Chapter 4
Providing a Safe Environment for Learning

To identify environmental- and safety-related topics that demand an education organization's undivided attention

• Ensuring Environmental Safety
• The "Four Horsemen" of School Facilities Maintenance
  • Indoor Air Quality
  • Asbestos
  • Water Management
  • Waste Management
• Other Major Safety Concerns
• Environmentally Friendly Schools
• Securing School Facilities
• Commonly Asked Questions
• Additional Resources
• Environmental Safety Checklist

The first step in complying with environmental regulations is to become aware of their existence, intent, applicability, and requirements. Most of this information is available from regulatory agencies, professional associations, and on-the-job training. Getting this information may not always be expensive, but it does demand considerable expertise, either hired or developed. In any case, compliance with environmental safety rules pays off relative to the alternative-the possible occurrence of significant indoor air problems, underground storage tank leaks, contaminated drinking water, or other serious environment-related safety or health incidents.

IAQ encompasses almost anything and everything that affects the air in a building, including radon gas, paint odors, mold, construction dust, asbestos, and stack emissions. Moreover, as allergens and irritants (such as perfumes and hair sprays) proliferate, school district maintenance staff must become knowledgeable about these issues as well. One of the best resources available is the "Indoor Air Quality (IAQ) Tools for Schools" action kit developed by the U.S. Environmental Protection Agency (http://www.epa.gov/iaq/schools/), which provides investigative checklists and hints for problem solving, as well as additional resources for guiding efforts to assess and improve indoor air quality.
 

Poor indoor air quality can affect student and teacher performance by causing eye, nose, and throat irritation, fatigue, headache, nausea, sinus problems, and other minor or serious illnesses. Thus, steps must be taken to ensure that IAQ causes neither actual nor perceived illness in facility occupants. Reasonable actions might include the following recommendations, although official standards may vary from state to state and locality to locality:

		Ventilate occupied areas at a minimum rate of 15 cubic feet per minute (cfm).
		Maintain indoor carbon dioxide (CO2) between 800 and 1,000 parts per million (ppm).
		Install both fresh air supply and exhaust ventilation systems in occupied areas.
		Avoid recirculating previously exhausted contaminants when ventilating.
		Ensure adequate make-up air in boilers to minimize backfires and carbon monoxide (CO) contamination.
		Maintain indoor air relative humidity below 70 percent.
		Maintain indoor air temperature at comfortable levels (68-72°F when the room is being heated and 70-78°F when the room is being cooled).
		Inspect for water damage and eliminate standing water and elevated humidity.
		Clean, dry, or remove water-damaged materials within 72 hours of wetting.
		Change filters and clean drip pans according to manufacturer's instructions. (Filters in high-pollution areas may require more frequent service.)
		Seal construction/renovation from occupied areas to minimize air exchange.
		Minimize use of volatile chemicals (in cleaning agents and pesticides), especially while the building is occupied.
		Replace toxic and noxious chemicals with less harmful products as available.
		Store toxic and noxious supplies in areas with adequate exhaust systems.
		Situate vehicle-idling areas away from occupied buildings and ventilation inlets.
		Dispose of used cleaning supplies and water-damaged materials immediately and properly (double-bagged in 6-mil polyethylene plastic).
		Balance all HVAC, air handling, and ventilation systems every five years.
		Periodically test air samples for CO2 (a sign of poor ventilation), CO (a sign of incomplete combustion), relative humidity (a sign of leaks and moisture problems), and air temperature.
		Sample for microbial growth (e.g., mold) when an IAQ problem is suspected.

Most districts that find themselves with IAQ troubles get into this predicament because they fail to respond to warning signs. Many IAQ issues may not be preventable, but can be "fixed" when monitoring, well-trained staff, and adequate resources allow the problem to be identified and addressed in a timely manner.

Indoor air always starts as one thing-outdoor air. Unfortunately, outdoor air may itself be of poor quality. Today's requirements for fresh-air exchange in schools mean that any impurities in the outdoor air will be brought indoors. Thus someone who is susceptible to hay fever may be able to find relief in their tightly sealed home, but they won't find it in a school classroom.

