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Reading, Writing and Risk: Read the Report
An Assessment by the California Interagency Working Group on Indoor Air Quality
Indoor Environmental
Quality n California Schools: Critical Needs
--DRAFT--
This Report is Still in Draft Form Please Do Not Cite
August 1998
Available from
Indoor Air Quality Section
Environmental Health Laboratory Branch
California Department of Health Services
2151 Berkeley Way # Berkeley, CA 94704 510-540-2469 # FAX: 510-540-3022
http://www.dhs.cahwnet.gov/org/ps/deodc/ehlb/iaqs/iaqindex.htm
Indoor Environmental Contaminants 5
School Administration and Authority 6
Design and Construction of School Facilities 6
Responses of School Officials to IEQ Problems 7
School Maintenance and Deferred Maintenance 9
Relocatable Classrooms and Class Size Reduction Programs 10
Postscript: Development of Guiding Principles 15
Committee on Indoor Environmental Quality in Schools 16
Executive Summary
This report was prepared by a committee of the California Interagency Working Group on Indoor Air Quality (CIWG-IAQ). Its goal was to evaluate the current status and critical needs of California schools’ facilities with respect to indoor environmental quality (IEQ). The report presents a review of available information and a set of recommendations and proposals aimed at policy-makers and public school administrators for initiating corrective change and developing measures to prevent IEQ problems in California schools.
There is evidence that many schools in California have serious IEQ problems, which are causing health concerns in students and staff, reducing teaching and learning effectiveness, and draining resources away from the schools’ core functions. Notably, in a recent U.S. General Accounting Office assessment of the nation’s school facilities, California was ranked last among the states, with the highest percentage of schools with unsatisfactory IEQ conditions (e.g., inadequate ventilation, leaking roofs, indoor air quality problems, etc.). The downward trend in school IEQ in California started with the passage of Proposition 13 in the late 1970's, and it can be attributed to the drop in funding for public schools over the past two decades. Often, facility maintenance programs were the first cut, and restoration of programs has been slow as funding is increasing. Furthermore, the construction of new and replacement school facilities has not kept up with the State’s student population growth of 34% (nearly four times the national rate) since 1980.
The following key findings are reported: (i) school facilities throughout the State have suffered protracted neglect, disrepair, and poor IEQ; (ii) many of these problems are due to a combination of limited resources, inadequate training of school staffs in IEQ issues, and diffuse authority for proper facilities design and maintenance; (iii) increasing student populations will further stress facilities and generate the need for more construction and renovation of public schools, and (iv) continued neglect will have considerable health, educational, and financial costs to the children, school staff and citizens of California.
The following actions are proposed to address these issues:
- Authorize centralized review of IEQ issues in public schools (e.g., design and maintenance) and development of IEQ training programs for school staff;
- Develop stronger incentives for school districts to remediate current IEQ problems and conduct effective, routine maintenance of school facilities;
- Mandate a full investigation of statewide IEQ problems to develop a more complete set of recommendations and priorities for the State Legislature, to the Department of Education, and school administrators;
- Ensure adequate funding, resources and staff for the above programs.
The committee’s report highlights the need to address the systemic problems in order to improve IEQ in school. Part of the recovery will accompany increasing funding; nonetheless, there needs to be administrative fixes applied, as well. The next steps will be to identify appropriate agencies, determine the funding and staff resources needed, and establish priorities for these programs. While the costs of corrective actions are potentially high, many no-cost and low-cost approaches are available, provided that the mandate and authority are given to develop and implement them. As important as funding, the development of guiding principles and program oversight is needed to implement more comprehensive, effective, and long-lasting approaches to IEQ problems in California schools. With
a commitment to such principles, California has the opportunity to restore its schools to the safe and healthy learning environments that citizens expect and about which students, staff and administrators can be proud.
California public schools are home to close to six million children in kindergarten through 12th grade and the workplace for more than 200,000 full-time equivalent teachers and thousands of administrators and support staff. These individuals spend a considerable portion of their days within the confines of school buildings. When before- and after-school care programs, day-care for pre-schoolers, and adult classes at public schools are also considered, the total time that members of the California public spend inside school facilities is substantial.
Indoor environmental quality (IEQ) is the sum of factors experienced by occupants in a building, such as temperature, humidity, ventilation, lighting, noise, cleanliness, odor, and exposures to chemical and biological agents. Recognizing that the key focus of school programs is the education of its pupils, it is important to emphasize how essential the safety, security, and healthfulness of schools are, so as not to compromise these educational goals. In this report, we are particularly concerned with factors affecting student and staff health.
Concerns about school IEQ among school personnel and the public health community have dramatically increased in recent years, along with a heightened awareness of these problems among the public. The public is now well aware that California public school infrastructure has been deteriorating. Problems of IEQ, such as leaking roofs, mold contamination, indoor air pollution, inadequate ventilation, and hazardous chemicals, are a common complaint made by school staff and parents to school officials, and by local districts to the California Department of Education (CDE). Furthermore, health and
air pollution control agencies at the local and state levels have noted sizable increases in requests for help from parents, teachers, and school administrators.
