After acknowledging electromagnetic sensitivity (EMS) in 2002, the U.S. Access Board contracted with the National Institute of Building Sciences (NIBS) to develop an Indoor Environmental Quality project, the first step in the Access Board’s “action plan to reduce the level of chemicals and electromagnetic fields in the built environment” for the EMF-disabled and those disabled by multiple chemical sensitivities.

In 2005, NIBS released a 97-page Indoor Environmental Quality report, containing extensive recommendations and resources. The report and its sections are on the Access Board’s website here 

A PDF of the entire report as it was released in 2005 is here:

(Links in the quotes below may not be working links, but these documents are still available.)



The Architectural and Transportation Barriers Compliance Board (Access Board) is an independent federal agency devoted to accessibility for people with disabilities. The Access Board is responsible for developing and maintaining accessibility guidelines to ensure that newly constructed and altered buildings and facilities covered by the Americans with Disabilities Act and the Architectural Barriers Act are accessible to and usable by people with disabilities. In November 1999, the Access Board issued a proposed rule to revise and update its accessibility guidelines. During the public comment period on the proposed rule, the Access Board received approximately 600 comments from individuals with multiple chemical sensitivities (MCS) and electromagnetic sensitivities (EMS). They reported that chemicals released from products and materials used in construction, renovation, and maintenance of buildings, electromagnetic fields, and inadequate ventilation are barriers that deny them access to most buildings.

There are a significant number of people who are sensitive to chemicals and electromagnetic fields. Surveys conducted by the California and New Mexico Departments of Health and by medical researchers in North Carolina found 16 to 33 percent of the people interviewed reported that they are unusually sensitive to chemicals, and in the California and New Mexico health departments’ surveys 2 percent to 6 percent reported that they have been diagnosed as having multiple chemical sensitivities. C. Miller and N. Ashford, “Multiple Chemical Intolerance and Indoor Air Quality,” in Indoor Air Quality Handbook Chapter 27.8 (McGraw-Hill 2001). Another California Department of Health Services survey has found that 3 percent of the people interviewed reported that they are unusually sensitive to electric appliances or power lines. P. LeVallois, et al., “Prevalence and Risk Factors of Self-Reported Hypersensitivity to Electromagnetic Fields in California,” in California EMF Program, “An Evaluation of the Possible Risks From Electric and Magnetic Fields (EMFs From Power Lines, Internal Wiring, Electrical Occupations and Appliances, Draft 3 for Public Comment, April 2001” Appendix 3 (

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Individuals with multiple chemical sensitivities and electromagnetic sensitivities, who submitted written comments and/or attended the public information meetings on the draft final rule, requested that the Access Board include provisions in the final rule to make buildings and facilities accessible for them.

The Board has not included such provisions in their rules, but they have taken the commentary very seriously and acted upon it. As stated in the Background [this is in the General Issues section] for its Final Rule Americans with Disabilities Act (ADA) Accessibility Guidelines for Buildings and Facilities; Recreation Facilities: [no longer working link – see below – 1]

The Board recognizes that multiple chemical sensitivities and electromagnetic sensitivities may be considered disabilities under the ADA if they so severely impair the neurological, respiratory or other functions of an individual that it substantially limits one or more of the individual’s major life activities. The Board plans to closely examine the needs of this population, and undertake activities that address accessibility issues for these individuals.

The Board plans to develop technical assistance materials on best practices for accommodating individuals with multiple chemical sensitivities and electromagnetic sensitivities. The Board also plans to sponsor a project on indoor environmental quality. In this project, the Board will bring together building owners, architects, building product manufacturers, model code and standard-setting organizations, individuals with multiple chemical sensitivities and electromagnetic sensitivities, and other individuals. This group will examine building design and construction issues that affect the indoor environment, and develop an action plan that can be used to reduce the level of chemicals and electromagnetic fields in the built environment.”

