building more reservoirs linked together by canals or pipe work, wind farms and tidal power, rainwater harvesting, the development of electric cars and motor bikes and the development of carbon capture and clean coal. We have many years of coal reserves in this country which would also create jobs, benefit our balance of payments and secure our energy needs without resorting to nuclear energy and the disposal of nuclear waste.

We can see how risky Nuclear energy can be when we read of how Japan is still finding and cleaning up spilt nuclear fuel, however hard they try they are not in control and have to react to an ever changing situation, like the leaking fuel rods the news of what’s happening finds a way out and is then quickly managed by their government to cause the least alarm. No one knows the actual situation in Japan or how it will be resolved other than at the time of preparing this paper Japan has closed

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 19 all of its nuclear plants and has moved away from nuclear energy, a timely reminder as to how dangerous this form of fuel can be.

The most enjoyable way to save energy and reduce the country’s carbon footprint is for all of us individually and collectively to grow our own food, as well as being fresh they are free from pesticides and eliminate expensive and energy wasting supply costs, this along with a stable population which is not allowed to grow out of control is the simplest and most immediate way forward.

3.6 Consultation It is the governments ambition for all new buildings to be carbon neutral by 2016, this should not happen without there being a comprehensive debate on this subject with alternatives to sealed buildings brought to the fore The debate should be lead by the Medical profession, HSE, BRE, NADCA, HVAC Engineers and the Manufactures of MVHR systems in support along with Energy environmentalists but most importantly engaging the general public and specific groups such as Lung and Asthma UK and Allergy UK.

3.7 Independent research Further scientific research on the long term impact of Carbon Neutral buildings is essential and might include: a Research on prolonged periods of time spent in Carbon Neutral MVHR buildings b Research on reduction in use of products fixtures and fittings which release VOC’s c The risk of developing lung diseases, asthma and other allergies in dwellings and all carbon neutral buildings with the risk assessments made public. d Recommendations into cleaning systems of duct work, buried pipe work, and ventilation for MVHR systems, with a view to making these requirements mandatory. e MVHR systems to be re-balanced and re-commissioned with each inspection with Log book like an MOT for cars. See NADCA guidance and research. f Provision of risk assessment relating to our health when keeping pets in carbon neutral buildings g Provision of risk assessment for legionella and presence of radon may also be required h A code of practice for the design, installation, commissioning, cleaning, servicing and maintenance of MVHR installations should be developed and like gas installations only qualified and registered contractors to install commission and maintain MVHR systems.

3. 8 Monitoring Monitoring and auditing are integral to health and safety management particularly when new products are bought to the market. Pilot schemes should be set up around the UK to monitor and audit the performance and potential impact on health good or bad as part of health and safety management of carbon neutral buildings both new and refurbished, in particular dwellings and institutions to cover periods of 5, 10, 20 and 40 years with results

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 20 developed and published by an independent organisation not part of the industry or Government.

4.0 Discussion/ Summary There are many books and papers on this subject written over the past 50 years as the science behind mechanical ventilation systems, microbiology, heat recovery systems gain pace in the battle to save energy and restrict the pollution of the earth by CO2 omission greater discussion is recommended if we are going to pursue this method of saving energy at the expense of our health.

This paper brings together many issues that need addressing and identifies the need for detailed risk assessment for living for prolonged periods in carbon neutral dwellings and places of work. The need for monitoring installed systems and further scientific research by Engineers and Scientists and other interested parties into the complexities of saving energy is clearly made. The alternatives to carbon neutral buildings and the requirement for natural fresh air are also identified and for the occupants of carbon neutral buildings to provided with suitable information and any potential risks to their health for the live time of the building.

To those developing zero carbon buildings, I request respectfully, please think carefully on what you may be inflicting on the occupants particularly the old and infirm and those with asthma and other allergies over the life time of the building, acknowledging that what suits some people may not suit everyone, there is a need for further research and analysis.

To those who are in a position to make further recommendations and understanding of the science behind carbon neutral buildings, please bring your findings good or bad to the Government and its various departments, manufactures and installers of MVHR systems, Architects, Engineers, Builders the general public and most importantly the occupants of these buildings.

5.0 Reference There is a considerable amount of regulation and guidance on the design, installation, testing, commissioning, cleaning servicing and maintenance of MVHR systems incorporated into energy saving buildings, which underline how complex the science is. The recent paper by Richard Sharpe and his team ‘High energy efficient homes are associated with increased risk of doctor diagnosed asthma in a UK sub population, published by Environment International’ is very welcome and a timely reminder of this issues we face.