The costs of poor school IEQ are considerable. These costs are paid by students, staff, parents and the community, alike. In the school populations, the costs include poor health, reduced learning, and increased frustration when IEQ problems become unmanageable. These costs are difficult to quantify. More easily counted are the strained budgets and staff resources expended for deferred-maintenance repairs, litigation, and damage control, especially when these would otherwise be available for educational programs.
Children have little or no control over their environment while at school. In California, no agency or group has central authority as a watchdog for children in their school environment. There are no right-to-know provisions in the law for parents or students pertaining to hazardous conditions which may exist in schools. While there are laws that regulate the health and safety of schools as workplaces for teachers and staff, these do not directly apply to the students in the same buildings. Nonetheless, even if applied to student populations, worker standards are not appropriate to children, as they are generally more susceptible to environmental hazards than adults.
Poor school IEQ can cause both short-term (reversible) and long-term (chronic) effects in students and staff. Overcrowded, poorly ventilated classrooms contribute substantially to the spread of infectious diseases, such as colds and influenza. Poorly maintained carpets, dirty air ducts, and water-damaged materials are prime breeding grounds for a plethora of substances that can trigger asthma attacks, sensitize allergy-prone individuals, and cause sinus and respiratory infections. Asthma is one of the environmentally triggered diseases acquired during childhood which may be carried well into the adult years. Other chronic diseases include irreversible lung and respiratory illnesses that result from chronic irritation by airborne chemical and/or biological contaminants. The economic costs of these long term, possibly life-long, diseases are substantial; the costs in terms of quality of life are more profound, and certainly difficult to measure.
The school infrastructure, which includes heating, ventilation and air conditioning (HVAC) systems, carpets, furnishings, and even roofing, floors, walls and ceilings, is a tremendous financial investment on the part of each community and needs to be protected. The State also has a considerable financial stake in school infrastructure, as it funds the majority of new building construction, modification, and deferred maintenance repairs -- over $1 billion per year. In spite of this, there are no State enforcement or incentive programs to promote or support routine and timely school building maintenance programs. Without proper upkeep, school facilities will continue to deteriorate. Besides quality of life impacts, scrimping on school maintenance is an unwise and short-sighted business practice.
This report was prepared by the California Interagency Working Group on Indoor Air Quality (CIWG-IAQ). The main goal of their assessment is to evaluate the current status and potential consequences of California school environmental quality and to address the questions: Are California public schools healthy and safe for students and teachers? What might be done to remedy existing problems and prevent future problems?
The CIWG-IAQ is an organization of representatives from State, Federal, local, and non-governmental agencies with IAQ oversight or interests, chaired by the California Department of Health Services’ (DHS) Indoor Air Quality Section Chief. The Group was established in 1983, under the mandate of Assembly Bill 3200 (Tanner, 1982), which directed the Department of Health Services to safeguard the public interest "by a coordinated, coherent State effort to protect and enhance the indoor environmental quality in residences, public buildings, and offices in the state." The CIWG-IAQ’s Indoor Environmental Quality in Schools committee was formed in June 1996 to address IEQ issues in California public schools, in the wake of the findings on California schools of the U.S. General Accounting Office reports on School Facilities, the release of U.S. Environmental Protection Agency’s IAQ Tools for Schools Action Kit, and the projection of major increases in school construction, renovation, and use of relocatable classrooms under the 1996-97 Class Size Reduction Program. This report was a voluntary, collaborative project among committee members (see page 16).
The newspapers and TV are frequently filled with alarming stories of hazardous school conditions, afflicted students and staff, and frustrated parents and administrators. Due to the decentralized nature of the California public school system, there are not means to accurately document the magnitude of system-wide IEQ problems encountered by school staff and students. Hence, the extent and severity of indoor air quality, ventilation, and contamination problems are not fully known. While concerned by the incidences and anecdotes of poor IEQ crises, the CIWG-IAQ committee has focused more on the systemic nature of IEQ problems in California school facilities and looked for global solutions. The committee sought the best available information and most current facts in our assessment of IEQ issues in California schools. The relative lack of hard data or systematic analysis on this topic was disturbing. Key findings of available studies are listed below:
- A recent report by Lawrence Berkeley National Laboratory reviewed the literature on school IAQ and found that the most common building-related problem was "inadequate ventilation with outside air." The second most common problem was water damage to the building shells of schools, leading to mold contamination and growth. The report suggests that the root cause of the problems was inadequate or deferred maintenance of school facilities. The report also pointed out that measurements of indoor air pollutants are very limited and make quantitative analyses of their impacts on health difficult.
- The California Energy Commission investigated ventilation in California schools. Their report found that schools consistently had lower ventilation rates than required and that one out of every three classrooms they tested had air exchange rates which were less than one-half that required to meet the baseline acceptable standard per occupant.
- In recent nationwide assessments of school facilities, California was ranked last, having more unsatisfactory environmental conditions in schools than any other state. Seventy-one percent of California schools reported at least one inadequate building feature (HVAC, plumbing, roof, framing, floor, foundation, wall, window, door, interior and exterior finish), 41% of schools reported inadequate HVAC systems, and 40% reported roof problems. These surveys were conducted by the U.S. General Accounting Office (GAO) and summarized in a series of published reports.
