Toward an Evidence-Informed Model Fragrance-Free Policy: An Indoor Air Quality Source-Control Framework for Accessibility and Inclusion

1. Introduction

Indoor air quality (IAQ) is a critical yet frequently overlooked determinant of public health. Fragranced consumer products represent an under-regulated source of indoor air pollution [1]. These products can emit numerous volatile organic compounds (VOCs), some classified as hazardous air pollutants, and exposure to these emissions has been linked to a range of adverse health effects, including headaches, respiratory irritation, migraines, asthma exacerbations, and skin reactions [2,3,4]. Fragranced consumer products disproportionately affect vulnerable populations, including individuals with autism, asthma, and multiple chemical sensitivity (MCS), and in some cases the severity of these effects may be considered disabling [5,6,7,8,9].

From a mechanistic perspective, many VOCs from fragrance products can stimulate Transient Receptor Potential (TRP) ion channels, particularly TRPA1 and TRPV1 in sensory neurons of the airways, skin, and eyes. This activation triggers neurogenic inflammation and irritation responses, providing a biological basis for symptoms such as coughing, airway constriction, burning sensations, and headaches, even at low levels of exposure in susceptible individuals [10,11].

In addition to direct inhalation exposure, fragranced products can contribute to secondary and tertiary exposure pathways, whereby chemicals accumulate on indoor surfaces such as clothing, carpets, furniture, and ventilation systems and may continue to emit VOCs long after the initial source has been removed, contributing to prolonged indoor exposure [1,12]. These exposures can restrict participation in public and social environments, creating barriers to accessibility, and may also impose broader economic costs through increased absenteeism, reduced productivity, and higher healthcare utilization, and in some cases lost workdays or job loss [3,13,14,15]. These impacts may also contribute to presenteeism, whereby individuals remain at work, but experience reduced productivity, concentration, and work performance because of ongoing exposure-related symptoms [16]. Therefore, addressing this concern is not only a matter of environmental health, but also an issue of equity, accessibility, and disability rights.

Despite these impacts, regulatory frameworks addressing fragranced consumers remain inconsistent across jurisdictions. In the absence of comprehensive regulatory frameworks governing fragranced consumer products, institutional policies have emerged as an important strategy for reducing exposure and promoting equitable access to indoor environments for individuals affected by fragrance-related sensitivities [1,3,17]. Increasingly, workplaces, healthcare institutions, and public organizations are adopting such policies as part of broader IAQ and accessibility initiatives intended to protect individuals with MCS and related health conditions. Despite their increasing adoption, fragrance-free policies vary substantially in terminology, scope, enforcement mechanisms, and accommodation provisions. To address these inconsistencies and identify effective policy elements, this study employed a policy synthesis and best-practice framework development approach, translating findings from the policy analysis into an evidence-informed model fragrance-free policy.

Fragrance-free policies are most effective when conceptualized as IAQ source-control policies grounded in accessibility. Accessible indoor environments require the elimination and substitution of airborne and other chemical emission sources within institutional control, alongside the prioritization of least-toxic ecological solutions for operational, maintenance, and environmental management needs. This model framework therefore advances an integrated IAQ-based policy approach that incorporates fragrance-free standards within a comprehensive environmental control system. The framework is designed to operate as a unified structure; selective restriction of certain emission sources (e.g., personal fragrances) while permitting others (e.g., fragranced cleaning products, combustion-related smoke, pesticide use, or chemical maintenance practices) undermines policy coherence and compromises accessible indoor air conditions. Effective implementation requires consistent application of source-control principles across all relevant emission categories within institutional environments.

2. Materials and Methods

The resulting model framework was structured to be adaptable across institutional sectors, including healthcare, education, government, and public-facing environments, and grounded in IAQ source-control and accessibility principles.

The development of the model fragrance-free policy framework was informed by the scoping review conducted in Paper 2 [18]. Analysis of the extracted elements revealed systematic gaps in existing policies, which informed the identification of best-practice components incorporated into the proposed model framework. The synthesis aimed to identify policy elements associated with clarity, enforceability, accessibility, and feasibility, and integrate these elements into a structured model policy framework. This approach supports the framing of fragrance exposure as an environmental health issue rather than a matter of personal preference. Implementation feasibility was assessed based on principles commonly used in implementation science, including policy clarity, monitoring mechanisms, and organizational capacity for enforcement. These considerations are critical for translating policy recommendations into practical institutional practices. The discussion is intended to support institutions, employers, health authorities, and policymakers seeking to develop policies that protect health while promoting accessibility and inclusion.

3. Best Practices Identified Across Sectors

Table 1. Best Practices.

