IAQ Covid Alternative Compliance

QUESTION
Confidential project - location and project-specific information removed from post

The Project Team could not and cannot comply with the conditions of the pre-occupancy air quality test using the United States’ EPA standard. The non-compliance is due to a delayed construction schedule caused by the unforeseen COVID-19 strict countrywide lockdown which hindered the construction programme and associated deadlines. 

Due to the National Lockdown, heavy restrictions were placed on all public activities, resulting in reduced construction workers and working hours for the project site. COVID19 restrictions therefore extended the project's construction timeframe, while the date for occupancy remained unchanged (February 2021), allowing for timeous opening for the new academic year. As per your precedent to allow pre occupancy testing to occur on site 3 months after occupancy, the project has already passed this 3 month 'buffer' and the project team confirm that there is still construction occurring on site and completed spaces are occupied as the school progresses with its operations in phases.

Due to these circumstances, the pre-occupancy indoor air quality tests could not be done in line with the LBC Indoor Air Quality EPA method nor with the Phase Construction approach/requirement as prescribed by Imperative 08. 

In conclusion to the above, the Project Team motivate that conducting pre-occupancy air quality tests is not practically possible due to the fact that the Project Team is required to perform air quality testing on all LBC buildings during the same performance period and if pre-occupancy air quality tests are/were conducted according to LBC requirements, the continued phased construction of the surrounding buildings would’ve yielded inaccurate results such as particulate matter contaminating the surrounding air. 

As the project team encountered the above stumbling block, it started to investigate alternative compliance options provided by ILFI. The alternative RESET Air Pathway was investigated and feasibility issues encountered include the following:

  1. lack of RESET Accredited Professionals (AP) in the country or region, which are mandatory to conduct the RESET Air submission
  2. a member of the project team would be required to become RESET Air APs with associated risks of not having any experience in this field.
  3. Only one (1) RESET Air approved monitor is available in the country (Model Tongdy MSD-1828D) out of fifteen (15) RESET Air approved monitors globally available. This monitor is five (5) times the price of an internationally available and affordable RESET air approved monitor.
  4. Due to the requirements set by RESET, the number of monitors required for the project equate to 16 in total, resulting in an exorbitant cost to demonstrate air quality compliance.

To achieve indoor air quality compliance feasibly the Project Team is requesting a project specific COVID-19 exception.

The following details how the COVID-19 project specific exception IAQ test methodology would be addressed by the Project Team to demonstrate alternative compliance:

(Please refer to drawing titled ‘190204 – [Project Name] IAQ alternative methodology COVID Exception – 21 June 2021’, herewith attached, which confirms the following):

  • All classrooms are the same form, size and employ the same construction techniques.
  • Classroom variations:
    1. Some classrooms have a back door
    2. There are variations of window positions, however the same window to wall ratio’s apply throughout.
  • Classrooms are clustered in the same location on the project site.
    • Indoor Sampling

    (Please refer to the site plan attached which details the proposed spaces and the Indoor Air Quality Sample Points (tests done in line with the indoor testing method as per Imperative 8):

  • Sxxxxxx - x1
  • Store room within Sxxxxxx (area with the least ventilation and greatest presumed source of toxins – x1
  • Admin – x1
  • Classroom – x1
  • Teacher’s Lounge – x1
  • TOTAL: 5 indoor data test points
    • Outdoor Sample Points

    One(1) outdoor sample will be collected within 1,5m of the outdoor air inlet of the classroom building.

    Monitoring Requirements

    The Project Team confirm that permanent air quality monitors would be installed to measure CO, CO2, temperature and humidity (as per Imperative 08 heading Ventilation and Monitoring Requirements).

    Conclusion

    The Project Team have investigated every avenue feasibly possible and believe that the above proposed alternative compliance is a reasonable and justifiable compromise based on unforeseen factors. The Project Team, hereby kindly request a project-specific COVID-19 exception to demonstrate alternative compliance for the Air Quality testing requirement of Imperative 08 Healthy Indoor Environment.

    ANSWER

    Due to COVID restrictions limiting access to the site and resulting in a delayed and overlapping construction timeline, the project team may omit the pre-occupancy IAQ test. The project team must conduct post-occupancy testing of discrete representative spaces. The proposed sampling plan, identifying the Admin building, teacher's lounge, two locations within Sxxxxxx, and a representative classroom, for a total of 5 indoor testing sites, in addition to the specified outdoor location, is approved.

    The post-occupancy test, completed in accordance with the EPA testing method, will need to occur within 9 months of occupancy of each space.

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