- In the GAO studies, center-city schools and those with higher proportions of minority and poor students reported needing extensive repair or replacement at least 30% more than non-center-city/minority schools.
- In 1994-95, California ranked 35th in per-student state expenditure for public (K-12) education, out of the 50 states and the District of Columbia. It is ranked at 41st, when federal sources are included This is currently the lowest among the ten most populous states. In 1979-80, California ranked 12th in the nation.
- The construction of new and replacement school facilities in California has not kept up with the population growth. From 1980 to 1995, the state public school (K-12) enrollment has grown from 4.1 to 5.5 million or 34%; the national growth for the same period was only 9%. According to a study published by the American Association of School Administrators (AASA), the majority of public school buildings have "outlived their predicted useful life."
- By 2005, California public school enrollment is expected to grow by an additional 9%, (to nearly 6 million students). Hence, the acute demand for new classrooms, generated by the recent Class Size Reduction Programs, can be expected to continue.
Besides its effect on other components of education, the drop in school funding has been a major factor contributing to the deteriorating environmental conditions in many schools. As the student population continues to increase, the supply of adequate and safe school facilities will not be able to keep up with the demand. There will be even more pressure on currently strained facilities, and continued neglect will result in considerable health and financial costs to the children, school staff and citizens of California.
Both students and school staff may suffer the detrimental effects of poor IEQ. Chemical toxins and biological agents in the classroom can lead to health risks and adverse learning conditions. These can affect many different body systems, and impact health, learning productivity, and self-esteem. Effects can be both transient and long-term. Symptoms can range from mild discomfort and the perception of bothersome odors to severe illness and permanent injury. Health effects include increased rates of infectious diseases (e.g., influenza and the common cold), eye and respiratory irritation, allergies and asthma, chronic sinusitis, headaches, and an array of respiratory diseases.
A key point for the concern over IEQ problems in schools is that children are much more vulnerable than adults to environmental contaminants and injury. Both their breathing rates and metabolic rates are significantly greater than adults relative to their size. Hence, in the same environment as adult staff, children will breath in and metabolize greater doses of airborne toxins. They are more sensitive because their tissues and body systems are less mature (e.g., less able to produce key metabolic enzymes). Because children’s bodies are actively growing, they absorb and retain more contaminants in the local environment. Their defense mechanisms are less effective to prevent contaminants and infectious organisms from entering their bodies, and their immune systems are less able to respond when agents
do enter. Finally, environmentally-induced diseases, such as asthma, lead to many more years of productive life being lost for children than for adults. In recent studies, exposures to common molds and damp environments have been associated with childhood respiratory illnesses (such as persistent wheeze, attacks of shortness of breath and bronchitis). With the backdrop of a national trend of increasing asthma morbidity, sharp increases in the prevalence and severity of asthma have been noted among student and staff populations, especially in some urban areas. This means an increasing number of students and staff already have highly sensitized respiratory systems.
IEQ in schools can have a profound effect on learning. Inadequate ventilation leads to the build-up of carbon dioxide and other indoor pollutants, which are often associated with discomfort and the inability to concentrate. Discomfort, eye irritation, recurring headaches, inability to concentrate or assimilate information, behavioral problems, sleepiness, absenteeism, and exacerbations of asthma are some of the examples of the effects of poor classroom IEQ on children. Similar impacts on teachers further diminish the effectiveness of the learning process.
Indoor Environmental Contaminants
The U.S. Environmental Protection Agency (U.S. EPA) has produced a number of comprehensive guides on indoor air quality and key contaminants. For most schools, the contaminants that have demanded their greatest attention and resources are Asbestos and Lead, which are governed under federal laws. Asbestos management in schools has been governed under AHERA, which requires schools to develop a "management plan" for Asbestos containing materials (ACM), provide training for certain staff, conduct school surveillance for ACM, and make written documentation available to all concerned persons such as faculty, staff, and parents. Lead abatement programs affect school districts with older facilities with Lead-containing paints or water system components. The State DHS Childhood Lead Poisoning Prevention Program recently conducted a survey of Lead contamination in schools.
Problems related to volatile organic compound (VOC) off-gassing, moisture and mold contamination, and pesticide use are believed to be increasing, although there have not been any investigations of these contaminant exposures in California schools. Guidance documents to aid in addressing these issues have been recently published. The DHS Indoor Air Quality Section, following legislative mandate, prepared non-binding guidelines on reducing occupant exposures to VOCs from building construction materials. The U.S. EPA prepared a How-to Manual on integrated pest management in schools, to assist
facility managers to minimize pesticide exposures by school personnel. U.S. EPA contractors are preparing a manual to help schools address mold problems and school renovations. A preliminary study of Radon contamination in California schools indicate that annual concentrations above the U.S. EPA action level in one or more classrooms occur at ~5% of schools; certain areas of the State are likely to contain a large proportion of these high Radon classrooms.
SCHOOL ADMINISTRATION AND AUTHORITY
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Besides school district and local school administration, governance over various aspects of school facilities and IEQ is shared among several State agencies, including the Departments of Education (CDE), General Services (DGS), and Industrial Relations (DIR). State and local health officers, building officials, and fire departments also have limited authority to address issues of public health and safety in school buildings.