Key Policy Elements	Best Practice	Rationale
Definitions	Clearly define fragrance-free, scent-free, unscented, fragranced products, lowest emission products, and IAQ objectives.	Clear terminology reduces confusion and improves policy implementation.
Scope	Apply the policy to all organizational spaces (the entire building structure and grounds), activities, occupants, contractors, visitors, students, patients, service users, temporary facilities, leased spaces, vehicles used for work purposes, and organization-sponsored events.	Ensures consistent indoor and outdoor environmental standards.
Institutional responsibility	Assign responsibility to HR, OHS, facilities management, and accessibility offices	Establishes accountability.
Communication	Use signage, websites, appointment reminders, registration materials, phone messaging, onboarding, and educational resources	Improves awareness and compliance.
Education and Training	Provide mandatory onboarding and periodic education regarding indoor air quality, fragrance exposure, accessibility, accommodation procedures, and policy requirements.	Improves awareness, compliance, and implementation consistency.
Product Restrictions	Clearly identify prohibited products and explain greenwashing risks	Supports compliance and informed product selection.
Source Control	Eliminate fragrance-emitting and other chemical emission sources and prioritize substitution with lowest-emission, least-toxic alternatives	Most effective method for reducing exposure.
Procurement and Purchasing	Require fragrance-free, lowest-emission, least-toxic products and consider independent environmental certifications	Prevents pollutant introduction at source.
Smoke and Combustion Sources	Prohibit indoor smoke-generating activities and prevent migration of smoke and combustion by-products into occupied spaces	Maintains accessible indoor air conditions.
Third-Hand Exposure Control	Address contamination on surfaces, textiles, furnishings, ventilation systems, and shared environments	Eliminate persistent exposure.
Institution and Workplace Protocols	Incorporate policy requirements into contracts, onboarding, workplace procedures, facility management, and operational practices	Embeds policy into organizational systems.
Recruitment and Employment Processes	Inform applicants of policy requirements and provide mechanisms for requesting accessibility supports	Reduces barriers to employment.
Public-Facing Service Delivery	Integrate policy information into appointments, event registrations, visitor communications, and public-facing websites	Supports accessibility before arrival.
Engineering Controls	Maintain ventilation systems; ensure adequate air exchange and filtration consistent with current evidence-based building ventilation standards; monitor and manage moisture and water intrusion; regularly replace filters; use fragrance-free, least-toxic practices for duct maintenance; avoid chemical treatments within ventilation systems; and locate outdoor air intakes away from pollutant sources.	Supports reduction of indoor pollutant accumulation and prevents introduction of contaminants through building systems.
Accommodation	Provide clear and accessible accommodation pathways while prioritizing source control and accessible indoor environments	Supports participation and accessibility.
Enforcement	Establish progressive compliance and institutional enforcement procedures	Promotes consistent policy implementation.
Complaint Reporting and Non-Retaliation	Provide confidential or anonymous reporting mechanisms and protect individuals from retaliation	Strengthens accountability.
Monitoring and Evaluation	Review complaints, accommodation trends, survey results, and IAQ indicators.	Assesses policy effectiveness.
Policy Review and Continuous Improvement	Conduct periodic reviews and incorporate new evidence and stakeholder feedback	Maintains policy relevance and effectiveness.

Table 1. Best Practices.

