The following is a Letter to the Editor from Wilton resident Marianne Gustafson:
To the Editor:
I see that you have an op-ed from from a Wilton parent and physician who states, “I wholeheartedly disagree with any parent who believes carbon dioxide levels measured thus far in Miller-Driscoll School have any detrimental effect on student or teacher health or performance.”
Apparently, there was one reading in a classroom at over 3,000 ppm.
My questions are:
1. Why OSHA and NIOSH apparently have a different position re CO2 affects and effects?
From the OSHA document, CO2 is listed as a ‘Major Indoor Air Contaminant’ with ‘acute health effects’: OSHA Technical Manual (OTM) Section III, Chapter 2: Indoor Air Quality Investigation, found online at https://www.osha.gov/dts/osta/otm/otm_iii/otm_iii_2.html
- “Section II. Acute Health Effects of Major Indoor Air Contaminants, B. Major Indoor Air Contaminants, 2. Carbon Dioxide:”
“Acute health effects: Difficulty concentrating, drowsiness, increased respiration rate.”
- Under Section IV. Sampling Instrumentation and Methods C. Optional Screening for Common Indoor Air Contaminants, Based upon Professional Judgment 3. Carbon Dioxide.
NIOSH is apparently part of the United States, i.e., federal, Center for Disease Control and Prevention (CDC) and stands for The National Institute for Occupational Safety and Health.
The ppm breakdown recommendation levels are indicated as ‘guidelines” with respect to ‘comfort’, but I would think that the complaints these agencies have delineated as ‘acute health effects’ and headaches, fatigue… have an impact, perhaps significant, on learning.
2. Why adults’ working space then is apparently governed by OSHA and/or NIOSH regarding negative affects or detrimental effect of CO2 on bodies in a confined spaces?
And if teachers’ complaints have resulted in their being moved to a different location, then wouldn’t the factors be significant on young bodies?
If adults’ complaints receive corrective action then our children’s experiences deserve equal attention and action. And, re nosebleeds, I understand that not all the nosebleeds were happening in the winter.
3. Should the OSHA and NIOSH documents and their guidelines be disregarded? Is there a newer document regulating adult occupational space that renders this one obsolete and their past statements inaccurate? What about our children’s occupational/learning spaces?
Marianne Gustafson
I would like to refer Ms. Gustafson to:
http://www.blm.gov/pgdata/etc/medialib/blm/wy/information/NEPA/cfodocs/howell.Par.2800.File.dat/25apxC.pdf
in regards to OSHA and ACGIH summary of “Health Risk Evaluation for Carbon Dioxide” in the U.S. workplace.
Once again, I would like to stress my point that in terms of workplace safety, carbon dioxide in these studies is being cited as a surrogate for workplace ventilation. To quote the OSHA recommendations: CO2 is “a good indicator of proper building ventilation and indoor air exchange rates.”
I submit that no laboratory data or physiologic data exist for headaches, fatigue, and eye and throat irritation because of carbon dioxide. With each heart beat, arterial blood is pumped to your body and brain with a partial pressure of 40 mmHg of carbon dioxide. (THAT IS OVER 100 times the atmospheric content in pristine air!) As well, blood flow to your brain is extremely tightly regulated using carbon dioxide as one of the primary regulators.
Before jumping to a cause/effect relationship with carbon dioxide, one must realize there is NO physiologic way carbon dioxide levels in the low thousands ppm can be detected by humans. Our carbon dioxide regulation is too sophisticated, because our survival depends on it. If ANYONE is so inclined, an arterial blood gas will tell you what your exact partial pressure of carbon dioxide is. My bet is that it is 40 mmHG, no matter how many hours you spend in Miller-Driscoll School.
OSHA, ACGIH, and NIOSH recommend 5,000 ppm levels for workplaces for 8-hour day/40-hour weeks to ensure proper ventilation. Imagine how poor the ventilation must be to have weeklong averages over 5,000! The other air contaminants would be unhealthy, but not the carbon dioxide. Again, it is a surrogate indicator.
Please, think about the basic science. How does something that our body regulates tightly at 40 mmHg in arterial blood (45-50 mmHg in venous) become a problem when dealing with 1-2 mmHg atmospheric fluctuations? Carbon dioxide cannot diffuse “uphill” against a 100x concentration gradient into our arterial blood via our lungs, and even if it could, our kidneys and buffering system would take care of it (like when we produce more carbon dioxide during exercise and we breather harder). Carbon dioxide at these low levels causing illness is impossible.
Thank you,
James Babashak, M.D.