CDE has general authority over school facility planning, construction, and funding. State aid provides just over half, and local property tax levies contribute 1/3 of school funding. The remainder comes from federal and local programs, and about 2% from the State lottery. Proposition 98 (passed in 1988) governs around 80% of public school funding in California. Since passage of Proposition 13 in 1978, funding for public schools has not kept pace with inflation. The per-pupil spending has dropped from 12th in the nation (1979-80) to thirty-fifth (1994-95). It is currently 15% below the national average, the lowest among the ten most populous states. General purpose spending accounts for 2/3 of school programs. Most of the remaining third is restricted to targeted-use programs, such as special education. On average, 10% of school-site costs are associated with maintenance. The funds for school construction and modernization are generally financed by State and district school bond measures.
Design and Construction of School Facilities
The design and construction of school facilities are subject to the State building and energy efficiency standards, contained in California Code of Regulations, Title 24. As with other State-funded material expenditures, DGS oversees the design and construction of educational facilities. The DGS’ Office of Public School Construction (OPSC) administers the State programs for public school facilities construction and modernization, relocatable classrooms, and deferred maintenance. DGS’ Division of the State Architect (DSA) is responsible for reviewing school design plans and construction inspection. School districts are required to submit planning and construction documents prepared by licensed design professionals. They are required to provide a DSA-certified project inspector to be present during construction on a continuous basis. DSA staff ostensibly reviews all aspects of the facility design, and for large projects, they conduct monthly and final visits during construction. However because of limited resources, the DSA
review and inspections focus principally on their mandated priorities: structural safety, fire & life safety, and access compliance.
In the case of relocatable classrooms, the DSA offers an expedited review focused on the fire & life safety components, provided the buildings are duplicates of previously approved designs. For the State Relocatable Classroom Program, the DGS issues bid specifications, which effectively serve as the template for non-Program relocatable classroom purchases.
The ventilation provisions of Title 24 specifies the related requirements for design and installation of heating, ventilation & air conditioning (HVAC) systems in non-residential facilities, including schools. For example, the State Minimum Building Ventilation Standard requires that mechanical ventilation systems operate continuously during working hours and provide a specific amount of outdoor air (usually 15 cubic feet per minute per person).
While DSA does not review compliance with ventilation requirements, local building departments do not have authority to monitor school facilities. This means that an explicit review of HVAC systems does not occur. Insufficient outdoor air supply, due to inadequate design or malfunctioning HVAC equipment, is often the cause for indoor air quality problems in schools. Similarly, there is no review or guidance in the area of material selection, which is another feature that can have significant impact on indoor environmental quality. School designs are not flagged for materials that off-gas excessive VOCs or are more prone to mold problems.
The State DIR’s Division of Occupational Safety & Health (Cal/OSHA) has responsibility for monitoring the health and safety of public school facilities as workplaces for teaching, administrative and support staff. Cal/OSHA has oversight over all workplaces, but they do not conduct routine inspections of non-industrial sites, such as school facilities. County and city health officials can intervene in clear emergencies, but rarely do in cases of routine health or safety issues. It is Cal/OSHA’s policy to investigate all complaints alleging workplace conditions that are hazardous to building occupant-employees, including "serious exposures involving workplace [indoor air quality]."
In reality, Cal/OSHA site inspections only occur when there are sufficient numbers or severity of teacher or staff complaints directed to them. This is a burdensome procedure, which often puts staff at odds with school administration. In practice, Cal/OSHA inspectors are able to visit only several dozen of the State’s many thousands of schools facilities in a given year. Furthermore, Cal/OSHA indoor air contaminant standards (i.e., maximum chemical exposure limits) are based on the susceptibility of normal healthy adults to individual industrial contaminants in the workplace. Their effectiveness to protect children or even non-industrial adult workers, such as teachers, is open to question. Thus, even when Cal/OSHA standards are applied, this does not ensure that pupils are adequately protected from potential adverse agents in their school environment.
Responses of School Officials to IEQ Problems
Responses of local school officials to IEQ problems tend to be unstructured and ad hoc. They are generally struggling within budgetary shortfalls to maintain educational programs, and IEQ complaints are often not considered to be serious or important. In cases when Cal/OSHA is not involved, the school administration may not have on-site expertise to address IEQ problems. Except for asbestos management, school maintenance staffs are not routinely trained on IEQ, and they are often ill equipped to manage these additional duties. Resolving on-going IEQ issues are typically delegated to lower-level
maintenance staff or consolidated under unrelated administrative staff. There are relatively few school districts which have resources to provide appropriate training for their staff in the technical skills necessary
for them to properly identify, evaluate, monitor or remediate IEQ concerns.
When there is a lack of resources or expertise, untreated problems can compound in severity until they threaten the health and safety of the individuals within the schools. These situations then grow to crisis proportions; often they lead to distraction of administration staff, adversarial relations with teachers and parents, and hiring of costly consultants. Even though crisis management is generally more difficult, costly, and painful than prevention planning, current limits in budgets and policies have bound State and local school officials to such practices.