Further reading The International Energy Conservation code The Building Regulations The Health and Safety at Work Act 1974, The Construction Design Management Regulations 2007, The Workplace Health and Safety at Work Regulations1992, Consumer Protection Act. Relevant British Standards The Management of Health and Safety at Work Regulations 1999. PAS 2060 standard.

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 21 BS EN 12599 Ventilation for buildings BS EN 1751 Ventilation in buildings BS EN 12599.2012 Ventilation in buildings test procedures BS EN 13141-6:2004 that defines ducting configurations BS EN 13141-7:2004 testing of heat recovery, ventilation MVHR test temperatures BS ISO 12/30253198 DC Heat recovery ventilators BS EN 308 1997 Heat exchangers test procedures BS EN 12735.1 2010 & ASTM B280 08 Specification for seam-less copper in Air-conditioning American Air and Water information and UV products Association and Residential Ventilation Association AVIC Information paper Air to air Heat recovery in Ventilation CIBSE guidance document on Ventilation, Air conditioning and heat recovery systems. Guidance on testing ventilation systems provided by Building Research Establishment, The and Ventilation National Air Duct Cleaners Association Research papers for HVAC The American College of Allergists The Green Built Certification Program of the national Association of home builders US Environmental Protection Agency papers ASHRAE (2006). "Interpretation IC 62.1-2004-06 of ANSI/ASHRAE Standard 62.1-2004 Ventilation for Acceptable ". American Society of Heating, Refrigerating, and Air-Conditioning Engineers. Building Services handbook Fred Hall and Roger Greeno April 2013 Chemical Sensitivity by Robert James Sinalko and Bonnye L Matthews Dec 1992 How to deal with Sick Building Syndrome Guidance for employers building owners and Building Managers HSE APRIL 1995 How Natural Ventilation Works by Steven J. Hoff and Jay D. Harmon. Ames, IA: Department of Agricultural and Biosystems Engineering, Iowa State University, November 1994.Apte, Michael G. Associations between indoor CO 2 concentrations and sick building syndrome symptoms in U.S. office buildings: an analysis of the 1994-1996 BASE study data.” Indoor Air, Dec 2000: Indoor Environmental Quality: Dampness and Mold in Buildings . National Institute for Occupational Safety and Health.Madigan High energy efficient homes are associated with increased risk of doctor diagnosed asthma in a UK sub population, published by Richard Sharpe, Environment International 2014 Indoor factors and symptoms in Office Workers 2008 Mark Mendell Lawrence Berkley National Laboratory M; Martinko J (editors). (2005). Brock Biology of Microorganisms (11th ed.). Prentice Hall. Money, Nicholas (2004). Carpet Monsters and Killer Spores: A Natural History of Toxic Mold. Oxford, UK: Oxford University Press. Morgan Mike ‘Moulds’ Microscopy UK Moore D; Robson GD; Trinci APJ (editors). (2011). 21st Century Guidebook to Fungi (1st ed.). Cambridge University Press. Ryan KJ; Ray CG (editors) (2004). Sherris Medical Microbiology (4th ed.). McGraw Hill. Penn Randy Mould: Volitile Organic Compounds & Mycotoxins: A primer for home owners Sick Building Syndrome: Neue Erkenntnisse und Ihre Auswirkungen auf den Bau und Betrieb Von RLT –Anlagen by Dipl Sven Sick Building Syndrome: v55: VOL 55 Advances in applied Microbiolgy by David C Straus Sept 2004 Sick Building Syndrome and the problem of Uncertainty Michelle Murphy Feb 2006 Sick Building Syndrome and related illness: prevention and recommendation of mould growth Walter E Goldstein Aug 2010 Sick Building Syndrome: concepts issues and practice by Jack Rostron March 1997 Staying well in a toxic World, understanding Environmental Illness, multiple Chemical Sensitivities Lynn Lawson April 2005 Rudolph. The Sick House Survival guide, simple steps to healthier homes Angela Hobbs January 2003 Ventilation by Michael McCann PhD, CIH

5.1 Qualification I am not an expert on MVHR ventilation systems, AC plant or energy conservation, neither am I a doctor overseeing a persons heath and wellbeing. I write

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 22 as an interested observer who has spent most of his life in the construction industry and practice as a Health & Safety Consultant. It can be seen from the length of this paper, it is not intended as an in depth study of the issues raised, this would require a book of many pages, but is an over view of my concerns for the development of carbon neutral buildings and is intended to stimulate debate and provide fresh ideas to this complex issue ensuring the well being and health of people that may occupy them.

5.2 Conflict of interest I declare that in writing this paper I have no conflict of interest with the development of my paper.

Michael R Ettinger Chartered member of IOSH

January 2015 Mike can be contacted at [email protected]

A breath of fresh air’ 2 nd print of a paper by Michael Ettinger page 23