Are Your Schools Safe?
Are Your Schools Safe?
Poor environmental conditions within child-occupied buildings (schools, day care centers, etc.) have been shown to decrease academic performance, increase absenteeism, as well as potentially contributing to various health concerns among students including respiratory irritation, increased asthma attacks, sore throats, and headaches to name a few. It is important to know if potential environmental issues (asbestos, lead-based paint, indoor air quality, mold, drinking water quality, radon, etc.), where appropriate, have been addressed within buildings in accordance with the Environmental Protection Agency’s (EPA) guidelines to provide a safe environment for the students, teachers, administrators and other staff.
The EPA has provided extensive guidance for facility directors, building managers, and other school personnel focused on maintaining safe and healthy building environments for the building occupants. The following narrative will briefly discuss the potential environmental hazards which are commonly found within school buildings. In addition, it will provide information regarding where facility directors, building managers, and other staff can get information to evaluate their school’s current environmental conditions, as well as their existing programs to maintain or enhance acceptable building conditions. The commonly found environmental hazards present in our school buildings are discussed below.
Asbestos
The EPA has mandated that school districts have distinct regulatory requirements to protect students, teachers, and other staff from asbestos exposure. School districts are required to develop, maintain, and update asbestos management plans and to keep a copy at each individual school. These plans were developed to assist facility directors, building managers, and other school personnel in the management of any asbestos containing materials present at their school(s). Any structure constructed before 1980 is likely to contain asbestos in insulation products, flooring, caulks, and roofing materials. The school authority is required to continue to monitor any asbestos within school buildings and update asbestos management plans as asbestos is removed and replaced with non-asbestos materials. Parents, teachers, and school employees or their representatives have the right to inspect the school’s asbestos management plan. Schools are required to notify parent-teacher organizations (such as PTAs or school websites) once a year about the availability of the school’s asbestos management plan and asbestos-related activity taking place within the school over the past year. The school must make the plan available for inspection within five working days of it being requested.
Environmental Resources Group, LLC (ERG) has worked with many school districts and found the majority have implemented Federal Asbestos Hazard Emergency Response Actions (AHERA) protocols and had an asbestos building survey completed many years ago. However, many of these districts have not continued annual obligations required by AHERA, including periodic inspections of documented asbestos, annual training for custodial and maintenance personnel, and annual notifications. Continued compliance with these annual requirements will assist school districts in identifying potential problems, as well as in upgrading their programs to address any maintenance requirements needed. EPA has published many guidance documents on the AHERA program for facility directors and buildings managers to use as resources to continually evaluate their obligations. Links to several of these key documents are presented below:
https://www.epa.gov/asbestos/asbestos-and-school-buildings
https://www.epa.gov/asbestos/federal-requirements-asbestos-management-schools-fact-sheet
Lead-Based Paint
Many schools constructed before 1978 can contain lead-based paint (LBP). Inhalation or ingestion of lead-containing paint chips or dust have been shown to cause various health issues including brain and nervous system damage, decreased IQ, learning difficulties, hearing problems, slow or reduced growth, muscle or joint pain, digestive problems, kidney damage, and speech, language, and behavior problems, especially in young developing children. Dust is the most common source of lead exposure among children.
In order to reduce the risk to lead exposure, the EPA, Occupational Safety and Health Administration (OSHA), as well as state health departments have developed various programs to reduce potential exposure incidents to lead in child-occupied facilities. A brief explanation of these programs is included in the EPAs Lead-Based Paint Renovation, Repair, and Painting Program (RRP) which mandates contractors, property managers, and others who disturb painted surfaces during work operations in child-occupied facilities built before 1978 employ lead-safe work practices during construction and/or renovation activities. To minimize potential exposure to lead, the EPA has mandated the following requirements for any work conducted in child-occupied facilities:
Pre-renovation education requirements:
• Contractors, property managers, and others who perform renovations for compensation in residential houses, apartments, and child-occupied facilities built before 1978 are required to distribute a lead pamphlet to owners, tenants, and child-occupied facilities before starting renovation work. This regulation is enforced by the Michigan Department of Health and Human Services.