Despite the fact that IEQ problems have become so common in recent years, there has not been any formal effort to determine the types or numbers of complaints in California public schools, and no State agency has emerged to provide information or assistance to school officials in this area. Neither CDE nor State health agencies systematically monitor site-specific problems involving health complaints or poor IEQ in schools. Some limited information on teachers’ asthma has been developed as part of the DHS’ Occupational Health Branch (OHB) worker surveillance for Cal/OSHA. However, lacking resources or a clear mandate to monitor this issue, no agency has conducted a statewide survey of teachers’ or pupils’ health or maintain incident logs of IEQ problems in schools.
One of the dramatic changes in the California school system in the Proposition 13 era has been the effective loss of the on-site school nurse. Nurses on district staffs are routinely rotated among the school facilities, and they are available no more than 1 or 2 days per month. This makes any routine health surveillance programs of staff or students difficult.
Limited assistance to California school officials, in the form of information and staff training, has become available in the past few years from the U.S. EPA, with the publication of their IAQ Tools for Schools Action Kit and the free workshops they have sponsored. Guidance documents also have been developed in recent years by programs in other states, such as the Washington State Department of Health, Maryland Department of Education, and Healthy School Networks in Massachusetts, and New York. Washington’s IAQ Best Management Practices Manual was written in response
to requirements of their state legislature and funded by their Office of the Superintendent of Public Instruction. Similarly, the Maryland Technical Bulletins were written under contracts paid by their state Department of Education. The New York coalition pressed their State Regents to sponsor an Advisory Committee on Environmental Quality in Schools. Legislation on IEQ in schools was recently enacted in Texas and Florida; lobbying came from coalitions of parent groups and teachers’ unions. Notably, there is no established coalition in California similar to those in Massachusetts, New York and other states.
SCHOOL MAINTENANCE AND DEFERRED MAINTENANCE
The responsibility of school facility maintenance falls to the board of local school districts. The Education Code requires the board to "keep the schoolhouses in repair during the time school is taught therein" [§17593]. It does not include specific guidance, except that "[the board] shall maintain schools and classes as provided by law" [§35290]. By that, it may be assumed that school facility maintenance should adhere to requirements applied to other public buildings. However, there are no general standards for building maintenance in the governmental codes. Instead, there are "professional standards of practice," such as those promoted by BOMA and other industry groups. Furthermore, there is no specific funding allotment for school facility maintenance staff or programs. These fall within school districts’ general school-site spending. In the Proposition 13 era of dwindling resources and Proposition 98 shift to centralized spending , funding requests for adequate maintenance have gone head-to-head with other school programs — and lost.
The Deferred Maintenance Program is administered by OPSC for the State Allocation Board (SAB) to provide funding to schools for major capital-item expenditures, such as new roofs, repairs of water damage, and HVAC components. The program requires districts to apply to the SAB with a five-year plan of maintenance needs and to match any State funds received. There is a cap on the amount a district can receive, based on its size (of approximately _ % of their operating budget). Districts may request "Critical Hardship Apportionment" in cases when the basic amount is insufficient and delaying the project past the current year will cause serious damage to the remaining facility or result in a serious health or safety hazard. As the program is configured, schools only receive funding beyond their annual operating
budgets for "large" problems. As such, the program provides little incentive for the preventive care of facilities, where districts receive inadequate funding for routine maintenance. Furthermore, the program has not been adequately funded to keep up with the rate at which school facilities are deteriorating. The plethora of roof leaks, water intrusion, and poorly functioning HVAC systems in schools throughout the State serve as evidence of routine maintenance activities too long deferred. In recent years, the State and some local districts have been successful in passing school bond measures, which have, in part, provided additional resources for construction, modernization, and repairs to infrastructure.
RELOCATABLE CLASSROOMS AND CLASS SIZE REDUCTION PROGRAMS
In 1996, there were an estimated 50,000 relocatable classrooms or "portables" in use. The majority of these have been purchased directly from manufacturers or other sources. The OPSC administers the State Relocatable Classroom Program, which has distributed roughly 7000 units in a lease/purchase arrangement with districts starting in 1979. Though the State program was initially designed to provide temporary school buildings in times of emergency need, one of three state-leased relocatable buildings is more than 10 years old. Although data are not available, it is likely that non-state leased relocatables
are at least as old. The deterioration of older relocatable classrooms, coupled with the lack of IEQ standards and preventative maintenance programs, would suggest that the fleet of non-State leased relocatables will experience serious problems.
Anecdotal reports from district facilities staff indicate that relocatable units appear to be especially vulnerable to water damage from roof leaks and condensation in the attic or crawl space. Teachers in new units frequently complain of off-gassing chemical odors; in older units, odor problems are often associated with defective HVAC equipment and moldly classroom carpets. The decline in maintenance staff (see below) has made carpets in classrooms a highly questionable option. Unfortunately, there is no program to systematically inspect relocatable classrooms, to monitor their continued suitability to provide a safe, healthy learning environment for students and teachers, or to determine optimal design/operation parameters for them.