Key Policy Elements	Best Practice	Rationale
Definitions	Clearly define fragrance-free, scent-free, unscented, fragranced products, lowest emission products, and IAQ objectives.	Clear terminology reduces confusion and improves policy implementation.
Scope	Apply the policy to all organizational spaces (the entire building structure and grounds), activities, occupants, contractors, visitors, students, patients, service users, temporary facilities, leased spaces, vehicles used for work purposes, and organization-sponsored events.	Ensures consistent indoor and outdoor environmental standards.
Institutional responsibility	Assign responsibility to HR, OHS, facilities management, and accessibility offices	Establishes accountability.
Communication	Use signage, websites, appointment reminders, registration materials, phone messaging, onboarding, and educational resources	Improves awareness and compliance.
Education and Training	Provide mandatory onboarding and periodic education regarding indoor air quality, fragrance exposure, accessibility, accommodation procedures, and policy requirements.	Improves awareness, compliance, and implementation consistency.
Product Restrictions	Clearly identify prohibited products and explain greenwashing risks	Supports compliance and informed product selection.
Source Control	Eliminate fragrance-emitting and other chemical emission sources and prioritize substitution with lowest-emission, least-toxic alternatives	Most effective method for reducing exposure.
Procurement and Purchasing	Require fragrance-free, lowest-emission, least-toxic products and consider independent environmental certifications	Prevents pollutant introduction at source.
Smoke and Combustion Sources	Prohibit indoor smoke-generating activities and prevent migration of smoke and combustion by-products into occupied spaces	Maintains accessible indoor air conditions.
Third-Hand Exposure Control	Address contamination on surfaces, textiles, furnishings, ventilation systems, and shared environments	Eliminate persistent exposure.
Institution and Workplace Protocols	Incorporate policy requirements into contracts, onboarding, workplace procedures, facility management, and operational practices	Embeds policy into organizational systems.
Recruitment and Employment Processes	Inform applicants of policy requirements and provide mechanisms for requesting accessibility supports	Reduces barriers to employment.
Public-Facing Service Delivery	Integrate policy information into appointments, event registrations, visitor communications, and public-facing websites	Supports accessibility before arrival.
Engineering Controls	Maintain ventilation systems; ensure adequate air exchange and filtration consistent with current evidence-based building ventilation standards; monitor and manage moisture and water intrusion; regularly replace filters; use fragrance-free, least-toxic practices for duct maintenance; avoid chemical treatments within ventilation systems; and locate outdoor air intakes away from pollutant sources.	Supports reduction of indoor pollutant accumulation and prevents introduction of contaminants through building systems.
Accommodation	Provide clear and accessible accommodation pathways while prioritizing source control and accessible indoor environments	Supports participation and accessibility.
Enforcement	Establish progressive compliance and institutional enforcement procedures	Promotes consistent policy implementation.
Complaint Reporting and Non-Retaliation	Provide confidential or anonymous reporting mechanisms and protect individuals from retaliation	Strengthens accountability.
Monitoring and Evaluation	Review complaints, accommodation trends, survey results, and IAQ indicators.	Assesses policy effectiveness.
Policy Review and Continuous Improvement	Conduct periodic reviews and incorporate new evidence and stakeholder feedback	Maintains policy relevance and effectiveness.

4. Translating Findings into the Policy Framework

4.1. Clear Terminology and Definitions

Many policies lacked clear definitions of fragrance-related exposures and often used the term “scent-free” without clarifying whether these included products labeled as unscented or products containing fragrance masking agents. Ambiguous terminology may create confusion regarding compliance expectations and product restrictions. Therefore, the model policy includes explicit definitions for fragranced products, fragrance-free, unscented, lowest-emission materials, and IAQ objectives.

4.2. Expanded Scope of Indoor Pollutant Sources

The scoping review identified that many policies focused narrowly on perfumes and personal fragrances, overlooking other fragrance sources such as cleaning products, laundry detergents, building materials, and air fresheners [18]. While fragrance compounds are important sources of VOC emissions in indoor environments, not all VOCs are fragranced or detectable by smell [14]. Indoor pollutant sources may include fragranced and non-fragranced products, building materials, maintenance activities, combustion-related emissions, and other environmental contaminants. Accordingly, the objective of the model framework is to identify and address indoor pollutant sources through source control rather than focus exclusively on fragrance emissions. Narrow policy scope may fail to address major sources of indoor chemical exposure. Findings from IAQ research further suggest that products marketed as fragrance-free, unscented, natural, or eco-friendly may still emit substantial quantities of VOCs. Certain compounds commonly associated with “green” products, including terpenes such as limonene and alpha-pinene, may contribute to indoor pollutant loads and participate in chemical reactions that generate secondary pollutants. Consequently, product selection should prioritize verified lowest-emission and least-toxic characteristics rather than fragrance claims, environmental marketing terms, or product category alone [19]. The model policy therefore emphasizes source control across multiple pollutant categories, including fragranced personal care products, cleaning products, laundry products, air fresheners and diffusers, building materials and furnishings.

4.3. Addressing Third-Hand Scent Contamination

Existing policies rarely address the persistence of fragrance-related chemicals within indoor environments. However, fragrance compounds and other semi-volatile organic compounds may accumulate on indoor surfaces, including clothing, furniture, furnishings, carpets, and ventilation systems, and subsequently re-emit into the air over time. This residual contamination can prolong exposure even after fragrance sources are removed. Failure to account for such environmental persistence undermines policy effectiveness and may contribute to continued accessibility barriers despite nominal fragrance restrictions.

The model framework therefore incorporates strategies to address both primary emission sources and residual contamination pathways. These include procurement controls, laundering expectations, surface management practices, ventilation maintenance, and clear restrictions on combustion-related activities that may contribute to particulate deposition and re-emission. By recognizing third-hand contamination as an ongoing IAQ management issue rather than an isolated event, the framework strengthens source-control integrity and supports sustained accessible indoor air conditions.

