Technology In Society, Vol. 8. pp. 277-286 (1986) Printed in the USA. All rights reserved.

0160-791X/86$3.00 + .oO Copyright B 1986 Pergamon Journals Ltd

Out-of-Sight - Out-of-Mind The Absence of Indoor Air Pollution from the Regulatory Agenda

Kathy Ham&on

ABSTRACT. Indoor airpolution is a more serious public health problem than many other problems on the regulatory agenda, but it has not been addressed by government agencies. The so&construction of the issue as a private one, its diffuseness, its technical nature, and a lack of obvious disasters attributable to it have limited the motivation and abiLty of a range of potential actors-including technical professionarcs, the media, public interest groups, legislators and regulators- to put it on the regzdatory agenda.

Most of us spend 80% to 90% of our time indoors’ - in private homes, workplaces, public buildings, and vehicles. Yet, exposure to pollutants indoors has been largely overlooked by government bodies responsible for health and environmental regu- lation. Studies published over the last 15 years suggest the indoor air pollution may be a very serious public health problem.’ The Council on Environmental Quality has acknowledged that, because we spend so much time indoors, “even moderate concentrations of pollutants encountered indoors are potentially significant .“3 Why has such a potentially serious health problem not been effectively addressed by the US government?

The Scale of the Problem

One possible reason for government inactivity may be an assumption that indoor air pollution is simply not as serious as other problems that are on the regulatory agenda. A look at the facts reveals that this is not the case. Pollutants that are released indoors are present in higher concentrations indoors than outdoors. Since the air volume available to dilute pollutants is smaller indoors, the ratio of ex- posure to emissions can be 1,000 times greater than it is for outdoor emissions.4 The problem has become worse in recent years for several reasons. Efforts to con- serve energy through better insulation and reduced ventilation have resulted in in- creased pollutant concentrations. “Air-tight” homes have been constructed in which resident living space has been compared to the “inside of a sandwich bag.“5

Kathy Hanrion recent/y completeda MS in poLiticalscience at MITandparticipatedin the working group on “To.& in the Won% WorRplaces: VaLues and Appmpnbte R&s” at the Conference. She has received undergraduate and graduate degrees in chemical engineering, and worked as an AAAS mass media fellow at CBS News in 1984.

277

278 K. Hamion

Furthermore, use of synthetic products has increased, thus introducing greater quantities of artificial chemicals into homes.

In these confined spaces, there are several sources of contaminants: building materials, consumer products, combustion by-products, cigarette smoke, radioac- tive leakage into buildings from natural sources, human metabolites, viruses, and allergens. One of the most popular insulating materials of the 1970s, urea- formaldehyde foam (UFFI), has been the most publicized source of indoor pollu- tion. UFFI releases formaldehyde, an acute toxin and a likely carcinogen .6 Other building materials of concern are plywood and particle board, which release for- maldehyde from the resins used in their manufacture, and asbestos insulation and ceiling tiles, which release carcinogenic asbestos fibers. Some consumer products, such as furniture and drapery fabrics, release chemicals used in their manufacture. Other products, such as cleaning solvents, pesticides, and room deodorizers, are in- tentionally dispersed into the air. The average American home contains an estimated 45 aerosol spray cans.’ Eighty-four percent of those homes use pesticides indoors.8 The National Academy of Sciences notes that measurements of emissions from consumer products are regrettably scarce, but where measurements have been made, “they can be very high.“g Unvented gas appliances, kerosene or wood heaters, and cigarettes release carcinogenic hydrocarbons, as well as nitrogen, sul- phur, and carbon oxides. Radon gas and its radioactive decay products are emitted by bricks and concrete or enter homes by leaking into basements from the soil. The Council on Environmental Quality reported that exposure to radon could be caus- ing up to 10% of all deaths from lung cancer in the US annually. lo Finally, human metabolites (i.e. , CO,), allergens, and disease vectors pose a greater health threat in buildings which have reduced ventilation.

The preceding discussion indicates that indoor air pollution is potentially a serious health threat. Risk estimates for radon alone warrant regulatory attention when compared with other carcinogens, such as asbestos, which have been regulated in the past. I1 Regulatory attention might take the form of immediate actions to reduce exposure to some indoor pollutants, with a concurrent comprehensive re- search effort to determine which actions would be warranted, effective, and afford- able to address indoor pollution in general.

