Our Ref : ENV/WKC/014
10 January 1999
Mr Kim Salkeld
Deputy Secretary
Planning Environment and Lands Bureau
9th 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.
- 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.
- 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.
- 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.
- 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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