Summary Report Humidification Issues in ASHRAE Standar d 62.

1
Jeff Boldt, PE, LEED AP, HBDP and Paul Hansen
Description of the Issues
Humidity control is required in many buildings including healthcare facilities. Many of
these facilities have a central boiler plant that produces steam. The most economical
humidification system for these buildings is the direct injection of boiler steam into the
airstream. The confusion for engineers and code officials is interpreting ASHRAE
Standard 62.1 section 5.13, which discusses humidifiers. An excerpt of the relevant
sections of the standard is provided below.
5.13 Humidifiers and Water-Spray Systems. Steam and direct evaporation
humidifiers, air washers, and other water-spray systems shall be designed in
accordance with this section.
5.13.1 Water Quality. Water shall originate directly from a potable source or from
a source with equal or better water quality.
This section of the standard is unclear about which common humidification systems are
acceptable. For example:
When designing humidification systems is it acceptable to inject boiler steam
directly into the airstream if it contains any amount of chemicals? As the current
standard reads it could be acceptable based on the argument that the boiler
steam is originating from a potable water source.
Is it acceptable to have a minimum amount of chemicals present in the steam
and air if the levels are within the acceptable ranges published by advisory and
regulatory groups?
If ultra-sonic or spray-type humidification is provided to the space then DI or RO
water systems are typically required to provide the ultra-pure water quality. Is
this considered equal or better water quality since the chlorine has been
removed from the water and microbial growth could potentially be present?
Boiler Steam Treatment Chemicals
Boiler steam/condensate systems are subject to corrosion due to the presence of
carbon dioxide in the condensate pipes coupled with availability of oxygen and high
temperature. CO2 is produced when carbonate and bicarbonate alkalinities in boiler
feedwater thermally decompose in the boiler. The carbon dioxide is carried with the
steam and then dissolves in the condensate to form carbonic acid, which accelerates
corrosion in condensate piping, receivers, and steam traps. If the carbonic acid is not
addressed, corrosion will severally damage the entire condensate system and corrosion
byproducts can be carried back to the boiler causing additional damage. To minimize
condensate system corrosion most central plant boiler systems utilize condensate
corrosion inhibiting chemicals called neutralizing amines. Neutralizing amines are
volatile alkaline compounds that are added to the boiler feedwater. These amines flash
off with the steam and when the steam condenses the amines neutralize the resulting
carbonic acid to prevent corrosion in the condensate system.

The three most common neutralizing amines are cyclohexylamine (CHA), morpholine,
and diethylaminoethanol (DEAE). These chemicals have been associated with upper
respiratory, eye, and skin irritations. Due to this concern the Occupational Safety and
Health Administration (OSHA) and the American Conference of Governmental and
Industrial Hygienist (ACGIH) have established regulatory and advisory limits for these
chemicals. These limits are intended to protect worker safety. These limits are not
necessarily appropriate for non-working building occupants since they are based on the
8-hour day as described below.
OSHA has jurisdiction over worker health and safety and publishes permissible
exposure limits (PELs) of airborne chemicals that protect workers against the health
effects of excessive exposure to hazardous substances. PELs are based on a time
weighted average exposure over an 8-hour day and 40-hour week and are enforceable
by law.8 PELs are listed below and can also be viewed at http://www.osha.gov
ACGIH publishes threshold limit values (TLVs), which are guidelines to assist industrial
hygienists in making decisions regarding safe levels of exposure to various hazards
found in the workspace. TLVs represent the opinion of the scientific community that
exposure at or below each TLV does not create an unreasonable risk of disease or
injury. Since the ACGIH is only an advisory group their recommendations are not
enforceable, but their opinions could be used in legal proceedings. TLV
recommendations are lower than PEL requirements for certain amines as shown below
in the table.
The Food and Drug Administration (FDA) has established maximum levels of amines
allowed in boiler steam that comes in direct contact with food, other than milk and milk
products. Chemical treatment companies often use these values as guidelines for the
maximum concentrations they will allow each chemical to reach if the boiler steam is
currently used for direct injection humidification.
ASHRAE Standard 170 states,
Steam chemical additives used for humidifiers serving health care facilities shall
comply with FDA requirements.2
2
FDA, 1999 US Dept. of Health and Human Services, Food and Drug
Administration in Federal Register 173.310 (April 1999)
The text of the referenced Federal Register is available at
http://www.grokfood.com/regulations/173.310.htm
In our opinion, the wording of Standard 170 is unenforceable, because FDA has no
requirements for steam used for humidification.
The limits established by OSHA and ACGIH have changed over the years due to
additional research on their health effects. The current limits are listed below.