The Governor and Legislature created the Class Size Reduction Program (CSR), starting in 1996/97 and augmented in 1997/98, to reduce average class size from nearly 30 to no more than 20 in grades K-3. In the first year, the Legislature appropriated close to $1 billion for ongoing operational funds and one-time facilities funds; in the current year, more than $1.5 billion is available. Overall, 98% of school districts participated by the end of the second year, with 84% of K-3 pupils in smaller classes. The districts received an allotment (~$800) for each pupil in a smaller class for full-day instruction, and they could apply for a one-time grant of ~$25,000 for each new classroom.
Unfortunately, along with its educational benefits, the CSR program created a sudden and huge demand for classroom space. The program prompted the use of thousands of portables and widespread renovation of school facilities to augment classroom numbers. The demand rapidly exhausted available inventories of State-lease relocatable classrooms, and most school districts were forced to instead try to very quickly obtain relocatable classrooms directly from manufacturers. This created a backlog of orders and put great strain on districts and suppliers. In addition, many schools resorted to creating needed "new" classrooms by subdividing larger classrooms or remodeling rooms designed for another purpose into classrooms.
When the program began, school districts were not provided adequate guidance, specifications or on-site review by authorities, such as DSA or OPSC, for the purchase, installation or operation of these relocatable units. With relocatable classrooms being sold (or leased) at a record rate, units are being installed and "commissioned" directly into use. This did not provide adequate time for construction materials, paints, carpets or furnishings to off-gas hazardous chemicals, such as formaldehyde. Several districts have reported significant health problems in their new relocatable or newly renovated classrooms.
In January 1997, an Advisory on Relocatable and Renovated Classroom was produced by this committee and made available to schools districts. The document gave information and advice on a limited number topics, including design, construction, installation, and maintenance considerations. Key concerns address problems of odors and chemical fumes from new building materials, potential deficiencies in "package" HVAC systems, and relocatable classroom siting problems.
The State Legislative Analyst Office (LAO) prepared a policy brief on the CSR program in February 1997. It documented that most of nearly 20,000 new classrooms for CSR were created by installing relocatables (56%), converting non-classroom (8%), or splitting classrooms (8%) use. The LAO was concerned that future CSR classroom creation will be much more expensive, because districts have fewer options for creating new classroom than they did in the early years of the program. Among other recommendations, it proposed that districts should be given more flexibility in attaining the 20:1 pupil-to-teacher
cap.
Notwithstanding the LAO report, there has not been any effort yet to monitor or assess the impacts on IEQ of the large numbers of relocatable and renovated classrooms. However, past experience has shown that, when proper design and care are not applied, IEQ problems can become endemic to relocatable and renovated classrooms.
One of the ramifications of school building neglect and its consequent adverse effects on IEQ is the potential for litigation from students, parents, and/or staff. Crisis stage IEQ problems can be extremely costly, litigious, and detrimental to long-term relations among school administrators, staff, parents, students and public agencies. The costs -- fiscal, political, and social -- of addressing a crisis situation are often far larger than anticipated. Schools may close, and students and staff may miss days of school, when a formerly manageable problem becomes a financial, logistic, and emotional crisis. Besides the costs of conducting emergency repairs, a school closing requires alternative space and making up of missed classes. Re-opening schools that have been closed is also a difficult process, due to the logistics of inspections, the uncertainties of authority, and the residual fears.
Unresolved IEQ problems can politicize parents, polarize communities, and create a rift between school administrator and their teachers. A series of articles in the San Jose Mercury News chronicled the growing tensions evolving from an initial health problem reported by a parent volunteer in a Cupertino elementary school portable classroom. The incident lead to petitions to the school board, investigation by a paid consultant, removal of the portables, and the "beginning of special attention to environmental problems in the school" by facilities management staff. While similar incidents are repeated district by district, with no central agency to assess or record the conditions of classrooms, state of repair of HVAC systems, or the reporting and resolution of facility problems, poor IEQ in California schools remains a masked problem.
The trends of increasing IEQ problems, recognition of adverse health effects from indoor air exposures, and the litigious nature of societal interactions warn that poor IEQ in California schools can threaten the
financial stability of local school districts. An unknown number of lawsuits have been filed against California school districts. After complaints, investigations, and legal actions spanning more than three years, a student in Yucaipa received a cash settlement for damages from "contaminated air" in his junior high school classroom. At the same time, a third of the school staff filed workers’ compensation claims for respiratory and other health problems. In other states, lawsuits have been settled for millions of dollars. In a school district in Washington, D.C., leaky school roofs and other IEQ problems prompted a judge to order closed 21 school buildings, due to the resultant potential fire hazard. It is clear that there are many less publicized cases for each incident that makes the evening news or is adjudicated in court.
Current evidence shows that (i) school facilities throughout the State have suffered protracted neglect, disrepair, and poor IEQ; (ii) many of these problems are due to a combination of limited resources, inadequate training of school staff in IEQ, and diffuse authority for proper facilities design and maintenance; (iii) increasing student populations will further stress facilities and generate the need for more construction and renovation of public schools, and (iv) continued neglect will have considerable health, educational, and financial costs to the children, school staff and citizens of California. After reviewing the available information and current administrative programs, the CIWG-IAQ committee developed the following sets of recommendations to start to address the current situation. These recommendations are proposed to initiate corrective change in public health policy and programs associated with the California school environment.