Neither can the absence of government response be explained by ignorance of the problem. Various agencies and departments of the federal government have received “thousands of complaints” of poor indoor air quality.” The growing number of reported cases of nonspecific illnesses suffered by workers in modern air- tight offices has been termed “sick building syndrome.” Yet, despite this growing awareness among health professionals, regulators, legislators, and even, to some extent, the public, federal response to indoor air pollution has been “piecemeal and complaint-oriented.“13 There has been no timely, coordinated effective response to the broader and growing problem of indoor pollution. Despite ample evidence to the contrary, pollution is still generally perceived to be an outdoor problem.

The premise of this paper is that the absence of such a response is a significant phenomenon. Although it is inherently more difficult to demonstrate why a prob- lem has not reached the agenda than why it has done so, there are reasons which

Out-of-Sight- Out-of-Mind 279

suggest that indoor air pollution has not reached the agenda by considering several of the most frequently proposed reasons why issues do achieve agenda status. Cer- tain characteristics of the problem limit the actions of relevant groups that could put the issue on the policy agenda. These characteristics of indoor pollution are its diffuseness, its technical nature, its location (in the home), and the lack of obvious disasters attributable to it. Furthermore, the predominant social construction of the issue tends to prohibit adoption of aggressive policy solutions. The remainder of the paper will discuss how these characteristics of the problem affect social per- ceptions and the roles of technical professionals, the government (regulators and legislators), interest groups, and the media in addressing the issue of indoor air pollution.

Social Construction of Indoor Air Polhtion

Recognition of indoor air pollution as a topic for public regulation involves “publicizing” what has traditionally been a private domain. Although indoor pollution occurs in public buildings, rented dwellings, and offices, general discus- sions of the problem often emphasize its occurrence in private homes. Americans associate many ideals with the home-safety, privacy, individual freedom-which are not consistent with government interference. The framing of the problem as one of private dwellings may in part explain public and government reluctance to acknowledge the potential public health threat (an alternate framing of the issue).

The social construction of indoor air pollution as a private issue may be par- ticularly influential in the United States, where the cultural ethos of individual rights and freedom is especially strong. Legislators’ questions at Congressional hearings tend to focus on pollution in schools, public buildings, and offices, although the same phenomena occur in private homes. I4 Regulators’ responses thus far have tended to affirm the view that indoor pollution falls on the “wrong” side of the public/private distinction. They claim lack of jurisdiction, while emphasiz- ing the role of the private sector in dealing with the problem. Is The Reagan ad- ministration’s anti-regulatory ideology emphasizes the public/private distinction, and encourages regulators in executive agencies to frame pollution issues as matters of private domain whenever possible.

Success in the framing of the problem as one of private dwellings may contribute to public reluctance to accept the potential health threat, given traditional views of the home as a safe retreat. Also, it is noteworthy that the US government does not consider the home as a workplace, even though it is the traditional location of much work, and thus it is not regulated under the Occupational Safety and Health Act.

The public/private conflict has not deterred researchers from investigating in- door pollution, perhaps they are primarily concerned with scientific and technical issues which are not affected by the privacy of a building. Their reports of indoor air pollution as a public health threat may eventually lead to a change in the social construction of the problem. Although the view of the home as a safe place may delay public recognition, if it becomes widely perceived that homes may be unsafe for reasons beyond the owners’ control, public reaction may become extreme. (Ar- ticles with titles such as “Our House was Endangering Our Health” are beginning

280 K. Haniron

to appear in popular journals. 16. j There are precedents for government interference in private homes: building codes, fire ordinances, and zoning laws. These regula- tions to protect “public” safety may have only become acceptable after a similar reframing of the issues.

Roie of Professionals

Health and environment professionals were the first to recognize indoor air pollu- tion as a problem. The first article on the subject in North America appeared in 197 1. I7 By the early 1980s there was a sizeable and active international professional community concerned with indoor air pollution. I* Some professional organizations have adopted indoor air pollution policies, or revised their suggested standards to incorporate indoor pollutant considerations. l9 Such standards and policies, however, are only advisory and do not have the legal force of government regula- tions. Despite relatively widespread interest and recognition of the problem within the scientific and engineering communities, this interest has not yet been conveyed to the affected public nor translated into government action. One can, however, be hopeful that the professional community is beginning to assume an advocacy role, which may eventually have an impact of government recognition of the indoor air pollution problem.