Thank you for your response; however, why does niosh recommend levels less than 1000 ppm? I thought the 5000 ppm was for adults in larger areas where there are fewer people. Office space generally is designed with ratios of 1 adult per 100, 150, 200 square feet. That would be at least 1/2 the density of people or students in a typical classroom and it certainly is not factory space which may require additional ventilation equipment.
Also, isn’t there a difference in how the lungs process the ‘air” it draws in from its environs and what those ideal concentrations should be versus the closed circulation system of the body and how the concentrations and chemical reactions along with the energy and heat that affects this closed internal system?
Ms. Gustafson:
As addressed in my position paper, I am not an industrial engineer, HVAC specialist, or OSHA expert. I do not know why NIOSH has a 1,000 ppm recommendation, when there is no physiologic reason for it. I don’t know how that level would be justified, nor how it is based (hour exposure time, yearly exposure time, etc.) Perhaps you could contact them directly to gain the information of what physiologic experiments justify their level. Given that all physiologic studies don’t mention subjective symptoms until levels of 2% CO2 (20,000 ppm), a 1,000 ppm recommendation seems drastic (especially since you can reach 1,000 just by having your blanket over your head in bed at night). Notice that OSHA has cumulative 5,000 ppm guidelines only, and that workplaces mentioned are only industrial in nature. This illustrates further why school exposure is not even considered as a hazard. No regulations exist for schools, and in a leaky school like Miller-Driscoll, you would have to literally seal a crowded room for many, many hours to drive levels up to symptomatic ranges. Again, carbon dioxide may or may not be an adequate surrogate for room ventilation, but it is not a hazard by itself at these low levels.
If I understand your second paragraph, you are asking if I am just talking about ideal situations for our body’s cardiopulmonary regulation? No, I am stating what I see clinically and what is known about human control of carbon dioxide levels in the body. Your brain, lungs, heart, kidneys, and circulatory system all work in concert to make it work. The set point, probably because of optimum enzyme function and CO2 transport, is 40 mmHg in arterial blood. In your kids, relatives, neighbors — the same 40 mmHg. In the air outside, CO2 is found at only about 0.4 mmHg. So in the usual atmospheric pressure of 760 mmHg, only 0.4 mmHg is due to CO2. So we dump out CO2 with each breath, and bring in low concentration air. You can thus see why people start to get symptomatic at 2% (20,000 ppm) and are near death at 9% (90,000 ppm). That concentration gradient gets flatter and flatter, and you would breathe harder and harder to get the CO2 out of your body. Miners, silo workers, or volcano victims have had this happen, and it is the stereotypical asphyxiant death. When you hold your breath, it is NOT lack of oxygen that causes you to take another breath, it is the brain’s sense of the minimal rise in arterial blood CO2 above 40 mmHG that drives you to breathe. That is how sensitive the system is, so that is why I am adamant that no student or teacher is experiencing symptoms based on carbon dioxide.
Yes, there could be other contaminants in the building, but carbon dioxide is not to blame. Each student and teacher in Miller-Driscoll has a normal arterial blood carbon dioxide level.
You cannot have “illness” when your body’s level of carbon dioxide is normal. I challenge any concerned student, parent, or teacher to have an arterial blood gas drawn (yes, it will hurt worse than a normal blood draw), and it will predictably be normal for CO2 (40 mmHg).
As for headaches, lethargy, fatigue, etc., one can probably ask people exiting the Wilton Market or Wilton Stop & Shop if they have had these symptoms in the past day and a sizeable percentage will answer affirmatively (as many Americans would). I have never been a big fan of subjective questions, as a certain percentage of people will always answer yes to some questions. Asking children is even trickier, as you know as a parent. If you want to show a link, please show some data or show some possible or plausible physiologic cause. This is how science works! Citing subjective studies is like asking your child if they ate the last cookie in the cookie jar, you just don’t know what they are going to say.
As for environmental exposures, we live downwind from New York City, so our airborne particulate exposure is enormous (look at your window sills). The Norwalk and Silvermine River outflows can be measured to show presence of all sorts of prescription medications (including narcotics, hormones, and antidepressants). It is thus ironic to cite a natural molecule that is found in high concentration in our body and in our every exhalation as a contaminant when we live in a densely populated U.S. suburb filled with chemical exposures.
Again, at levels of 2% (20,000 ppm) CO2, there have been positive subjective studies with long term exposure(but again, no arterial blood gas data), but not at the low levels (none even approaching 5,000 ppm even once, let alone hours of exposure!) found in Miller-Driscoll. There simply is no cause/effect link, nor any substantial exposure.
Thank you,
James Babashak, M.D.