This report and the recommendations included within are a direct outgrowth from that public comment process. The Access Board contracted with the National Institute of Building Sciences (NIBS) to establish this Indoor Environmental Quality Project as a first step in implementing that action plan.

The overall objectives of this project were to establish a collaborative process among a range of stakeholders to recommend practical, implementable actions to both improve access to buildings for people with MCS and EMS while at the same time raising the bar and improving indoor environmental quality to create healthier buildings for the entire population. This IEQ project supports and helps achieve the goals of the Healthy Buildings, Healthy People project, which acknowledges that “We will create indoor environments that are healthier for everyone by making indoor environments safer for the most vulnerable among us, especially children.” (p.17)

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Summary Recommendations

The recommendations in this report are only a first step toward the action plan envisioned by the Access Board.

[1 – Link to Final Rule:  ]]

Operations and Maintenance

Introduction and Overview
Problem Summary

The operation and maintenance of commercial and public buildings can affect their accessibility for people with asthma and multiple chemical and/or electromagnetic sensitivities. The presence of many products or conditions involved in cleaning, maintaining, using, and operating buildings often contributes to poor indoor environmental quality and are access barriers for these individuals.

General Solutions

Measures taken to improve indoor environmental quality, such as reducing air pollutants, noise and electromagnetic fields in buildings, will increase their accessibility for people with asthma and chemical and/or electromagnetic sensitivities, as well as provide a more healthful environment for all building occupants.

While “green” and “environmentally-friendly” practices and products for construction and maintenance of buildings sometimes provide more healthful indoor environments and improves access for those with asthma and multiple chemical sensitivities, this is not always the case. The U.S. EPA notes that there is growing concern that standards being promoted by the green building movement, such as Green Seal and Green Guard standards, are not sufficiently protective of health (1).

For example, some measures recommended to promote energy and water conservation — such as reducing outdoor air supplied and/or reducing time of HVAC usage, using motion sensors that can create electromagnetic fields, using waterless urinals that require continuous chemical treatments, recommending cold water for cleaning, and promoting the use of alcohol hand wipes instead of hand washing – can cause or lead to increased indoor pollution and less healthful and accessible environments.

Barriers and Issues

Electromagnetic Fields

For people who are electromagnetically sensitive, the presence of cell phones and towers, portable telephones, computers, fluorescent lighting, unshielded transformers and wiring, battery re-chargers, wireless devices, security and scanning equipment, microwave ovens, electric ranges and numerous other electrical appliances can make a building inaccessible.

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The National Institute for Occupational Safety and Health (NIOSH) notes that scientific studies have raised questions about the possible health effects of EMF’s. NIOSH recommends the following measures for those wanting to reduce EMF exposure – informing workers and employers about possible hazards of magnetic fields, increasing workers’ distance from EMF sources, using low-EMF designs wherever possible (e.g., for layout of office power supplies), and reducing EMF exposure times (11).

Recommendations for Accommodations

People with chemical and/or electromagnetic sensitivities can experience debilitating reactions from exposure to extremely low levels of common chemicals such as pesticides, cleaning products, fragrances, and remodeling activities, and from electromagnetic fields emitted by computers, cell phones, and other electrical equipment.

The severity of sensitivities varies among people with chemical and/or electromagnetic sensitivities. Some people can enter certain buildings with minor accommodations while others may be so severely impacted that they are unable to enter these same spaces without debilitating reactions. Furthermore tolerances to specific exposures can vary greatly from one individual to the next.

According to the Americans with Disabilities Act (ADA) and other disability laws, public and commercial buildings are required to provide reasonable accommodations for those disabled by chemical and/or electromagnetic sensitivities.

Design and Construction

Recommendations for Future Actions

The Committee acknowledges that while the scientific evidence may be inconclusive about whether ambient electromagnetic fields pose a substantial health risk to the general population, the presence of EMF is an access barrier for people who are electromagnetically sensitive. Therefore, the Committee recommends that measures be taken to reduce EMF whenever possible in order to increase access for these individuals as well as taking a precautionary approach to protecting the health of all.