There are several possible explanations for the ineffectiveness of researchers in bringing indoor air pollution to the regulatory agenda to date. First, they may not have tried until recently. Early articles on indoor pollution do not emphasize the political significance of the findings. The specialization and exclusiveness of the scientific community do not encourage general publicity. Moreover, institutional factors which explain regulators’ reluctance to adopt the issue (as discussed below) may have been more powerful than the researchers’ interest. This is particularly plausible since many of the interested scientists depend on the same reluctant regu- lators for their budgets to research the issue. This would limit the amount of research that they could do, and provides incentives not to “go public.”

The Rok of Regul’ators

Scientists and engineers working for the Environmental Protection Agency (EPA) and other government agencies were the first government officials to recognize the potential hazards of indoor air pollution. Yet, to date, there has been little action. The Consumer Product Safety Commission (CPSC) has taken isolated actions on a few products.20 Since 1980, the EPA and Department of Energy (DOE) have each provided a couple of million dollars per years for indoor air pollution research,*’ a small fraction of the research funding for outdoor air pollution projects. In recent years, both agencies have repeatedly attempted to eliminate funding for indoor pollution research, claiming that the topic is not within their jurisdiction.** Funds that these agencies have actually spent on indoor air pollution research were allo- cated by Congress as line items to prevent their complete elimination.

These federal agencies have paid lip-service to the problem, while attempting to pass off responsibility onto other agencies or the private sector. In other countries

Out-of-Sight- Out-of-Mind 281

(Canada, the Netherlands, Sweden, West Germany, and Denmark), indoor stan- dards and stricter product regulations have already been enacted. Even some state and local governments in the US have responded with regulations.23

Cobb and Elder suggest that issues are less likely to be adopted by government officials if there is no single institution in place to receive the problem. 24 This is cer- tainly the case with indoor air pollution. Jurisdiction for some pollutants is shared by several agencies, whereas for others, there is no obvious assignment of respon- sibility . 25 Agencies which share responsibility for indoor air pollution in the federal government include EPA, DOE, HUD, CPSC, HHS, NIOSH, OSHA, and the Center for Disease Control. Thus far, in the absence of a clear statutory mandate, adequate funding, and political support, each agency has expressed reluctance to assume full or even partial responsibility for indoor air pollution. Some agencies, such as the EPA, already have their plates full, and therefore may be reluctant to take on such a large responsibility, especially one that could force them to radically change their approach to air pollution in general, and to exposure assessment in particular. Furthermore, acknowledgement of the seriousness of the indoor air pol- lution problem may undermine the public impression that costly government pro- grams to control outdoor pollution have been successful in significantly improving public health by reducing exposure to pollutants.26 The agency’s own Science Ad- visory Panel recently warned that federal pollution regulation “may become less defensible in the near future” in light of “emerging evidence of the importance of indoor air quality.” 27 For other agencies, such as the DOE, indoor air pollution problems arise in part because of their own energy conservation policies, and there- fore, acceptance of the issue would involve backing off on other programs. The General Accounting Office has recognized the lack of a clear mandate on indoor air pollution, and recommended amending the Clean Air Act to assign responsibility to the EPA.2B Although the statute’s mandate to protect “ambient air” is ambiguous;

the EPA has chosen to interpret it as referring to outdoor air only.29 Although Cobb and Elder’s argument that issues are less likely to reach the agenda

when no single agency is prepared to receive the problem is helpful, it is also some- what circular. If an issue is truly new, it is unlikely that there would already be clear jurisdiction over it. Although the absence of a receiving agency is influential in keeping an item off the agenda, in certain situations other factors must more than compensate for this effect. The existence of effective public pressure or a national disaster could provide sufficient incentives for legislators to adopt the problem, even without a single receiving agency.

The RoLe of Legidators

Federal elected officials have expressed some interest in indoor air pollution. Agency efforts to halt funding for research on indoor air pollution have been attacked in public hearings, and circumvented by appropriating funds specifically for the sub- ject. 3o Legislators’ interest is surprising, given the lack of public and media atten- tion to the problem. It is likely that officials who demonstrate the greatest interest in indoor air pollution have personal or staff contacts with researchers in govern- ment agencies who have alerted them to the problem. Despite the limited interest

282 K. Hation

demonstrated to date, however, a situation has yet to evolve that would provide or publicize sufficient incentives for more members of Congress to support a compre- hensive indoor pollution policy.