While you maintain that CO2 is a ‘surrogate’ for ventilation issues, that is exactly the point…
except that the word surrogate may better be substituted with indicator which is supposed to represent real measurements. There are ventilations issues that affect ability to work, learning environment.
Discerning how and why NIOSH has a recommendation of 1000 ppm CO2 levels should be a question well worth your and other doctors’ assertion of your positions to challenge how OSHA came to identify and specify ‘acute health effects’ such as difficulty concentrating among other health effects as consequences of indoor air contaminants.
I note however that studies that only focus on adults in offices or factories do not mean that there are no effects on children.
We know that for years heart attack and disease models were focused on men with the results setting standards that were not applicable to women because their bodies present differently than men’s bodies. Women were put at risk as a result.
When you refer to closed body systems and the percentages or concentrations of CO2, those statements are not necessarily analogous to environmental concentrations and their affect on young children and adults.
I find it hard to make absolute statements that there is or are no affects and that there are no studies in existence. Do we know that there are or have been any studies on children? WHen were they done, what were they studying, how many children, where, under what circumstances…
is there one source as to all research studies so that a person can claim that no research or studies exist that can justify the NIOSH recommendations?
Just because CO2 is a natural molecule in high concentration in our body and is present in our every exhalation does not equate to having no effect in potentially improperly ventilated areas.
As far as having a blanket over one’s face wrt the concentration of CO2 to make a point that much higher concentrations can be tolerated, I would suspect that it would be a most natural reaction to remove the blanket, or a pillow case, or other object from the nose because of the ‘discomfort’ involved even if one could adjust to the compromised environment- it would probably be a primal reaction to ensure air intake that is healthy and normal, …The blanket over the nose doesn’t discount that hours of compromised ventilation may have real affects on children’s ability to focus, learn, interact.
Are there any studies that deal with children’s immune systems and their development when IAQ are compromised.
We are talking about good and healthy learning environments that do not compromise the health and welfare of the children and staff.
To Ms. Gustafson:
I can make absolute statements based on Dalton’s Law of Partial Pressure of Gases, the proven medical physiology of all humans, and a multitude of previous adult human exposure studies to extremely high levels of CO2.
I have yet to see the opposing viewpoint present any scientific data or theory as to how low levels of CO2 can affect children’s or adult’s performance or health. The new shift seems to be focused on “paperwork lapses”, which is not something I am interested in at all.
I find it hard to respond to your repeated comments when you present no data, no studies, and no findings that give any clue as to how minimally elevated CO2 levels can lead to any effects in adults or children. I have presented my physiologic reasoning and calculations based on sound scientific principles, so to debate in a scientific manner requires you to put up your own information. This is not FOX or MSNBC, where introducing biased statements without facts or data holds sway.
Again, CO2 may be a surrogate or indicator of ventilation (which is always suspect when used by those who are going to sell you the upgraded HAVAC systems!) HVAC regulations vary widely, and CO2 measurements vary in every room in every structure on Earth hourly. Breathing air in Fairfield County is not “healthy” either, as pathologists can show you from autopsy results on NON-smokers that live here for years. All of us live downwind of a huge metropolis, so this idea of pristine Wilton air is a fallacy just from a particulate standpoint. Live in the Northeast US, and your lungs are pretty sickly in color when examined by a pathologist.
Your statement on “closed body systems” shows that you do not understand the dynamics of how your body maintains simple homeostasis by responding to the environment. Our blood is as an open system with the air as when we were simple sea creatures maintaining salt balance in the open ocean (Compare blood and sea water and realize how similar they are in salt concentration — not a coincidence, but a fact).
We maintain our arterial blood CO2 at a partial pressure of 40 mmHg, so once again, ALL the Miller-Driscoll kids and adults will have a CO2 of 40 mmHg in their arterial blood (until the CO2 levels get to truly asphyxiant levels, like being placed to breathe in a big sealed plastic bag).
Your cry of “what about the children” holds true for many things in medicine unfortunately. Who wants their kid in a pharmaceutical study or environmental exposure study? It is hard to determine effects of new medicines (or even old medicines), because what company wants to enroll children in a drug trial? This is not a pharmaceutical problem, though, it is simply an exposure to all natural CO2 breathed out by the people in the Miller-Driscoll rooms. Miller-Driscoll is not a sealed bag, it is an old leaky school that cannot maintain CO2 levels to any noticeable level because of the natural gradient to the outside ambient air. Again, no health issue from CO2 itself!