Good IAQ plans strive for problem solving through systematic investigation and, when all else fails, professional help. District staff must be encouraged to investigate all complaints thoroughly and promptly. Individual complaints may indicate either an isolated problem in a secluded area or the intolerance of a single individual to a contaminant. Repeated or multiple complaints may indicate larger or growing problems. While the details of IAQ work can be "scientific" and difficult to understand, more frequently they are straightforward and reflect common sense. For example, IAQ investigations often point to expected sources such as a classroom's pet hamster, sprays and perfumes worn by students and staff, reactions to foods or food supplements, or even allergic reactions to the aloe in tissues and hand soaps. Investigators should keep in mind that elementary-school students may have allergies that have not yet been identified by their parents or physicians.

If there is reason to suspect biological contamination (e.g., molds and microbes), the lab testing portion of an IAQ investigation begins with a study of the molds, bioaerosols, and other "natural contaminants" in the outside air for use as a control against which indoor air can be compared. Usually, HVAC filtration purifies the outdoor air so that indoor air has lower quantities of the same impurities. When indoor air tests reveal impurities that do not exist in the outdoor control, it suggests that something is "growing" inside. If investigators suspect that the problem is chemical in nature (e.g., fumes from cleaning agents stored within a facility), then volatile organic sampling may be undertaken.

Common indoor air pollutants include (but are not limited to):

tobacco smoke   formaldehyde   volatile organic compounds (VOCs)   nitrogen oxides

carbon monoxide   carbon dioxide   allergens   pathogens   radon

dust   lead   pesticides (used in or near buildings)

While this list is far from exhaustive, each of these contaminants needs to be understood and properly managed. Many of these compounds are common outdoor air pollutants as well, and all can be routinely linked to buildings and air-handling equipment.

Potential sources of IAQ contaminants include (but are not limited to):

		"fresh" air
		odors from dumpsters
		lab and workshop emissions
		cleaning process emissions
		insects and other pests
		insecticides and pesticides
		furnaces and fuel lines
		building occupants (e.g., perfumes)
		underground sources (e.g., sewer lines and radon gas)
		HVAC equipment (which is often a path of distribution)

Building administrators also need to be concerned about creating air quality problems. For example, landscaping "environmental" areas is a popular and worthwhile school revitalization project. However, if not properly handled, such initiatives can introduce moisture and mold problems (e.g., from mulch laid outside air-intake vents), lead to fire-exit violations (e.g., if access to exits are obstructed or impeded), and invite bees and biting insects (e.g., if pollen-releasing flowers are planted). The answer is not to forbid landscape initiatives, but to make sure that projects are carried out with proper foresight. The right questions - addressing issues such as plot location, intended use, and potential impact on health and safety - must be asked (and answered) prior to granting permission for any improvement projects.

For more information about indoor air quality management, visit the National Clearinghouse for Educational Facilities' IAQ resource list at http://www.edfacilities.org/rl/iaq.cfm, which provides list of links, books, and journal articles addressing indoor air quality issues in K-12 school buildings, including building materials, maintenance practices, renovation procedures and ventilation systems.

Asbestos

Asbestos is a naturally occurring mineral found in certain rock formations. When mined and processed, asbestos fibers can be mixed with a binding material for use in a variety of products. Asbestos products are strong, fire-resistant, corrosion-resistant, and good insulators. In schools, asbestos was commonly used in building materials and has been found in floor and ceiling tiles, cement pipes, pipe and boiler insulation, and spray-applied fireproofing. While the presence of asbestos-containing materials does not in itself pose an immediate health threat, it is well known that asbestos becomes hazardous when the microscopic fibers are released into the air, as can occur as a result of damage or deterioration.
 

The type and amount of asbestos in a product varies depending upon application. The condition, location, and exposure of the material to air are factors in determining the proper response. Asbestos fibers are so small and light that they can remain airborne for many hours (increasing the chance for inhalation) if they are disturbed and released into the air. Preventing the release of asbestos fibers into the air should be a school district's primary concern.