CHEMICAL
CHA
DEAE
Morpholine

OSHA (PELs)8
In Air
10 ppm
10 ppm
20 ppm

ACGIH (TLVs)2,8
In Air
10 ppm
2 ppm
20 ppm

FDA
In Steam
10 ppm
15 ppm
10 ppm

In addition to the established limits for amines described above, amines have an
unpleasant odor that can cause complaints. The odor thresholds for these chemicals
are listed below.
CHEMICAL
Cyclohexylamine (CHA)
DEAE
Morpholine

ODOR THRESHOLD9
0.90 ppm
0.04 ppm
0.14 ppm

We were interested in whether direct-injection of boiler steam containing amines at

various concentrations for humidification would cause the amine levels in air to exceed
the established limits set by OSHA and ACGIH; and whether this would cause
unpleasant odors. Both of these issues should be of concern and addressed in
ASHRAE Standard 62.1. Our analysis is shown below.
ASHRAE and other organizations require or recommend that many buildings including
health-care facilities be humidified to a minimum of 30% relative humidity. It is also
common for equipment manufacturers of diagnostic healthcare equipment to require the
rooms to be above 40% relative humidity. Some states, including Illinois, require
operating rooms to be above 40% relative humidity. If chemicals are added to the boiler
steam as allowed per ASHRAE Standard 170, Ventilation of Health Care Facilities, the
maximum levels in the humidified air can be theoretically calculated. Standard 170
states, Steam chemical additives used for humidifiers serving health care facilities shall
comply with FDA requirements. This is somewhat ambiguous since FDA regulates
boiler steam that contacts food rather than air, but our attempt to calculate this is shown
below for humidification of 100% OA that enters with 0% RH.
Room Air = 73F DB @ 40% RH. Humidity Ratio = .007 lbs moisture per pound dry air
steam
10 lbsCHA
=.070 ppm
( .007lb
)(
1 lb Dry Air 1,000,000 Steam )
.007 lb steam
15lbs DEAE
DEAE ConcentrationAir =(
=.105 ppm
)(
1lb Dry Air 1,000,000 Steam )
.007lb steam 10 lbs Morpholine
Morpholine Concentration Air=(
=.070 ppm
1 lb Dry Air )( 1,000,000 Steam )

CHA Concentration Air=

The calculation above agrees reasonably well with field studies where amine levels
were measured in boiler steam used for humidification and in the room air. Some of the
data is listed below for reference.

Amine

Steam amine
Concentration (ppm)

DEAE

15

Airborne amine
concentration
(ppm)
.01

DEAE

5.33

.0024

CHA

2.93

.008

Morpholine
Morpholine
DEAE
DEAE
CHA
CHA

19.2
64.8
11.6
19.8
30.6
87.7

.004
.018
.010
.031
.041
.066

Study
NIOSH Cornell
University6
Unknown : Chemtex
Literature4
Unknown : Chemtex
Literature4
Nalco Research5
Nalco Research5
Nalco Research5
Nalco Research5
Nalco Research5
Nalco Research5