In terms of environment, do you KNOW what the absolute worst physiologic environment any child/children ever experienced? Believe it or not, the human uterus. It has extremely low oxygen levels (babies are purple when born and fetal hemoglobin specialized for this environment), extremely high blood CO2 levels, and very high acidity (low pH). This ties in with my thesis, because the only way fetuses survive is that mothers’ whole CO2 systems ratchet down mothers’ CO2 levels to the low 30s mmHg. Hence, a GRADIENT again from baby’s blood to mother’s blood to mother’s lungs to outside. See how it works, the gradient explains once again why CO2 can be expelled, even from a fetus with its own blood supply inside the expectant mother! It is the culmination of millions of years of evolution using basic chemistry to act to achieve a certain goal — getting rid of CO2.
Millions of years of evolution has given us a CO2 system that is an optimal ventilation and chemical buffering machine. It is not a “closed body system” at all, but the result of survival pressure forces that continue today. Sadly, ALL OF US will miss the point in a handful more generations when the ambient CO2 outside is 1,000 ppm all the time. The curve for planetary CO2 atmospheric levels is entering a steep inflection point on the graph. By my calculations in my initial paper, we will still breathe fine at 1,000 ppm, and no one will have noticeable symptoms. By your statements (with no calculations, data, or proposed mechanism), we — especially our children! — will somehow have “acute health effects” continuously. Please tell me how. I have presented my gradient numbers from known human physiology in my position paper, now present yours.
I can tell you from my day job of keeping people alive during surgery that the numbers do not lie. If you have laparoscopic surgery, your abdomen is pumped full of CO2 continuously. Your body absorbs it, so I have to alter some of the ventilation parameters on my mechanical ventilator to keep your CO2 level normal. Again, not a “closed loop system”. This is what I do when you are intubated and artificially ventilated and oxygenated, so it is not a theory but my day-to-day practice.
Likewise, I invite you to talk to people who do not have normal CO2 regulation. A person with COPD, a morbidly obese person, a person with obstructive sleep apnea, and an asthmatic during an attack all can tell you (or you can watch them carefully) to see how their breathing patterns are different. The patterns are different because their bodies are TRYING to maintain that CO2 level at a nice 40 mmHg. It is a built-in thermostat, with people’s other medical problems throwing the system off kilter.
If you want real data, and a few teachers are brave enough, you could realistically have arterial blood gases drawn right in the rooms with the highest CO2 levels. It requires a blood stick usually at the radial artery at the wrist. After nearly 20 years of work in the operating room, I can tell you that the results will be normal (again, 40 mmHg). This is a fact, not an opinion. (Kids are REALLY tough to do an awake arterial stick on, but again the result would be normal).
If you want to do your own little experiment without blood involved to show how CO2 drives your breathing, try this:
1. Go to CVS and get a “pulse oximeter”, which should be around $50. It measures oxygen percentage in your blood via light waves.
2. Put the pulse oximeter on your finger, and it will read between 96% and 100% (normal room air range).
3. Hold your breath for as long as you can.
4. Write down the breath holding time.
5. Did the oxygen level change? (No)
6. Hyperventilate, meaning during a minute, take 25 big in-and-out breaths.
7. Hold your breath.
8. Could you hold your breath longer? (Yes) 9. Did the oxygen level change? (No)
This shows that the reason you are breathing normally is CO2 regulation, not oxygen blood levels. You tested low CO2 by hyperventilating, but you are worried about high CO2. Okay, observe a large group of students and teachers at Miller-Driscoll for a set amount of time in a number of locations. Any changes of respiratory rate? The answer will be no, because their arterial CO2 did not change and there was no stress on their respiratory system by any changes in CO2 levels in the different school rooms. Have the same people breathe into a plastic bag, and sure enough CO2 will rise quickly and respiratory rate will increase (like in the military studies I mentioned previously in my position paper). This would be a great project for the AP or regular chemistry classes at the high school. I believe it would be an excellent science fair project too.
Yes, I agree with you that your body will go into survival mode when CO2 levels get really high (that is why heart rate and blood pressure go up with high arterial blood CO2 levels). It is also why those who commit suicide by asphyxiation usually have to take narcotics, benzodiazepines, barbiturates, or alcohol (or some combination of all of them) to overcome that survival instinct. The Hemlock Society has whole recipes for this purpose, if you have any morbid interest. The drugs also change the brain’s CO2 regulation, allowing CO2 blood levels to rise and depressing ventilation, so the whole drug cocktail actually speeds up the death spiral. Watch the old movie “Trainspotting” to see how narcotics like heroin can facilitate respiratory arrest despite high levels of CO2 that would normally tell the body to breathe rapidly. This is how the end game of narcotic abuse plays out, simply by telling the brain that it is not important to breathe.