- A. Authorize centralized oversight of public school IEQ using existing State agencies to carry out review of school HVAC design, routine surveillance of maintenance programs, and effective training of school staff to address IEQ issues.
- B. Develop stronger incentives for school districts to fully address the prevention and mitigation of current IEQ problems in a timely manner, and provide resources for preventative (not "deferred"), scheduled maintenance of school facilities.
- C. Mandate a full investigation of the nature of statewide IEQ problems, with findings and recommendations to be reported to the Legislature, CDE, and to school facility authorities.
- D. Ensure adequate funding, resources and staff for the above programs.
Furthermore, a set of Guiding Principles -- a Bill of Environmental Quality Rights for California Public School Students and Staff -- should be developed and adopted (see Postscript below).
The CIWG-IAQ committee recommends that specific measures be considered by Statewide policy makers, CDE and other agencies, and local school districts. It is beyond the scope of this report to calculate the total costs of corrective actions to address California school IEQ. While they are potentially high, many no-cost and low-cost approaches are available. We recognize that further analysis will be required as the next steps to determine the necessary funding and staff resources, to identify the appropriate agencies, and to establish priorities for these measures.
To Statewide Policy Makers:
- 1. Provide resources for DGS’ Division of the State Architect to review HVAC systems and IEQ concerns in all public school facility design and construction.
- 2. Authorize further investigation of the extent and severity of IEQ problems, the impact of these problems on students’, teachers’ and employees’ health, and the need for additional mitigation actions in California public
schools, in a report addressed to the legislature. - 3. Develop central authority to be responsible for the regulation and review of school IEQ performance, and to maintain a central registry of school facilities, status, maintenance programs, and IEQ incidents.
- 4. Require an IEQ management plan for every school district, with development of a facility operation and maintenance plan for each school site.
- 5. Remodel the existing Deferred Maintenance program into a Preventive Maintenance program, to discourage schools from putting off routine and timely maintenance and inspections. Possible revisions might include augmenting eligibility of funds to promote proper routine maintenance and inspections of school facilities.
To CDE and Other Agencies:
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- Better monitor design, construction, operations and maintenance standards and regulations with particular emphasis on portable classrooms and room ventilation.
- Develop a standardized IEQ inspection (audit) program for school construction and building commissioning.
- Require each school to maintain an inspection/maintenance/repair log for all indoor environmental systems, including HVAC systems.
- Establish emergency protocols to identify and mitigate water/moisture problems at school facilities.
- Require implementation of Integrated Pest Management (IPM) for all schools.
- Develop a set of training materials on IEQ (starting with U.S. EPA’s IAQ Tools for Schools Action Kit) for California school districts, and provide resources for related training and implementation.
- Develop an "IEQ Clearinghouse" that can provide technical support, guidance, and a statewide registry of IEQ problems and complaints in California schools.
- Establish a statewide IEQ-in-Schools resource/outreach group (a) to staff a telephone info/hotline to answer questions from school personnel about how to handle IEQ complaints and concerns; (b) to develop training materials and curriculum and to coordinate training courses for school facilities personnel; and (c) to operate an assistance program for site investigations.
To Local School Districts:
- Improve training in IEQ for school facilities personnel, with emphasison ventilation system operation and maintenance.
- Ensure that classrooms purchased or renovated as a consequence of the Class Size Reduction Program meet minimum ventilation standards and undergo IEQ inspections, and that relocatable units are designed and configured with consideration of occupant exposures to chemicals from building materials and/or furnishings (e.g., formaldehyde in pressed-wood products).
- Require training of facilities and safety personnel in IEQ management and of school nurses in IEQ health effects; provide means to educate administrators and school boards, as well as teachers, students and parents about school IEQ.
- Establish an IEQ complaint log/response system for staff and students.
- Provide a Right-to-know mechanism for parents to acquire IEQ information regarding public schools.
To address the IEQ issues raised in this memorandum, commitments of both resources and resolve are needed. Recent Class Size Reduction Program funding added an enormous number of new classrooms to California schools. Major bond measures have passed around the State in the past several years, and more will be voted on in the coming years. The federal School Construction Initiatives propose to help local communities and states rebuild the nation’s schools. Each of these programs is poised to infuse California school districts with much needed resources for its facilities. There needs to be technical guidance provided to help direct the best use of these resources for future improvements in the school facilities. Education professionals and public health officials need to better understand the nature of school IEQ problems and their solutions. Furthermore, in light of the magnitude of fiscal expenditures needed to repair the State’s public schools, it is imperative that assessment of mitigation programs be instituted.
If implemented, the measures recommended herein will result in a more responsive and effective system to address school IEQ problems in California. They will help to resolve the dilemmas of decentralization and deferred
maintenance and result in more proactive and cost-effective school facility programs. They can be expected to reduce the economic impacts and liability exposure to school districts and state and local government. Most importantly, they will serve to enhance the health and education of California’s school children.
