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Maintaining a clear focus for Part F

There have been suggestions that control of VOCs and CO could be included in the next generation of Part F of the Building Regulations. Alasdair Howie explains why this could be counter-productive
Less than 18 months after the ink has dried on the Building Regulations 2010 the consultation process for the next round of changes has begun. And as the Building Regulations 2016 are expected to be the most ambitious yet, some key issues will come under the spotlight.

These include suggestions by some that Part F (Ventilation) could include control of volatile organic compounds (VOCs) and carbon monoxide (CO). Given that both impact on indoor air quality (IAQ), this would seem reasonable. However, when looked at in more detail, there are compelling reasons for dealing with these issues through other parts of the Regulations.

Indeed, I would argue that trying to control VOCs and CO through Part F has the potential to increase the energy consumption of ventilation systems unnecessarily. This would put Part F in conflict with the aims of Part L (Conservation of Fuel & Power), where the two have hitherto worked in harmony, and it would do nothing to help the UK reduce its carbon emissions. It could also hamper the adoption of ore rigorous energy performance standards for buildings, such as Passivhaus.

VOCs are organic chemicals that have a high vapour pressure at room temperature. This means that large volumes of molecules from materials containing VOCs can evaporate into the air, potentially causing a range of medical problems among the occupants of the space.

VOCs almost certainly contributed to instances of so-called 'sick building syndrome' in the early 1990s, when ventilation levels were not so tightly controlled. However, in most cases, VOCs are not an ongoing problem. Typically, they are a transient issue following a fit-out or refurbishment. Consequently there is a danger that using ventilation rates to take account of VOCs will lead to higher Ventilation rates than are necessary to maintain everyday IAQ levels, leading to excessive energy consumption. And this will be exacerbated as building envelopes become tighter and mechanical ventilation with heat recovery (MVHR) becomes more widely used. In fact, this flies in the face of the principles of demand controlled ventilation, which seeks to avoid overventilation.

Furthermore, there have been significant changes to regulations pertaining to the VOC content in materials. For example, EU Directive 2004/42/ CE committed all EU states to ensure the VOC content of products was reduced to 72 per cent of 2,000 levels by 2010. In the case of adhesives, fillers, paints, primers and decorative materials manufactured in Europe, these have had to be free of solvents and plasticisers since 2010. Similarly, many furniture and fabric manufacturers have launched VOC-free products.

Tackle VOC issue at its roots
As a result, it would be more practical and sensible to tackle the issue of VOCs at its roots. Architects and interior designers could be encouraged (or required) to specify only VOCfree materials, paints and adhesives. If necessary, this could be enforced through amendments to Part D (Toxic Substances) of the Building Regulations.

The argument for not including CO in Part F is, I suggest, even stronger. Given the potential danger to occupants of elevated CO levels, this is clearly another aspect of indoor pollution that should be prevented, rather than controlled through ventilation regulations. In fact, this already falls within the remit of Approved Document J (Combustion Appliances and Fuel Storage Systems), which seeks to eliminate faulty appliances and bad installations.

So it's hard to see what would be gained by bringing CO into Part F. For all of these reasons it seems clear that burdening Part F with issues that are, or can be, adequately dealt with in other parts of the Building Regulations would be counter-productive. The focus of Part F should continue to be to ensure acceptable IAQ on a day-to-day basis, working in conjunction with Part L to ensure this is achieved efficiently.

Some studies indicate that the energy savings associated with Demand Controlled Ventilation (DCV) could be as high as 50 per cent so it is important to include only the elements of IAQ that are correctly addressed by Part F. These include humidity and CO2 levels, the latter being directly linked to occupancy levels.

Consequently, clear, sensible goals for Part F 2016 would include increasing the use of DCV, so that ventilation levels are more closely aligned to ventilation requirements. This should also be combined with MVHR to minimise heat losses from the building. These are areas where Part F can make a real difference to comfort levels and carbon emissions.

// The author is marketing manager at Soler & Palau //

1 March 2012

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