The Rob of Interest Groups

Regulators’ reluctance to take action on indoor air pollution has not been challenged by an organized public group. Occupants suffering from “sick building syndrome” and homeowners with symptoms of exposure to formaldehyde from UFFI have made only individual complaints to various agencies. The only active public in- terest groups have been those concerned with non-smokers’ rights. Complaints have thus only been registered by those suffering from acute effects of visible or well-publicized pollutants. Given the reluctance to regulate indoor pollution, few incentives to abandon a complaint-oriented approach exist. Yet, this approach ig- nores the potential for longer-term and less localized, chronic effects. If regulators wait until they receive complaints, it will be too late to help victims of cancer or birth defects.

There are many explanations for the lack of organized public response to indoor pollution. The risks posed by indoor air pollutants are an extreme case of what Wil- son terms “diffuse harms.“31 That is, there is a very small risk per person, but the number of people at risk is very large. Although tens of thousands may be harmed nationally, the risks are not only too diffuse to provide an incentive for action by the affected parties, they are often too diffuse even to be recognized by any one in- dividual.

The actual physical symptoms of exposure to indoor air pollutants may be non- specific, and, therefore, the cause may be difficult to diagnose. Acute reactions to indoor pollutants may include headaches, sore throats, or respiratory difficulties. Many people do not associate their symptoms with pollution within the home and would be unable to pinpoint the offending sources even if they did.

Lack of public awareness of the problem is the largest obstacle to the rise of pub- lic pressure. Indoor air pollutants seldom provide sensory clues to their presence. This is not as much the case with outdoor pollution, with its visible and irritating

smog, or demonstrated effects of acid rain. Although there may be an odor or acute symptoms for some chemicals, substances such as radon, asbestos fibers, and com- bustion by-products can only be detected using sophisticated devices. The affected public has not been well informed of the potential risks of indoor pollution by either the media (discussed later) or the scientific community. Even if the public did have access to studies on indoor pollution, few people would be capable of understanding the information in the technical terms in which it is now stated.

Finally, those who are most affected by indoor air pollution would be the least likely to be aware of it, and the least able to do something about it. Although poorer people often live in poorly insulated and, therefore, less air-tight dwellings, this may be more than compensated for by the greater use of unvented gas appli- ances (for heating as well as cooking), and the higher incidence of smoking per capita.32 Residents of mobile homes (who also tend to have lower incomes) are ex-

Out-of-Sight- Out-of-Mind 283

posed to much higher levels of chemicals such as formaldehyde ,33 as a result of poor ventilation and the extensive use of synthetic materials in mobile-home interiors. The poor are more likely to rent their homes, and so have less control over their liv- ing conditions. If they do own their homes they can not usually afford to remedy problems. 34 Poor people are less likely to have the expertise to understand the tech- nical information now available. The growing number of aged poor have the addi- tional problem of spending a higher percentage of their time indoors. Women who work in the home also spend substantially more time in their homes than men and women who work outside the home. It is not surprising that these groups of suscep- tible people have not been active in lobbying for indoor air pollution legislation, since they are not traditionally politically active nor technically trained, and often have more obvious and pressing problems.

The lack of activity on indoor pollution among existing pollution-oriented in- terest groups is more puzzling. Most historically active environmental groups have an orientation toward wilderness and natural resource issues. Indoor pollution, therefore, may not readily fit into their activities and interest. This, however, can- not explain the lack of interest on the part of national public health or consumer oriented groups. In Wilson’s model, the collective action problems in this situation can only be overcome if a skillful policy entrepreneur adopts the issue.31 Thus far, no entrepreneur has stepped forward.

Non-smokers’ rights groups, such as the Group Against Smokers’ Pollution (GASP) and Non-Smokers’ Rights Association, have been active and somewhat successful in obtaining legislative solutions to that one particular aspect of indoor pollution. Although these interest groups have become aware of the indoor air pollution problem through their activities, there is no incentive for them to adopt the larger problem. Non-smokers’ rights groups likely perceive that they will have more success if they push a single issue at the local or even state level than if they dilute their effectiveness by taking on a larger problem and a larger political juris- diction. It is noteworthy, however, that the only fledgling indoor air pollution public interest group is being organized by a woman who was active for several years with a local GASP group.35 The American Lung Association has also begun to dis- play interest in indoor air pollution as an offshoot of its anti-smoking campaign. Nonetheless, the interests of the public which would potentially benefit from an indoor pollution policy remain diffuse and unrepresented.