4.4. Engineering Controls and Ventilation Management

The scoping review identified limited discussion of ventilation system management within existing fragrance-free policies [18]. While ventilation can support dilution and removal of indoor contaminants, it cannot compensate for ongoing introduction of pollutant sources. Effective fragrance-free policies therefore require integration of engineering controls with source-control strategies.

Ventilation systems should be maintained to support IAQ through adequate outdoor air exchange, filtration, routine inspection, and filter replacement. Filtration systems should be selected according to the contaminants of concern, recognizing that conventional filtration may not effectively remove VOCs and other gaseous contaminants. HEPA filters are highly effective for removing airborne particulate matter but do not remove gaseous contaminants. Removal of volatile organic compounds (VOCs) and other chemical gases generally requires sorbent media such as activated carbon or other specialized adsorbents. Ventilation management should be consistent with recognized standards and guidance, including current ASHRAE recommendations, while recognizing that source control remains the primary strategy for reducing indoor contaminant exposure.

Moisture management is also an important component of indoor air quality. Organizations should implement measures to identify and address water intrusion, condensation, leaks, and other conditions that may contribute to mould growth. Early detection and timely remediation help prevent deterioration of indoor environmental quality and prevent ongoing exposure to mould-related contaminants.

Outdoor air intakes should be located away from pollutant sources such as vehicle idling areas, loading zones, waste storage areas, combustion sources, and smoking areas. Ventilation systems themselves should not become sources of contamination. Accordingly, duct cleaning and maintenance activities should utilize fragrance-free, lowest-emission, and least-toxic practices, and the use of fragrances, deodorizers, biocides, pesticides, and other chemical treatments shall not be used within ventilation systems.

These measures support accessible indoor air conditions by reducing pollutant accumulation while preventing the introduction or recirculation of contaminants through building systems.

4.5. Institutional Responsibility and Compliance Mechanisms

A common feature of existing policies was reliance on voluntary compliance without clearly defined institutional responsibility. The model framework assigns responsibility to institutional actors such as Occupational Health and Safety (OHS) departments, HR units, and accessibility offices.

4.6. Accessibility and Accommodation Procedures

Accommodation pathways were frequently unclear, burdensome, or dependent on extensive medical documentation. Procedural barriers may limit accessibility for individuals with MCS. The model policy integrates accessibility principles by recognizing fragrance exposure and poor indoor air quality as potential accessibility barriers, emphasizing barrier removal and participation, and establishing clear accessible pathways that do not create unnecessary administrative or procedural burdens.

4.7. Monitoring and Evaluation

Monitoring and evaluation mechanisms were rarely included. Lack of monitoring makes it difficult to assess policy effectiveness. The model policy therefore incorporates monitoring strategies such as confidential complaint reporting systems and periodic policy review.

5. Conceptual Framework for Evidence-Informed Fragrance-Free Policy Development

Effective fragrance-free policy implementation requires more than isolated product restrictions. It requires integration within a structured IAQ governance framework grounded in accessibility and source control. The proposed model conceptualizes fragrance-free policy as a layered environmental control system, linking foundational principles, policy design elements, operational implementation strategies, and measurable outcomes.

I.

Foundational Principles

• Accessibility and barrier prevention
• Public health ethics and primary prevention
• IAQ source-control and hierarchy-of-controls principles
• Precautionary environmental governance

These principles position fragrance-related exposure not as a matter of personal preference, but as an environmental condition requiring structured management to maintain accessible indoor air.

II.

Policy Design

• Clear and standardized definitions
• Comprehensive policy scope
• Explicit identification of emission sources
• Integrated fragrance-free and ecological procurement standards
• Defined institutional responsibility
• Enforcement and accountability mechanisms
• Monitoring and evaluation procedures

Policy coherence requires that these elements function as an integrated system rather than isolated provisions.

III.

Implementation Strategies

• Institutional accountability across departments
• Education and training programs
• Institutional accountability
• Transparent communication & signage
• Procurement controls and contractor compliance
• Environmental management and ventilation practices

Implementation must prioritize elimination and substitution of emission sources over reliance on voluntary behavioral compliance.

IV.

Expected Outcomes

• Reduced airborne and residual chemical exposure
• Improved accessibility for individuals with MCS and related conditions
• Greater consistency in institutional IAQ governance
• Strengthened alignment between accessibility commitments and environmental health evidence
• Reduced absenteeism and presenteeism associated with preventable indoor environmental exposures
• Improved workforce participation, productivity, and employee well-being

6. Model Fragrance-Free Policy

The policy synthesis identified several key domains required for effective IAQ source-control policies incorporating fragrance-free standards, which form the basis of the model fragrance-free policy framework.