Based on this theoretical calculation and the field studies we believe that if the amine
levels in steam remain below the FDA recommendations for steam in contact with food
the chemical concentration levels in the humidified air are well below exposure
recommendations by OSHA and ACGIH. However, there is a possibility that the air
could contain a high enough concentration of DEAE that it would exceed the odor
threshold and thus be objectionable to building occupants. Using the same basic
calculation as above we calculated that the maximum concentration of DEAE to remain
below the odor threshold is approximately 5.7 ppm.
Please also note that NIOSH completed a study in 1983 at the Johnson Museum of
Cornell University. NIOSH investigated complaints of skin and eye irritation by
employees. It was determined that the university used a direct-injection steam
humidifier and used DEAE for condensate corrosion prevention. After completing air
quality testing NIOSH determined the concentration of DEAE in the air was at most 0.01
ppm. While this level was orders of magnitude below any recommended maximum
concentrations published by OSHA or ACGIH, they did find DEAE on exposed surfaces.
NIOSH concluded that DEAE condensed out of the air and building occupants touched
the surfaces, thereby causing the skin irritations and complaints. Thus there is a risk of
exposure of amine chemicals to building occupants if the building is not cleaned. In our
research we did not find any other cases where this had caused a complaint, however,
we have provided this study as additional information for your consideration.
Recommendations and Suggested Wording Options
We recommend that the committee clarify Standard 62.1 as it relates to humidifiers, and
that you coordinate the modifications with Standard 170. We also offer the following
wording options for you to consider in place of the wording of Standard 62.1 section
5.13.1. These options are in no particular order other than that the first option is the
most stringent. The later options are not arranged in order of stringency.

Option 1: Water Quality Water entering humidifiers shall originate from one of
the following sources and no chemicals shall be added to the water between the
source and the airstream.
o Potable water
o RO water
o DI water

Option 1 is the most conservative choice, but increases first costs, maintenance costs,
and energy costs.

Option 2: Water Quality Water entering humidifiers shall originate from one of
the following sources.
o Potable water
o RO water
o DI water
Chemicals and minerals shall not be present in the steam in concentrations that
are known to be hazardous to health or that might contribute to an indoor air
quality problem. The specific chemicals listed below may be present in steam,
but they shall not exceed the following concentrations in the steam.
o Cyclohexylamine (CHA) : 10 ppm
o Diethylaminoethanol (DEAE) : 5 ppm
o Morpholine : 10 ppm

Option 2 is based on the lower of the FDA limits and the calculated value to fall below
the odor threshold for DEAE.

Option 3: Water Quality Water entering humidifiers shall originate from one of
the following sources.
o Potable water
o RO water
o DI water
Chemicals and minerals shall not be present in the steam in concentrations that
are known to be hazardous to health or that might contribute to an indoor air
quality problem. The specific chemicals listed below may be present in steam,
but they shall not exceed the following concentrations in the air in any occupied
zone.
o Cyclohexylamine (CHA) : 0.90 ppm
o Diethylaminoethanol (DEAE) : 0.04 ppm
o Morpholine : 0.14 ppm

Option 3 is based on the odor thresholds in air. This is a more direct method than option
2, but is possibly more difficult to measure and would require measurement in many
more locations to monitor.

Option 4: Water Quality Water entering humidifiers shall originate from one of
the following sources.

o Potable water
o RO water
o DI water
Chemicals and minerals shall not be present in the steam in concentrations that
are known to be hazardous to health or that might contribute to an indoor air
quality problem. The specific chemicals listed below may be present in steam,
but they shall not exceed the following concentrations in the steam or in the air in
any occupied zone.
o Cyclohexylamine (CHA) : 10 ppm steam / 0.90 ppm air
o Diethylaminoethanol (DEAE) : 5 ppm steam / 0.04 ppm air
o Morpholine : 10 ppm steam / 0.14 ppm air
Option 4 is based on complying both with the FDA limits and the odor thresholds in air.
Proving compliance would require monitoring both steam and air concentrations.

Option 5: Water Quality Water entering humidifiers shall originate from one of
the following sources.
o Potable water
o RO water
o DI water
Chemicals and minerals shall not be present in the steam in concentrations that
are known to be hazardous to health or that might contribute to an indoor air
quality problem. If chemicals are added their concentration in the steam shall not
exceed the FDAs latest concentration limits for steam that contacts food.

Option 5 is similar to Option 2, except that it ignores the odor threshold for DEAE and it
does not specifically list chemicals and avoids the need to review the FDA requirements
for each new version of Standard 62.1.