The Role of the Media

The media first took notice of indoor air pollution in the late l97Os, probably in response to both the increasing number of articles appearing in scientific journals and the growing number of complaints associated with UPPI (which was first in- stalled in the US in the mid-1970s). The first article on indoor pollution in a popular journal appeared in 1978. 36 By 1982, 24 articles on indoor air pollution are listed. Although the earliest stories appeared in popular science journals such as Technology Review and Science News, by 1982, Consumer Reports, Redboo&, and McCaL!. were also publishing articles on indoor air hazards.

284 K. Harrison

Doris Graber’s discussion of news reporting provides several insights into media coverage of indoor air pollution.37 For the most part, stories have emphasized in- dividual indoor pollutants or polluting products, such as formaldehyde, asbestos, and kerosene heaters. This approach avoids the more complex issues of indoor pollution in general, and also allows easier sensationalization and personalization of the story. Furthermore, emphasis on individual pollutants neglects the potential synergistic risks posed by combinations of pollutants. Despite increased attention to indoor pollution, the media have not presented it as an issue comparable to other environmental problems, such as acid rain or hazardous wastes. In part, this may be explained by the same reasons that the public is not activated. However, the lack of a “news peg” such as obvious deaths, mutilations, or disasters, lack of identifiable victims or culprits, and absence of public conflict may also limit media attention to the issue.

Conchsions

The absence of attention to indoor air pollution illustrates that certain types of problems are unlikely to achieve the public agenda as a result of their characteristics, and perceptions of them, but not necessarily their gravity. In the case of indoor pollution, its peculiar characteristics do not galvanize the public and the media, and, hence, it is not an attractive issue to legislators. The presence of unfavorable institutional factors, combined with the antiregulatory tenor of the times, deters regulators from adopting the issue. The interdependence of social groups in affect- ing each others’ perceptions and actions is striking. Major changes within any one group may have sufficient impact on the others to put the issue on the agenda. For instance, particularly well-documented and horrifying results published by the scientific community (especially sudden ones, rather than a gradual accumulation of information) could activate the press, the public, and, thus, legislators. Alter- natively, a change in administration would likely bring more receptive regulators. Finally, an effective policy entrepreneur might raise public awareness and activism.

Recent developments indicate that such changes may have begun to occur. In 1984, the EPA published a draft policy proposal which acknowledged the signifi- cant health risks posed by radon. The report estimates that over one million homes are contaminated with the radioactive gas, resulting in between 5,000 and 20,OOO lung cancer deaths each year.38 The release of such results indicating large numbers of deaths and even identifiable victims (those living in areas with particularly high radium content in the soil), received relatively widespread media attention, with articles on indoor air pollution appearing in The New York Times and Time.39 In response to the EPA report, in September, the Senate authorized a $6 million two- year research program on radon and other indoor pollutants in its version of legisla- tion to reauthorize “superfund.” However, whether media and Congressional at- tention will be sustained long enough to result in concrete action to lessen the hazards of indoor pollutants remains to be seen. One can only hope that interest in indoor air pollution hazards will spread, thus overcoming the obstacles to wide- spread attention discussed in this paper.

Out-of-Sight- Out-of-Mind 285

Notes

1, National Academy of Sciences, Indoor Air Polhtunts Washington, DC: National Academy Press, 1981), p. 1.

2. For good reviews of the state of knowledge about indoor pollutants and their effects, see the National

Academy of Sciences report on indoor air pollutants, or John D. Spengler and Ken Sexton, “Indoor Air Pollu-

tion: A Public Health Perspective,” Science 221 (July 1, 1983). p. 9. The effects of passive cigarette smoking

are discussed by James L. Repace and Alfred H. Lowery, “Indoor Air Pollution, Tobacco Smoke, and Public

Health,” Science 208 (May 7, 1980), p. 464. 3. Council on Environmental Quality, Environments Quality (Washington, DC: US Government Printing

Office, 1980). p. 184. 4. Kathryn Harrison, Dale Hattis and Katherine Abbat, Implications of Chemical Use for&posure Assessment.

report no. CTPID 86-2 (Cambridge, MA: MIT Center for Technology Policy and Industrial Development,

February 1986), p. 74.