6.1. Policy Statement

(Organization Name) is committed to maintaining a safe, accessible, and inclusive indoor environment. Individuals with MCS, and others who may be adversely affected by airborne, particulate, and residual chemical contaminants, may experience significant physiological reactions to these exposures, which can adversely affect health and access to services, workplaces, educational settings, healthcare facilities, and public spaces.

To support accessibility, occupational health, and environmental protection, (Organization Name) establishes this “Fragrance-Free Policy”. The goal of this policy is to identify and address indoor sources of airborne, particulate, and residual chemical contaminants through source control and to support equitable access to services, workplaces and other shared indoor environments.

6.2. Purpose

Fragranced products emit VOCs that activate TRP ion channels, triggering inflammation, bronchoconstriction, neurological symptoms, and irritation. For individuals with MCS, these effects can be severe and disabling, making fragrance exposure an accessibility issue rather than a preference.

This policy aims to protect IAQ in all organizational environments by reducing environmental contamination associated with fragranced consumer products and preventing health reactions caused by fragrance chemicals and VOCs. Additionally, it will promote inclusive environments where individuals with fragrance-triggered disabilities can safely access services and employment.

6.3. Scope

This policy applies to all employees, staff, students, volunteers, visitors, clients, contractors, vendors, service providers, and third-party personnel operating within spaces under the control of the organization.

It applies to all indoor environments and enclosed spaces under operational contexts under institutional authority, including offices, healthcare facilities, educational institutions, public service areas, shared workspaces, meeting rooms, waiting areas, vehicles used for work purposes, and temporary or event-based indoor settings.

The policy extends to all activities, procurement decisions, contracted services, facility management operations, maintenance practices, and environmental management systems capable of influencing indoor air quality. Where buildings share ventilation systems, air circulation pathways, or adjacent indoor environments, the organization shall take reasonable measures within its authority to prevent transfer of airborne contaminants into spaces covered by this policy.

The policy applies to all emission sources introduced or managed through institutional control, including but not limited to cleaning services, building renovations, pest management, landscaping practices, furnishings, and operational supplies.

6.4. Definitions

• Model Fragrance-Free Policy: An institutional indoor air quality (IAQ) source-control policy that eliminates and substitutes fragrance-emitting substances and other airborne chemical, particulate, and combustion-related emission sources within institutional control to maintain accessible indoor air conditions. Such sources may include, but are not limited to, fragranced products, cleaning agents, pesticides, smoke, combustion by-products, incense, candles, and other contaminants capable of affecting indoor air quality or accessibility.
• Fragrance: Chemical mixtures used to produce scent in consumer products. These may be synthetic or derived from natural sources. Fragranced consumer products are recognized sources of VOCs and other airborne chemicals that may contribute to indoor air pollution and trigger adverse health effects in susceptible individuals. Fragrance chemicals are commonly found in:

  ✔

  Perfumes and colognes

  ✔

  Laundry detergents and fabric softeners

  ✔

  Cleaning products and disinfectants

  ✔

  Air fresheners and diffusers

  ✔

  Scented candles

  ✔

  Essential oils

  ✔

  Deodorants and body sprays

  ✔

  Lotions and cosmetics

  ✔

  Shampoos, conditioners, and other hair products

  ✔

  Soap and shower gel

Other potential sources may include fragranced building materials, treated textiles such as curtains or carpets, and items contaminated through shared laundry facilities.

• Fragrance-Free Environment: An indoor space in which fragrance-emitting substances and other chemical emission sources are eliminated or substituted in order to prevent both direct airborne exposure and residual contamination that may re-emit into the air over time.
• Unscented: Products may still contain fragrance chemicals and masking agents used to mask odors and capable of triggering reactions.
• Second-hand Fragrance Exposure: Exposure occurring when individuals inhale airborne chemicals emitted from fragranced products worn or used by others within shared indoor environments.
• Third-hand Fragrance Exposure: Residual chemical contamination that persists on indoor surfaces, clothing, furnishings, ventilation systems, and other materials following fragrance or chemical use. These residues may continue to off-gas or re-emit volatile compounds over time, contributing to ongoing indoor exposure even after the original source has been removed.

6.5. Policy Requirements

To maintain accessible indoor air conditions, all indoor environments under the control of (Organization Name) shall eliminate and substitute fragrance-emitting substances and other chemical and combustion-related emission sources.

This policy applies to primary emission sources, residual contamination pathways, and operational practices that may contribute to indoor chemical exposure.