In 1986, the Asbestos Hazard Emergency Response Act (AHERA) was signed into federal law to regulate the management of asbestos-containing materials in public and private schools. AHERA regulations apply only to interior building materials and those under covered walkways, patios, and porticos.

AHERA requires local education agencies to:

		designate and train an asbestos coordinator
		identify friable (i.e., easily crumbled or ground) and nonfriable asbestos-containing materials
		develop and implement an asbestos management plan that reflects ongoing surveillance, inspections, and response actions
		develop and implement a responsible operations and maintenance program
		conduct inspections for asbestos-containing materials every three years
		perform semiannual surveillance activities
		implement response actions in a timely fashion
		provide adequate staff training and meet certification requirements
		notify all occupants (and parents/guardians) about the status of asbestos-containing materials each year.

In other words, school districts must know where asbestos materials are located in their buildings, inform occupants, and train their staff how to work in affected areas. EPA officials conduct random checks and audit district records for asbestos monitoring and reporting.

For more information about asbestos and asbestos management, visit the National Clearinghouse for Educational Facilities' Asbestos resource list at http://www.edfacilities.org/rl/asbestos.cfm, which provides lists of links, books, and journal articles on how asbestos abatement and management is conducted in school buildings, and how schools can comply with federal regulations.

Water Management

Public water supplies are generally categorized as either "community water systems" or "non-community water systems." If a school district gets its water from a local city authority, it is likely on a "community water system." If a school district uses its own wells as its water source, it would be classified as a "non-community system." In 1976, the U.S. Congress passed the Safe Water Drinking Act, which authorized the U.S. EPA to set standards for maximum contaminant levels (MCLs) for specified substances in water. Most state departments of environmental protection also have regulations addressing water-testing procedures. To ensure compliance with applicable water management regulations, school districts should:

		review pertinent federal, state, and local regulations
		develop a sampling, monitoring, and reporting plan that is commensurate with applicable regulatory guidance
		verify sampling methods used for testing and monitoring water quality
		address all water quality and systems operation deficiencies identified by the compliance plan
		incorporate water management guidelines into future construction and renovation initiatives.

Lead in drinking water has been shown to have a substantially detrimental impact on human health. The U.S. EPA requires that schools take adequate measures to ensure that lead-lined water coolers are repaired, removed, or replaced. Schools are also required to test and remove lead contamination from all sources of drinking water.

If a school district receives its water from a community system, water-testing requirements may be the responsibility of the local water authority. If, however, a school district has its own wells, it may have to comply with numerous water-testing requirements (such as for nitrates, chlorination, and turbidity), although state and local requirements vary.

In some areas, schools face water shortages. Moreover, once an adequate water source is identified, storage levels must be properly maintained, monitored, and treated. Because schools normally operate in peak-use time frames, water treatment equipment has to be sized to handle peak demand. Water-related considerations may affect the size of the boiler room as well as space for storing service equipment and chemicals. Effective water systems management requires a well-trained staff or a professional firm hired to perform the monitoring and testing. In many states, certificates and permits are required to perform these services.

Waste Management

Waste management is a catch-all term that includes trash removal, recycling, and the disposal of hazardous waste. Trash removal is probably the most high-profile aspect of waste management in a school setting. In many jurisdictions, it is illegal to dump, burn, or otherwise dispose of solid waste (e.g., paper, wood, aluminum, trash) without a permit. Thus, school districts must be aware of applicable local and state laws and regulations concerning solid waste disposal.

Recycling may also play an important role in an education organization's waste management plan. Many townships and cities require recycling. In other areas, school districts may have to choose between the environmental and social benefits of recycling and the incremental costs incurred to recycle.
 

In any case, both solid waste and recyclables should be removed from occupied areas as soon as possible after being collected. Storage facilities (even temporary storage areas) must be located away from occupied areas to minimize the risk of fire and infestation.