5. Michael Gold, “Indoor Air Pollution,” Science 80 (March-April 1980), p. 30.

6. For a survey of scientific reports and government actions regarding formaldehyde, see Nicholas Ashford, C.

William Ryan and Charles Caldart, “A Hard Look at Federal Regulation of Formaldehyde: A Departure from

Reasoned Decision-Making,” Harvard EnvironmentalLaw Review 7, no. 2 (1983). 7. Laurence F. Kirsch, “Behind Closed Doors,” Envimnment 25, no. 2 (March 1983). p. 39.

8. US Environmental Protection Agency, “National Household Pesticide Use Study,” EPA 549/9-80-002

(1982). 9. National Academy of Sciences, op. cit. note 1, pp. l-4.

10. Council on Environmental Quality, op. cit. note 3.

11, The EPA’s maximum risk estimate for radon, as reported by the Council on Environmental Quality, of up to

10% of annual deaths from lung cancer, is considerably higher than lung cancer estimates for occupational

exposure to asbestos, which typically vary between 1% and 3 % of annual lung cancers. (See Federa/ Regrjter 49 [ 19841, p. 14116.) Yet, asbestos has been the subject of considerable occupational exposure regulation, as

well as some consumer product bans.

12. Council on Environmental Quality, Envimnmentcu’Qwdity 2983 (Washington, DC: US Government Printing

Office, 1983). 13. Ken Sexton and Robert Repetto, “Indoor Air Pollution and Public Policy,” Environment Internatiomu’, Vol. 8

(1982) p. 5. 14. House Committee on Science and Technology, Subcommittee on Natural Resources, Agricultural Resources,

and the Environment, Hearings on Indoor Air Pollution, August 2-3, 1983.

15. See the testimony of Joseph Tribble, Assistant Secretary, Department of Energy, and Donald Ehreth, Office

of Research and Development, Environmental Protection Agency, at House Hearings on Indoor Pollution,

August 3, 1983.

16. D.S. Robb, “Our House Was Endangering Our Health,” RedbooR (October 1982).

17. The first article cited in the US is usually John E. Yocum. W.L. Clink, and W.A. Cote, “Indoor/Outdoor

Air Quality Relationships,” Journal of the Air Pohtion Con& Association, Vol. 2 1 (1971), p. 25 1. The

paper summarized the results of the first major US study, which was funded by the National Air Pollution

Control Association, the forerunner of the EPA.

18. The first international conference on indoor air pollution was held in Massachusetts in 1981. Over 100 papers

were presented by authors from around the world. Many of the papers are printed in a special issue of En-

vironment Internationa/, Vol. 8 (1982).

19. The American Society of Heating and Refrigeration Engineers revised its standards for acceptable ventilation

in 1984. The Air Pollution Control Association published a policy paper on indoor air pollution, and adopted

indoor air quality as its primary issue for 1985.

20. The Consumer Product Safety Commission banned urea-formaldehyde foam insulation in 1982, The ban,

however, was overturned by the 5th Circuit Court in 1983. The CPSC has required warning labels on kerosene

heaters, and required that they automatically shut off if the level of oxygen in the room falls below a certain

level. CPSC has banned the use of asbestos in certain home products, such as spackling compounds. Finally, the CPSC has limited allowable emissions of ozone from photocopy machines. See Laurence Kirsch, “Behind

Closed Doors-Part 2,” Environment 25, no. 3 (April 1983). p. 27.

2 1. Reports of the exact amounts spent by government agencies on indoor air pollution research vary somewhat. This is not surprising, considering that figures are quoted both by EPA officials who want to discontinue

research, while defending their already “extensive” effort, and by authors and legislators who want to increae

government spending on the subject. See James Repace, quoted by Laurence Kirsch in Environment 25, no. 2

(1983), p. 18. Also see Anne Burford, quoted in Occupa#iona( He&b and Safety Reporter, Bureau of Na-

tional Affairs (October 23, 1981) p. 797.

286 K. Hation

22. See testimony by Tribble (p. 378) and Ehreth (p. 390) in House Hearings on Indoor Air Pollution, op. cit. note 15.

23. For a discussion of standards in place elsewhere, see National Academy of Sciences. Indoor Air Poffutunts (1981), Appendix A; Robert A. Berstein et a/, “Nonoccupational Exposures to Indoor Air Pollutants: A

Survey of State Programs and Practices,” Amenian Journa(oj’Pub/ic Health 74, no. 9 (September 1984), p.