• Personal Fragrance Products: Individuals must be fragrance-free when entering and occupying organizational spaces. This requirement applies to all personal care products that emit volatile and semi-volatile fragrance-related compounds, including but not limited to perfumes, colognes, body sprays, scented lotions, scented deodorants, fragranced hair products, scented cosmetics, and essential oils applied to the body. These emissions may trigger acute or delayed health reactions and compromise accessible indoor air conditions.
• Laundry Products: Clothing worn within organizational spaces must be laundered using fragrance-free detergents and must not contain residual fragrance from scented laundry products. This includes, but is not limited to, scented detergents, fabric softeners, dryer sheets, and scent boosters. Fragrance residues deposited on textiles may off-gas volatile and semi-volatile compounds over time, contributing to second-hand and third-hand exposure within shared indoor environments and compromising indoor air conditions.
• Indoor Products and Materials: All indoor products, materials, and operational practices under organizational control must align with fragrance-free, lowest-emission, and least-toxic ecological standards to maintain accessible indoor air conditions. This requirement applies to products and materials that may emit volatile or semi-volatile compounds into shared indoor environments, including but not limited to air fresheners, automatic fragrance dispensers, plug-in fragrance devices, diffusers, essential oil vaporizers, incense, scented candles, fragranced cleaning agents, scented washroom products, treated furnishings, fragranced or treated paper products, and other indoor products or devices capable of emitting volatile or semi-volatile compounds.
• Combustion and Smoke-Producing Sources: Activities, products, and practices that generate smoke, combustion by-products, or other airborne emissions capable of affecting indoor air quality shall not be permitted within indoor environments covered by this policy. This includes, but is not limited to, tobacco products, cannabis products, incense, scented or unscented candles, smoke-generating devices, and other combustion-related activities.
• Cleaning and Maintenance Products: All cleaning, maintenance, pest management, and outdoor groundskeeping activities under organizational control must adhere to fragrance-free, lowest-emission, and least-toxic ecological standards in order to maintain accessible indoor air conditions. Product selection and operational practices shall prioritize elimination and substitution of chemical emission sources over masking, dilution, or reactive remediation approaches.

This requirement applies to cleaning agents, disinfectants, hand sanitizers, soaps, surface treatments, pesticides, herbicides, deodorizers, aerosolized products and any chemical applications capable of contributing to indoor air contamination. Integrated ecological pest management and lowest-emission landscaping practices shall be used to minimize chemical transfer into shared indoor environments.

• Building Materials and Furnishings: All building materials, furnishings, renovation practices, and capital improvement activities under organizational control must prioritize lowest-emission, fragrance-free, and least-toxic ecological standards to prevent the introduction of airborne and surface-bound chemical contaminants into indoor environments. Selection decisions shall favor materials with verified lowest-VOC emissions and transparent third-party environmental certification.

This requirement applies to paints, adhesives, sealants, flooring systems, composite wood products, carpeting, treated textiles, insulation materials, furniture, and other installed materials capable of off-gassing volatile or semi-volatile compounds. Renovation and construction activities must be managed to prevent chemical migration into occupied spaces through ventilation systems or shared pathways.

Where new materials are introduced, the organization shall implement appropriate ventilation management, off-gassing mitigation, and occupancy controls to maintain accessible indoor air conditions during and after installation.

Moisture management is an important component of maintaining accessible indoor air conditions. Buildings shall be monitored for signs of moisture intrusion, water damage, or mould growth. Where such conditions are identified, prompt investigation and remediation shall be undertaken using practices that minimize occupant exposure and maintain accessible indoor air conditions.

6.6. Product Selection and Procurement

Product selection plays a critical role in maintaining accessible indoor air conditions. Organizations shall prioritize independently certified fragrance-free, lowest-emission, and least-toxic products wherever feasible and shall not rely solely on marketing claims such as “green,” “natural,” or “eco-friendly” when evaluating products.

Procurement decisions should incorporate review of available ingredient information, emissions characteristics, and credible third-party environmental certifications. Where available, preference should be given to products certified by recognized independent environmental certification programs that assess emissions, ingredient transparency, and human health considerations.

Where accommodations are required, organizations should consider input from affected individuals during product selection whenever feasible, recognizing that incomplete ingredient disclosure and individual variability may influence product suitability.

6.7. Recruitment and Employment Processes

Recruitment and employment processes shall be conducted in a manner consistent with this policy and the organization’s accessibility obligations.

Job postings, recruitment materials, and interview communications should inform applicants that the organization maintains a fragrance-free indoor air quality policy. Interview invitations shall include information regarding fragrance-free expectations and provide a contact mechanism for requesting accommodations related to indoor air quality, fragrance exposure, chemical exposure, or MCS-related accessibility needs.

