Our Ref : ENV/WKC/014
10 January 1999

Mr Kim Salkeld
Deputy Secretary
Planning Environment and Lands Bureau
9^th Floor Murray Building
Garden Road
Hong Kong



Dear

Consultation Paper on Indoor Air Quality

Thank you for the opportunity to be consulted on the indoor air quality (IAQ) management programme. As you know, the Chamber is concerned about Hong Kong's environment, not least the problem of air pollution. We have therefore found the consultation paper a very timely document. We have consulted members of the Chamber, particularly those of the Environment Committee and our comments are set out below.

The Chamber believes that as a high-density international city, it is not acceptable that so many of our buildings are "sick", and that the population and the workforce are constantly being exposed to an unhealthy environment. Hong Kong deserves the best air quality, both outdoors and indoors, that befits an advanced service economy aspiring to become "the world city of Asia". While an elaborate programme to combat ambient and road-side air pollution has been developed - which, incidentally, should in the Chamber's view be speeded up - there has for too long been too little attention paid to indoor air pollution. Hence we welcome and support the measures proposed in the consultative document.

In addition, we would like to make specific comments on the IAQ management programme, as follows.

1. In the proposed programme the emphasis has been placed on education, awareness, voluntary participation and market incentive. While we support this principle, there is a feeling that the problem is serious and ought to be addressed more quickly. The three year time table seems too long. Given the dynamic nature and can-do spirit of Hong Kong, we believe the whole process could be speeded up to, say, one year.

2. At the end of the three-year (which we propose to shorten to one-year) programme, government should be in a position to evaluate whether some form of legislation is required to make it mandatory for buildings to achieve IAQ objectives. New buildings should, as a rule, be required to do so, while the whole regime can be progressively extended to all existing buildings. In the course of implementation, there should be assistance for buildings owned by small and medium sized businesses.

3. The implementation of the IAQ programme should be facilitated by greater transparency. One important way to improve transparency is to set out clearly the costs and benefits, to society as a whole and to building owners, of the IAQ programme.

4. On the three different levels of standards proposed in the document, it seems to us that under a regime to promote indoor air quality, the specification of a quality level under the occupational safety and health laws (Level 3 in the document) is superfluous. The IAQ programme should be about quality of air itself, not about occupational safety. In any case, it is inconceivable to expect Hong Kong buildings, in general, to have IAQs that are so poor as to be beneath the lawful standard for industrial workers.

I hope you will find the above views useful.

Yours sincerely

Dr Eden Woon
Director

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