1020; and I. Anderson et a/. , “A Strategy for Reduction of Toxic Indoor Emissions,” Environment Interna- tional, Vol. 8 (1982), p. 11

24. Roger W. Cobb and Charles D. Elder, Participation in American Pohtics: The Dynamics of Age?& Building, 2nd ed. (Baltimore: Johns Hopkins Press, 1983), Chapter 5.

25. Actions to control indoor air pollution are possible under several statutes and local ordinances. EPA could

regulate some pollutants under the Clear Air Act and Toxic Substances Control Act. CPSC has authority for

some sources under the Consumer Product Safety Act. Remedies under that act, however, would be limited

to bans, product standards, or information requirements, and could not include, for instance, ventilation re-

quirements. Housing and Urban Development and local or state government could alter ventilation require-

ments. Thus, some pollutants could be regulated under many statutes, while others-such as radon-may

not be effectively regulated under any statute. Furthermore, no agency has sufficiently comprehensive authority

to consider which type of remedy would be most effective and cost efficient for all pollutants. For a more

detailed discussion of possible legal remedies, see Laurence Kirsch, “Behind Closed Doors: Indoor Air Pollu-

tion and Government Policy,” Harvard Environmental Law Review 6, no. 2 (1982). p. 339.

26. Spengler and Sexton, op. cit. note 2. 27. The report of the EPA’s Scientific Advisory Panel was quoted in the Bureau of National Affairs’ Environment

Reporter (April 12. 1985). p. 2185.

28. General Accounting Office, “Indoor Air Pollution: A Growing Health Peril,” report to the US Congress,

1980. 29. The Clean Air Act authorizes the EPA to “protect and enhance the quality of the Nation’s air resources.” The

EPA, however, has defined ambient air as “that portion of the atmosphere, external to buildings, to which

the general public has access.” (See James L. Repace. Environment International, Vol. 8 (1982), p. 21.

30. See House Hearings on Indoor Air Pollution, 1983.

3 1. James Q. Wilson, “The Politics of Regulation, ” in James McKie, ed., SociaL ResponsibiZty and the Business Predicament (Washington, DC: Brookings Institution, 1975).

32. Although overall 79% of American homes have at least one smoking resident, the incidence of smoking is

higher in lower economic classes. See National Academy of Sciences, op. cit. note 1, pp. 42 and 153.

33. EPA’s Advance Notice of Proposed Regulation of Formaldehyde, published May 18. 1984 (Federal Regula-

tion 21870) estimated that 4.2 million mobile home residents are exposed to 0.25 ppm formaldehyde, com-

pared to the level of 0.03 to which over 100 million residents of conventional, non-UFFI homes are exposed.

34. Poor people who own their own homes are more likely to live in mobile homes, which have higher levels of in-

door air pollutants. See National Academy of Sciences, p. 420. Removal of sources of indoor air pollutants

can be very expensive-in regular or mobile homes. Kirsch notes that removal of UFFI, once installed, can

cost $15,000 (Environment 25, no. 3 [April 1983). p. 33). Furthermore, although sales ofportable indoor air

filters are rapidly increasing, one would suspect that buyers of these devices are educated, upper-class home-

owners with disposal income. 35. Personal communication with Stephanie Bildner, founder of Clean Indoor Air Now.

36. Readers’ Gurde to Periodica/ Literature. 37. Doris Graber. Mass Me&u and Amenkn Politics. 2nd ed. (Washington, DC: Congressional Quarterly,

1984). 38. Two recent articles in The New Yor& Times-“EPA Plans a Campaign to Fight Radon” (October 13, 1985, p.

E7) and Philip Shabecoff, “Effort is Urged to Cut Risk from Radioactive Gas” (May 24. 1985)-have referred

to an EPA policy document, “A Strategy and Management Plan for Assessment and Mitigation of Radon in

Structures.” The policy plan calls for the agency to conduct research in high risk areas, and to provide

technical assistance to the states in support of their own radon control programs. 39. In addition to The New York Times articles mentioned in Note 38. see “The Colorless, Odorless Killer,”

Time, July 22, 1985, p. 72. 40. “Senate Votes Emergency Toxic Chemical Program,” The New Yor& Times. September 9. 1985, p. A20.