The Right-to-Know Act (http://es.epa.gov/techinfo/facts/pro-act6.html) requires planning and assessment for a range of hazardous waste materials-from small-engine machine shop oil to science laboratory chemicals. Chemicals used by maintenance and custodial personnel may need to be noted on a material safety data sheet (MSDS) to verify that proper procedures for their use, storage, and disposal have been followed. No potentially hazardous material should be brought into a school facility without being properly labeled and having an MSDS on file. Staff must recognize the potential volatility of chemical agents that can enter breathable air when they are handled improperly. For example, many people know that when the roof leaks, wood can get wet and mold can grow. Fewer people know that the bleach used to clean mold stains may itself have serious health ramifications if the space is not properly ventilated during use. Thus, the ongoing review of systems, monitoring, and testing is critical to the recognition and handling of potentially hazardous materials.

Certain hazardous waste materials, including asbestos, also require that the organization sign a waste manifest for the receiving dump or waste site. For example, the dumping of soil contaminated by leaking fuel oil during a tank removal project may require the district to sign a waste manifest before the solid waste management facility will accept the contaminated dirt. This manifest may assign ownership and potential liability to the district in the event of a future site-cleanup mandate. In some cases, storage facilities may offer (for an additional cost) to burn the material, thereby avoiding the waste manifest procedure and negating potential future liabilities. These decisions require forethought, due diligence, and disclosure-and may warrant the advice of the district's legal counsel.
 

The disposal of medical waste, including blood-borne pathogens (BBPs), requires additional supervision and planning. "Universal precautions" is an approach to infection control that requires all human blood and certain bodily fluids to be handled as though they were infectious. Thus, all persons who clean, or otherwise come in contact with, bodily fluids should routinely take appropriate barrier precautions to prevent skin and membrane exposure. This includes wearing gloves, masks, protective eyewear, gowns, and mouthpieces (e.g., during resuscitation). The disposal of needles and sharp instruments also requires special care (e.g., used needles should never be recapped or broken by hand). All building surfaces exposed to bodily fluids should be decontaminated by cleaning with a bleach/water solution at a 1:10 ratio or another EPA-approved tuberculocidal cleaning agent. All cleaning tools should be disposed of immediately after use (and double-sealed in 6-mil polyethylene plastic bags). It is advisable for decision-makers to refer to local hospitals, clinics, and doctor offices for guidance in this area. Procedures for handling medical waste from the nurse's office and athletic training facilities should be clearly written, and all staff involved in cleanup and transport of such waste must be adequately trained. Storage and transportation of such materials is regulated, and disposal may require the services of certified or licensed individuals or firms.

An issue that further complicates proper cleaning practices is that janitorial staff are advised to wear latex gloves when handling hazardous materials (and even general cleaning agents), although some individuals may have severe allergies to latex gloves. Therefore, employees must be monitored for skin or respiratory reactions when wearing latex gloves. If the use of latex gloves by students is warranted (e.g., in chemistry labs), such procedures also require monitoring, and may justify parental notification.

Wastewater management (sewage plants) is another topic that some schools may need to be concerned about. Whether wastewater goes to a local community waste plant, an in-house waste treatment plant, or an on-site drainage field, school staff should have a thorough understanding of their wastewater management responsibilities. Regardless of ownership, water treatment facilities must be managed and run by certified operators. District-owned facilities face special operational concerns that stem from the great fluctuations in demand placed on the system due to the variability of the school schedule. On a daily basis, facilities must handle peak flow during school hours (and even more specifically during windows between class periods). Weekends and holidays, on the other hand, present intervals of very low demand. Prolonged dormancy associated with summer vacation pose additional start-up issues each fall. Therefore, staff must be prepared to schedule equipment use, maintenance, and testing accordingly. Care of on-site systems should include annual inspections, pumping, and regular maintenance as needed. Kitchens should have grease traps to prevent grease from being transported to drainage beds in the system. The drainage beds themselves should be well marked. Wastewater from science labs and maintenance shops (both potentially carrying hazardous materials) must be managed from their source all the way to the treatment facility. These pipes must also be protected from accidental damage (on more than one occasion a local school organization has placed playground equipment right on top of a sewer bed or driven equipment poles through a drainage pipe).