This is the fourteenth in a series of risk communication columns I have been asked to write for The Synergist, the journal of the American Industrial Hygiene Association. The columns appear both in the journal and on this web site. This one can be found (more or less identical except for copyediting details and a couple of cuts for space) in the August 2007 issue of The Synergist, pp. 52–54.
One of the most daunting risk communication problems managements routinely face is a rash of employee complaints about indoor air quality (IAQ). Whatever the presenting symptoms – headaches, nausea, actual rashes, or even the dreaded Multiple Chemical Sensitivity – the possible consequences are dire. More than one building has had to be abandoned altogether because its occupants flat-out refused to return. More than one jury has returned big-money judgments to compensate plaintiffs for the presumed impacts of a “sick building.”
How you communicate with affected people may well determine how – or whether – an IAQ controversy gets resolved.
Real Problems, Psychogenic Symptoms
IAQ risk communication is grounded in this basic conundrum. On the one hand, most buildings have real IAQ deficiencies. On the other hand, most IAQ complaints are largely psychogenic.
As the U.S. EPA has famously said (it’s a quote used to sell home air purifiers), the air inside the average house is dirtier than the air outside. Office and factory air can easily be dirtier still. You know the main culprits better than I do – from mold to VOCs to HVAC inadequacies. Your facility can meet all the relevant OSHA standards and still have a long list of ways air quality could be improved. Even if the air isn’t actually “bad,” it is almost always bad enough to make some employees’ symptoms (and other employees’ worries) credible on their face.
But there are similar air quality deficiencies in buildings that never experience IAQ complaints. Certainly poor air quality leads to more symptomatic employees than good air quality. But in my experience, three other factors are also important in determining how much IAQ controversy you’re likely to face:
- Underlying morale and labor-management relations: Unhappy employees are likelier to find the conditions unacceptable, likelier to decide the building is sick.
- A precipitating event: A new cleaning fluid with a distinct odor or a bad storm that floods part of the building can get people thinking about IAQ.
- Above all, an inadequate communication response from management to the precipitating event and the expressions of concern it triggers.
The worst response: Management says nothing publicly, appearing to be paying no attention. Meanwhile, it quietly brings in an expert to identify and fix as many IAQ problems as possible – at least the cheap ones. When employee complaints fail to subside, management belatedly decides to go public. It makes a show of testing air quality (again), points out that everything looks pretty good (now), and implies that employees with symptoms must be troublemakers, malingerers, or nutcases.
By contrast, IAQ controversies are likeliest to go away if management takes the precipitating event and the early complaints very, very seriously. Worry with your employees. Worry more than your employees. (This is the risk communication seesaw; the more worried you let yourself look, the calmer everyone else is likely to get.) Ask employees what they think might be behind their symptoms, and then look there first. Some of the possible problems employees point to will inevitably turn out to be genuine deficiencies. They may or may not account for the symptoms (odds are you’ll never know). But they’re not too hard to fix. So fix them – publicly, with lots of fanfare and employee oversight. Express guarded hope that maybe you got to the root of the problem, and determination to find some more things to fix if the first batch didn’t do the job.
Talk First, Fix Later
The obvious truth we tend to forget: A “secret” IAQ improvement can correct only the technical part of the problem. But a public improvement – especially a public improvement employees suggested and predicted would help a lot – addresses the psychological part of the problem as well. So talk before you fix anything.
I’m not saying you should just let your building’s air quality deteriorate until employees finally get around to demanding improvements. Of course it’s wise to maintain IAQ at as high a level as feasible. But whatever your level of maintenance, when the IAQ complaints start to surface, don’t rush out and secretly do a bunch of upgrades without telling (or asking) anyone. Visible responsiveness is a key to resolving the psychogenic component of IAQ controversies. Eventually you’ll probably end up fixing some things that employees are demanding you fix. Try to reach that point before you’ve already fixed everything that isn’t terribly expensive and everything that is actually likely to help technically.
The following additional tips on IAQ risk communication aim to help you address the psychological side of indoor air quality as well as its technical side – “as well as,” not “instead”!