POSTSCRIPT: DEVELOPMENT OF GUIDING PRINCIPLES
The "healthy" school is one which supports and optimizes the ability of students to learn and of teachers to instruct; it provides a safe and healthful site for the wide range of school activities. Good IEQ contributes to the sense of comfort, health and well-being for school occupants and substantially enhances a favorable learning environment. Along with high student test scores, healthy schools are viewed as assets to the community and an attraction for businesses and citizens to the community. They are both reflections and factors that impact the economic and social health of the community. The effort to sustain healthy schools can promote a sense of civic pride in students and school staff alike.
Healthy, safe and well-maintained school facilities give an important message to students about the values of the community in which they live, and how they are valued by the community. Efforts expended in achieving
good IEQ teach students, through example, that their community is concerned about children and has pride in itself and in them. It is prudent to remind ourselves "that which we honor best will grow best."
New York is among the a number of states to undertake a comprehensive review of school facilities. In 1995, Guiding Principles for school IEQ, developed by the New York State Regents Advisory Committee on Environmental Quality in Schools, were adopted by the Regents:
- Every child has a right to a safe and healthy learning environment that is clean and in good repair.
- Schools should serve as role models,particularly for students, for environmentally and socially responsible behavior Federal, State, local, and private sector entities should work together to ensure that resources are used effectively and efficiently to address environmental health and safety conditions.
- Every child, parent, and school employee has a "right-to-know" about environmental health issues and hazards in their school environment.
- School officials and appropriate public agencies should be held accountable for environmentally safe and healthy school facilities.
The CIWG-IAQ recommends the development of a set of guiding principles for a comprehensive, extensive and effective approach to school IEQ in California. Paraphrased from the Regents Report: "California students,
teachers and parents have a right to expect that school buildings are safe, healthy and comfortable and provide an environment that promotes learning and growing."
COMMITTEE ON INDOOR ENVIRONMENTAL QUALITY IN SCHOOLS
Ellen Aasletten, California Department of Education / Schools Facilities Planning Division
Amy Arcus, Office of Environmental Health Hazard Assessment / Air Toxicology & Epidemiology Section
David Berger, American Lung Association of Los Angeles County
Rachel Broadwin, Office of Environ. Health Hazard Assessment/ Air Toxicology & Epidemiology Section
Joan Daisey, Lawrence Berkeley Laboratory / Indoor Environment Program
Ken Dudash, San Bernardino Co. Superintendent of Schools Office / Inland Empire Schools Insurance Auth.
Louise Hill, U.S. EPA Region IX / Radon Program Coordinator
Peggy Jenkins, California Air Resources Board / Research Division
John Kaschak, California Department of General Services / Division of the State Architect
Elizabeth Katz, California Department of Health Services / Occupational Health Branch
Richard Lam, Office of Environ. Health Hazard Assessment / Air Toxicology & Epidemiology Section
Kai-Shen Liu, California Department of Health Services / Environmental Health Laboratory Branch
Janet Macher, California Department of Health Services / Environmental Health Laboratory Branch
Sandra McNeel, California Department of Health Services / Environmental Health Investigations Branch
Obed Odoemelam, California Energy Commission / Toxicology
Tom Phillips, California Air Resources Board / Research Division
Gary Pons, Los Angeles Unified School District / Business Services Division
Barbara Spark, U.S. EPA Region IX / Indoor Air Coordinator
Jed Waldman, California Department of Health Services / Environmental Health Laboratory Branch
Andy Yasenovsky, San Bernardino Co. Superintendent of Schools Office / Inland Empire Schools Ins. Auth.
Direct correspondences to the California Interagency Working Group on Indoor Air Quality to:
Jed M. Waldman, Ph.D. Phone: 510-540-3427
Chief, Indoor Air Quality Section FAX: 510-540-3022
California Department of Health Services E-mail: jwaldman@HW1.cahwnet.gov
2151 Berkeley Way, Berkeley, CA 94704
Disclaimer
The opinions expressed are the views of the authors; they do not necessarily reflect the official position of the affiliated authors’ agencies or organizations.
- AASA American Association of School Administrators
- AHERA Asbestos Hazard Emergency Response Act
- ASHRAE American Society of Heating, Refrigeration & Air-Conditioning
Engineers - BOMA Building Owners and Managers Association
- C or CA California
- Cal/OSHA California DIR Division of Occupational Safety and Health
- CDE California Department of Education
- CEC California Energy Commission
- CIWG-IAQ California Interagency Working Group on Indoor Air Quality
- CCR California Codes and Regulation
- CSR Class Size Reduction
- DGS Department of General Service
- DHS Department of Health Services
- DIR Department of Industrial Relations
- DSA Division of the State Architect
- GAO General Accounting Office
- HVAC Heating, ventilation, and air conditioning
- IEQ Indoor Environmental Quality
- IAQ Indoor Air Quality
- IPM Integrated Pest Management
- K-12 Kindergarten to 12th grade
- LAO Legislative Analyst Office
- OHB Occupational Health Branch
- OPSC Office of Public School Construction
- SAB State Allocations Board
- U.S. EPA Environmental Protection Agency
- VOCs Volatile Organic Compounds