Training, certification, and work practice requirements:
• Contractors are required to be EPA Lead-Safe certified, and their employees must be trained (either as a certified renovator or trained by a certified renovator while on-the-job) in the use of lead-safe work practices, as well as in lead-safe work practices that minimize exposures to lead hazards.
• The EPA RRP Certification does not allow the contractor to conduct lead abatement.
For additional information on minimizing building occupants to lead-containing dust or paint chips, refer to the following links:
https://www.michigan.gov/documents/lara/lara_miosha_constfact_miosha_epa_lead_rules_388662_7.pdf
Drinking Water Quality
Drinking water quality within many school districts is typically controlled by the local municipality which ensures water quality meets stringent EPA guidelines. Municipal water systems are treated and regularly tested by the water authorities, thus providing high quality drinking water to the school district buildings. The concern comes into play when the water reaches the school building where it could encounter aged and corroded plumbing which can release lead, copper, and other contaminants into the drinking water. The plumbing may consist of lead pipes and/or solder, or brass or chrome plated fittings or fixtures which can be readily absorbed in the drinking water. The EPA has developed guidance on the proper sampling and management of drinking water at child-occupied facilities. Select references are presented below:
https://www.epa.gov/dwreginfo/lead-drinking-water-schools-and-childcare-facilities
Indoor Air Quality
Most people are aware that outdoor air pollution can impact their health, but indoor air pollutants such as radon can also have significant and harmful health effects. EPA studies of human exposure to air pollutants indicate that indoor levels of pollutants may be two to five times—and occasionally more than 100 times—higher than outdoor levels. These levels of indoor air pollutants are of particular concern because most people spend about 90 percent of their time indoors. The definition of good indoor air quality (IAQ) management includes:
• Control of airborne pollutants
• Introduction and distribution of adequate outdoor air
• Maintenance of acceptable temperature and relative humidity
Temperature and humidity cannot be overlooked because thermal comfort concerns underlie many complaints about “poor air quality.” Furthermore, temperature and humidity are among the many factors that affect indoor contaminant levels. Outdoor sources should also be considered since outdoor air enters school buildings through windows, doors, and ventilation systems.
A summary of potential problems with indoor air quality is presented below:
• Impact on student attendance, comfort, and performance
• Reduction in teacher and staff performance
• Acceleration in the deterioration and reduction in the efficiency of the school’s physical plan paint and equipment
• Increase in potential for school closings or relocation of occupants
• Strain on relationships among school administration, parents, and staff
• Negative publicity
• Impact on community trust
• Potential liability and legal problems
The EPA has published an excellent resource tool entitled “Indoor Air Quality Tools for Schools Reference Guide” to assist facility directors, building managers, and other staff in their management of the indoor environment. A link to this document is presented below:
https://www.epa.gov/sites/production/files/2014-08/documents/reference_guide.pdf
In addition to the above common environmental issues, ERG has seen other environmental factors occur at schools including:
· Chemical spills
· Radon
· Pesticides
· Mercury
· Polychlorinated Biphenyls (PCBs)
· Underground Storage Tank releases
Should you have any questions on the above environmental matters feel free to contact the author at robert.anderson@ergrp.net or via telephone at 810.964.9055.
About the Author - Robert C. Anderson, PG, EP is a Senior Project Consultant with Environmental Resources Group, LLC (ERG). Mr. Anderson specializes in the material science and industrial hygiene areas and has had significant experience in assisting various school districts with asbestos, lead-paint, drinking water issues, indoor air quality, and implementation of environmental management programs. In addition, Mr. Anderson has assisted school districts with employee training, chemical management programs and chemical response activities. Mr. Anderson is a licensed professional geologist (PG) and Environmental Professional (EP), in addition to being certified in asbestos, lead, and radon. He can be reached at robert.anderson@ergrp.net or call ERG’s offices: 248-773-7986 (Southeast Michigan) or 231-747-8556 (West Michigan).