It is a little bit depressing for me to realize that in a suburban, well-educated, affluent town like Wilton that simple science and the scientific method is so foreign to a segment of the adult population. It is quite astonishing that statements can be made with no scientific basis and that no facts can be cited that form the foundation of this Erin Brockovich-like campaign. If you are presenting a cause-effect relationship between CO2 and a health problem, shouldn’t you at least have data and a physiologic mechanism to counter my own position on this topic? This is how science works, and I sincerely hope that the high school science classes take advantage of this parent’s unscientific approach to teach the scientific method to the current students.
On a completely different tack, I believe the teachers’ union is the most powerful one left in this country. If this was a problem, wouldn’t there be some national or even state regulations on school HVAC readings? Wouldn’t the national and local unions have had this as an issue decades ago? The devil’s advocate in me says that if it was an issue, it would have been dealt with by this point at the union-administration level all across the country. It would be a workplace safety issue, as in mines, smelters, etc. Sure, Miller-Driscoll likely missed some paperwork, but this does not generate a health issue. As egocentric as some are, Miller-Driscoll is probably not the very first school in the world to have a classroom CO2 reading pop over 1,000 ppm. You can bet that when schools had wood stoves in the classrooms, CO2 levels were higher on every cold winter day. On a common sense level, without knowing any science, one can realize this is not a new epidemic emerging from the schools on Wolfpit Road. The well organized and thorough teachers’ union would have had this covered by now if this was a historic issue of any interest to them.
Respectfully,
James Babashak, M.D.
Again, I encourage you to present your findings and assertions to OSHA and NIOSH. You need not be ‘depressed’ regarding your wrong assumption that other adults do not believe in the scientific method. The details matter even in science and in its method. Please present your findings to the government agencies and require of them to disclose the studies for their recommendations.
Dr. Babashak,
While I have taken the time to peruse your statements, I ask you to be careful with your tone and assumptions and personal projections about others.
You have presented your information and maintain your absolute position but then accuse me of having no data and no studies which is irrelevant to my question posed:
“Why OSHA and NIOSH which is part of the federal Centers for Disease Control and Prevention (CDC) have identified CO2 as an major indoor air quality contaminant and have identified 1000 ppm for indoor CO2 concentration because of its negative health affects including difficulty concentrating?”
Please see my original letter where the information is taken directly from their websites and manual.
As an anesthesiologist, do you conduct studies as to optimal cognitive function while your patients are asleep or in a twilight state?
Your word usage of ‘cry of ‘what about the children’, references to television networks, “real data”, ‘foreign to the adult population”, ‘morbid interest” , “Erin Brockovich-like campaign”, ‘this parent’s unscientific approach’, ‘pristine Wilton air fallacy”, ‘egocentric as some are’ have no place in civil discourse.
Agreed that there are other elements/factors in the school air – that is a given. Proper ventilation and proper use and care of the HVAC system are important components of work/study/learning environments. As an additional consideration, they are also important in maintaining the value of the investment in the equipment.
It appears that you are setting those actions aside as ‘paperwork lapses?’ I wouldn’t think that the maintenance or lack of documentation of your own hospital equipment would be easily accepted as ‘paperwork lapses.’
There is no ‘pristine Wilton air…fallacy’ here and making that assumption is wrong. And referring to autopsy results of non-smokers that live in Fairfield County may also be irrelevant since there would be many other factors involved regarding the condition of their lungs.
Any assumption that I believe that CO2 alone has affects on an indoor environment is also inaccurate. I had a question regrading the statements based allegedly on research from NIOSH.
Yet, studies alone on only one segment of the population, as I referenced regarding heart attacks in women vs men where women were disregarded yet presented differently, makes a point regarding absolute standards where studies have been limited in scope and here apparently the studies were on adults and not children. I don’t think it appropriate to equate studies regarding drugs for children to potential studies on cognitive function in poorly ventilated classrooms.
I also find that the characterizing the human uterus as the ‘absolute worst physiologic environment any child experiences” is misleading and not analogous to speaking about optimal indoor air quality for concentration and learning for children and staff.
Regarding your assumptions of union positions and that they ‘would have this covered by now” and that it would be a workplace safety issue – that most likely is is why OSHA and NIOSH are involved and have regulatory authority for adults = and sorry, yes, I will now ask what about the children’s health and welfare. I know directly from some staff at one of our other schools that their complaints have been ignored despite having a union.
Marginalizing that ‘some paperwork’ has been ‘missed’ does not mean there has not been or is not a health issue – so, we can go back to why OSHA and NIOSH identify CO2 and other indoor air contaminants as having acute health effects. You do not believe it to be accurate, point taken, but they do.