Where feasible, organizations should offer remote or virtual interview options to reduce barriers associated with fragrance and chemical exposures. Interview rooms and assessment environments shall comply with policy requirements and avoid recent use of fragranced products, air fresheners, or other avoidable emission sources.

Employees shall receive information regarding the organization’s indoor air quality and fragrance-free policy during onboarding to ensure awareness of expectations and responsibilities prior to commencing work.

6.8. Accessibility and Disability Accommodation

The primary objective of this policy is to maintain accessible indoor air conditions through source control and environmental management. Individual accommodation measures may be required where barriers remain despite implementation of policy requirements.

Fragrance exposure can trigger serious health reactions for individuals with disabilities. Therefore, this policy supports accommodations for individuals affected by indoor air contaminants. Possible accommodations include:

✔

Providing fragrance-free workspaces

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Relocating exposure sources

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Scheduling activities during low occupancy periods

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Notifying individuals in advance of activities that may generate airborne pollutants, such as painting, construction, renovation, maintenance, pest management, landscaping, or greenspace management activities. These activities shall prioritize fragrance-free, lowest-emission, least-toxic ecological products and practices. Where accessibility concerns have been identified, product and practice selection should incorporate input from affected individuals to support accessible indoor air conditions.

✔

Offering services outdoors or in well-ventilated areas when appropriate

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Allowing individuals to wait in separate areas to prevent exposure

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Enabling remote or virtual participation where requested by the individual or where temporary environmental conditions prevent maintenance of accessible indoor air conditions

It is important that accommodation policies and processes already in place must align, and be integrated effectively, with this policy.

Organizations should prioritize maintaining accessible indoor environments that support full participation in workplace, educational, healthcare, and community settings. Remote participation should not be regarded as a substitute for accessible indoor environments and should not result in reduced opportunities for inclusion, advancement, professional development, or participation in organizational activities.

6.9. Policy Implementation

• Communication: The organization will communicate this policy through signage posted at building entrances clearly stating “This is a Clean Indoor Air Environment. Fragranced products are not permitted inside this facility.”

The policy will also be communicated through website notices, appointment reminders, email signatures, and public communication materials. Educational resources will be provided on how to transition to fragrance-free products. Organizations that provide public services, healthcare, education, or community programming shall incorporate fragrance-free information into appointment confirmations, event registration materials, visitor communications, and public-facing websites. Communication materials should clearly explain the purpose of the policy, products and practices covered by the policy, and how individuals may request accommodations or obtain additional information.

• Employee Training: To address common misconceptions and support consistent implementation, all employees shall receive training on the sources and health impacts of fragrance exposure, accessibility obligations, indoor air quality principles, accommodation procedures, and policy compliance requirements. Training shall be incorporated into employee onboarding and provided periodically thereafter. Contractors, vendors, volunteers, and other individuals whose activities may affect indoor air quality should receive policy information appropriate to their role.

6.10. Monitoring and Enforcement

Individuals with fragrance-related disabilities must not be responsible for enforcing the policy themselves. Instead, responsibility for enforcing the policy will rest with the management, HR, and OHS staff.

If a person enters the facility wearing fragranced products, staff may remind the individual of the policy and provide information on fragrance-free requirements. When needed, staff may offer alternative arrangements such as rescheduling or a virtual meeting. If the individual is unable to comply, they may be asked to leave and return fragrance-free.

Employees who repeatedly fail to comply with the policy may be subject to progressive disciplinary measures. Policy effectiveness surveys may be conducted anonymously.

6.11. Emergency Response

If an individual experiences a reaction to fragrance exposure, the following steps should be taken:

✔

Move the affected individual to fresh air

✔

Increase ventilation if possible

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Remove the exposure source

✔

Facilitate medical assistance if necessary

6.12. Accessibility and Environmental Standards

Accessible indoor air is a component of an accessible built environment. This policy establishes environmental standards designed to prevent exposure to airborne, particulate, and residual chemical contaminants that may create barriers to participation for individuals with MCS and others adversely affected by such exposures.

Concerns regarding implementation shall be addressed through established accessibility, occupational health, and complaint resolution procedures. Policy implementation shall prioritize maintaining accessible indoor air conditions through source control, environmental management, education, communication, and institutional accountability.

6.13. Complaints and Reporting

Employees, visitors, students, contractors, and service users may report indoor air quality concerns, fragrance-related exposures, accommodation issues, or policy violations through HR, OHS, accessibility offices, or the organization’s anonymous reporting system.

Anonymous reporting mechanisms should be available to address barriers associated with stigma, fear of retaliation, or concerns regarding disclosure. Individuals reporting concerns shall be protected from retaliation, discrimination, or adverse consequences associated with raising indoor air quality or accessibility concerns.