Option 6: Water Quality Water entering humidifiers that do not boil the water
shall originate from one of the following sources.
o Potable water
o RO water
o DI water
Steam used for humidification shall not have chemicals or minerals present in
concentrations that are known to be hazardous to health or that might contribute
to an indoor air quality problem. The specific chemicals below may be present in
steam, but they shall not exceed the following concentrations in the steam.
o Cyclohexylamine (CHA) : 10 ppm
o Diethylaminoethanol (DEAE) : 5 ppm
o Morpholine : 10 ppm

Option 6 adds the wording that do not boil the water in its first sentence. This is based
on the premise that the quality of the feedwater to a steam humidifier is irrelevant since
the water entering the air will have been distilled. The only chemicals of concern are
those that volatilize with the steam. The assumption is that there are few of those that

would not be destroyed by the temperature of boiling other than chemicals designed for
that purpose. This wording also would allow the use of site-collected rainwater, which
would be an excellent source of water with low solids content. We avoided the term
steam humidifier because of concern that there could be argument that all humidifiers
technically create steam.
Final thoughts about testing of amine concentrations:
Testing of steam or condensate amine concentrations is probably easier than
testing airborne concentrations, so that has an advantage from the standpoint of
compliance and enforcement. Also, testing of the amine concentrations in steam
is probably part of most facilities existing procedures.
NOTE FOR COMMITTEE:
There is one difference between the version of this proposal that I formally submitted
and the versions in this letter. The difference is in the wording of the acceptable waters
for humidifiers that do not boil water. I believe that the original wording would not have
protected against purified water that was stored long enough to have microorganisms
grow to unacceptable levels, such as in an unprotected RO or DI water tank. To protect
against this I searched for a standard that that set objective criteria to determine
whether water was acceptable and decided that the National Primary Drinking Water
Regulations provided an easily referenced set of criteria that are easily accessible. You
can view them at http://www.epa.gov/safewater/contaminants/index.html#listmcl
REFERENCES:
1. A Guide To Amines In Steam, EHS1007, Garratt Callahan (SEE ATTACHED
PDF)
2. American Conference of Governmental and Occupational Hygienists
http://www.acgih.org/tlv/
3. Amines, TT-015-0891, Chemtex Corporation
http://www.chemtexcorp.com/docarchive/pub/TT-15%20Amines.pdf
4. Are Neutralizing Amines Safe in Steam Humidification Systems?, Volume 18, Fall
2004, Chemtex Corporation http://www.chemtexcorp.com/docarchive/news/Water
%20Treatment%20News%2018-NeutralizingAmines%20in
%20SteamHumidification.pdf
5. Grattan, D., Koutek, M., Russum, S., Amine Levels in Steam Humidified Room
Air. Engineered Systems, 1989
https://www.armstronginternational.com/files/products/humidifiers/pdf/techreports
/aminelevels.pdf
6. HETA 83-020-1351, Cornell University,
http://www.cdc.gov/niosh/hhe/reports/pdfs/1983-0020-1351.pdf
7. Neutralizing Amine Regulation & Testing, TT-031-1098, Chemtex Corporation
http://www.chemtexcorp.com/docarchive/pub/TT-31%20Neutralizing%20Amine
%20Regulation%20and%20Testing.pdf
8. OSHA http://www.osha.gov/
9. Rabinovich, Shulamit, Hospital Steam Humidification Systems and the Chemicals
they Use, HPAC Engineering, May, 2004 (SEE ATTACHED PDF)

10. Regulations Governing Chemical Treatment in Food Processing Plants, TT-01203900, Chemtex Corporation http://www.chemtexcorp.com/docarchive/pub/TT12%20Regulations%20Governing%20Chemical%20Treatment%20in%20Food
%20Processing%20Plants.pdf
11. Steamline Treatment Policy: Humidification, EHS1001, Garratt Callahan (SEE
ATTACHED PDF)
12. Turpin, J., (2001) Direct Steam Injection Humidification: Is It Safe For Building
Occupants?, March, 2001
http://www.esmagazine.com/Articles/Feature_Article/55e590b7ffba8010VgnVCM
100000f932a8c0____