Investigations, Committees, and Consultants
- Fixing problems is usually more useful than investigating problems. By all means conduct a commonsense survey of building conditions; work especially hard to track down the source of anything people are detecting on their own – an odor, for example. But think twice before commissioning environmental sampling. The tests are expensive, the number of compounds to test for is nearly infinite, and the test results are often inconclusive. Furthermore, discovering that your building doesn’t violate the regulatory standard (assuming there is a regulatory standard for the compound in question) may well make it harder to convince management that improvements are justified, and harder to convince employees that the improvements did the trick.
- Formal testing is justified only when everyone has agreed beforehand what you’re testing for, why you’re testing for that rather than something else, what constitutes a bad result, what you’ll do if you find one, and what you’ll do if you don’t. Whatever testing you decide to undertake, bear in mind that one key goal is to find something you can fix – and then retest to make sure it got better. Testing that rules out possible sources of the problem actually makes it harder to accomplish documented improvements.
- You’re going to want an employee committee to help oversee the improvements, as well as any testing you decide to do. If you already have a union or an employee safety committee, it usually makes sense to work through them. But make sure you supplement the existing group with some of the employees who are most upset about your IAQ problem. (This may mean meeting offsite whenever possible to minimize their exposure.) The ideal employee oversight team includes both employees who are very concerned and employees who aren’t.
- You’re also going to want an outside IAQ consultant. Even if you have ample expertise in-house, an outside consultant will add value by adding credibility. Ideally, the consultant should report to your employee oversight team, not to management. If you can’t talk management into that, at least the consultant should communicate freely with the employee oversight team, and with employees generally. (Another option: Give the oversight team a Technical Assistant Grant to hire its own consultant, who then works as a peer with management’s consultant.) Try to find a consultant who knows how to explain technical topics in plain English, and who comes across as candid whether s/he’s saying that X looks bad or that Y looks okay. Above all, try to find a consultant who is willing to say that X looks bad if it does, and that Y looks okay if it does.
Communicate, Communicate, Communicate
- Plan on a lot of employee communications. Put the oversight team and the outside consultant(s) in charge of a lot of it – but don’t let facility management disappear from view. Remember that time spent listening to employees’ concerns is at least as valuable as time spent telling them what you’ve found or what you’ve done. You’ll probably want to meet individually with employees who are reporting serious symptoms, so you can talk about their specific health situation and the options for dealing with it. (Check first with legal counsel in case HIPAA waivers may be needed.) But don’t exclude your most upset employees from the more general meetings. Let them come, and let them rant (if they’re disposed to rant). And if other employees are jeering or even just rolling their eyes, be sure you come to their defense.
- Never say or imply that anyone’s symptoms are all in his or her head. You probably can’t get through an IAQ controversy without occasional mention that some part of the problem may be psychogenic – but making that a recurring leitmotif won’t help. When it comes up, the point should be that some suffer worse effects than others from the same conditions. But the conditions themselves are real, and you’re determined to improve them.
- Try not to evacuate a building, or part of a building, until there has been agreement on the criteria for reoccupying it: “until the outside consultant says it’s okay,” “until the readings are below X,” “until we have finished replacing the wallboard,” whatever. The same goes for removing individual employees. Either you transfer them for good, or you move them (or let them stay home) until specified criteria are met. Note that “until you feel better” isn’t a criterion; it’s a set-up for future conflict.
- Work closely with your attorneys, but try not to let them run the show. Bear in mind that the worst case scenario, legally, is a class action tort case alleging both serious health effects and management negligence/intransigence. The best way to prevent such a lawsuit is for management to show its concern. The best way to defend such a lawsuit (if it materializes) is to have evidence of how much concern management showed. Lawyers who won’t let you show concern, for fear that it’ll be used in court as proof that the company knew the problems were serious, have a point – but on balance showing concern is a better bet than blowing off the problem or fixing it secretly.
The approach outlined above is likeliest to yield both cleaner air and employees who think the air is cleaner and stop feeling sick. It is grounded in the fact that most IAQ controversies involve a combination of air quality that needs improving and risk communication that also needs improving. But what if you improve them both … and lots of employees are still reporting symptoms? What if you’ve built a good rapport with the workforce and together you’ve done all the obvious fixes … and people are still getting sick? Once the likelier hypotheses have been eliminated, you must seriously investigate the possibility that you have a tougher and subtler technical problem.
But start with the likelier hypotheses. And before you fix anything, talk.
Copyright © 2007 by Peter M. Sandman