All reports shall be reviewed promptly and addressed through appropriate investigation, corrective action, or accommodation processes.

6.14. Policy Evaluation

To evaluate the effectiveness of this policy, the organization will monitor indicators such as the number of complaints, accommodation requests, and employee feedback collected through surveys and IAQ data where available. Surveys may be conducted anonymously to encourage candid feedback regarding policy effectiveness, implementation challenges, and opportunities for improvement.

A two-year review period will allow sufficient time to evaluate the policy’s effectiveness, monitor compliance, and incorporate feedback or new evidence while ensuring the policy remains current and relevant. This policy will be reviewed to ensure alignment with occupational health standards, accessibility obligations, and IAQ best practices.

6.15. Operational Considerations and Environmental Constraints

While this policy aims to prevent fragrance-related and other airborne chemical exposures through source control in indoor environments, certain structural conditions may affect full exposure control. For example, shared ventilation systems, legacy building materials, external pollution infiltration, and previously installed fragranced materials may contribute to background exposure levels despite institutional mitigation efforts. These constraints do not diminish the organization’s responsibility to implement source control measures within its operational authority, including procurement standards and contractor compliance requirements. Outdoor sources of airborne contaminants, including wildfire smoke and nearby combustion activities, may affect indoor air quality and should be considered in building operation and ventilation management practices.

Activities that generate smoke, combustion by-products, airborne particles, or other contaminants shall be managed in a manner that maintains accessible indoor air conditions. Contaminants must not enter occupied indoor environments through air intakes, windows, doors, ventilation systems, shared air pathways, or other routes of migration capable of affecting indoor air quality or accessibility.

Indoor environmental conditions associated with moisture intrusion, water damage, or mould growth may also affect accessibility and indoor air quality and should be managed proactively through monitoring, maintenance, and timely remediation.

7. Implications

The proposed model policy advances fragrance-free governance from awareness-based guidance toward structured IAQ source-control implementation. Unlike many existing institutional policies that rely primarily on signage or voluntary behavioral compliance, this framework embeds fragrance-free standards within a comprehensive environmental management system grounded in accessibility and primary prevention.

By integrating procurement controls, contractor compliance, ventilation management, monitoring mechanisms, and ecological operational standards, the model addresses implementation gaps identified in the scoping review. This approach reduces variability in interpretation and enforcement and strengthens institutional accountability for maintaining accessible indoor air conditions.

Beyond accessibility and health benefits, effective implementation of fragrance-free source-control policies may reduce absenteeism, presenteeism, and productivity losses associated with preventable indoor environmental exposures. By minimizing exposure-related symptoms and reducing barriers to participation, organizations may also benefit from improved workforce retention, attendance, and employee well-being.

The framework is designed to be adaptable across institutional sectors, including healthcare, education, government, and public-facing environments. Its integrated structure allows organizations to apply consistent environmental control principles across diverse operational contexts without fragmenting emission categories or relying on reactive accommodation processes.

Recent policy developments further illustrate the growing recognition of fragrance-related exposures as a public health, accessibility, and occupational health issue. For example, in 2026, the Canadian Medical Association (CMA) adopted a policy endorsing the American Medical Association's fragrance regulation resolution (H-135.902), reflecting increasing professional and institutional attention to fragrance-related health impacts and the need for exposure-reduction strategies within healthcare and public settings [20].

Adoption of this model may support alignment between accessibility commitments, occupational health standards, and indoor air quality best practices. Future research should evaluate implementation fidelity and assess whether structured source-control policies produce measurable improvements in indoor air quality and accessibility outcomes.

8. Conclusion

Fragrance-free policies must be understood as structured IAQ source-control interventions rather than voluntary courtesy measures. When implemented as integrated environmental governance frameworks, such policies function as accessibility infrastructure by preventing airborne and residual chemical exposures that restrict participation for individuals with MCS and other conditions.

The model presented in this paper advances fragrance-free standards within a comprehensive IAQ framework that prioritizes elimination and substitution of emission sources, ecological procurement practices, ventilation management, institutional accountability, and monitoring mechanisms. This integrated approach addresses the fragmentation and variability observed in existing policies and strengthens alignment between accessibility obligations and environmental health evidence.

Maintaining accessible indoor air requires consistent application of source-control principles across all relevant emission categories under institutional control. Without structured implementation and environmental management, fragrance-free policies risk remaining symbolic rather than functional. Embedding fragrance-free standards within broader IAQ governance systems provides a practical pathway for institutions to operationalize accessibility in measurable and sustainable ways.