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

Other Major Safety Concerns

The list below denotes several prominent environmental safety issues that can occur in schools:

chlorofluorocarbons (CFCs)   emergency power systems   hazardous materials   integrated pest management   lead paint   mercury

personal protective equipment   polychlorinated biphenyls (PCBs)   radon   storm water runoff   underground storage tanks (USTs)

A brief description of each of these potential environmental problem areas follows. Additional information can be found at the U.S. EPA's main index page at http://www.epa.gov/ebtpages/alphabet.html.
 

Chlorofluorocarbons (CFCs) - The release of ozone-depleting compounds - such as chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), which are found in air conditioning and refrigeration equipment - should be minimized. School districts should ensure that all personnel servicing refrigerants are certified to do so and are using proper tools and equipment. Moreover, systems must be designed to include redundant valve settings as necessary to minimize the release of CFCs and HCFCs during routine maintenance.

Emergency Power Systems - Failure to protect the supply of power to school buildings can have both short- and long-term consequences-from damage to computers to school cancellations. One strategy for dealing with the possibility of power interruption is the installation of backup energy and power systems. This may mean installing large, multipurpose, on-site power generators for general use or smaller, portable uninterruptible power supplies (UPSs) for especially valuable equipment.

Hazardous Materials - The use and storage of hazardous materials is an important school facility management issue. Long-term exposure to chemicals (e.g., cleaning agents or reactants in chemistry labs) can cause serious health problems. Chemicals can also be fire hazards. Thus, all hazardous materials must be identified and catalogued for proper management (e.g., assigning disposal and storage responsibilities). The Emergency Planning and Community Right-to-Know Act of 1986 (EPCRA), sometimes referred to as SARA Title III, does not place limits on which chemicals can be stored, used, released, disposed, or transferred at a facility, but it does require the facility to document, notify, and report relevant information to occupants. Right-to-Know requirements affecting a school district include:

Whether chemicals are being used to meet custodial or instructional needs, decision-makers should investigate whether alternative, less toxic, supplies can be used. For example, "green experiments" and "microexperiments" (see http://www.epa.gov/
greenchemistry/ and http://www.seattle.battelle.org/services/e&s/P2LabMan/) can be substituted for traditional science lab experiments. In any case, hazardous materials must be handled with care (using gloves and goggles, as appropriate), ordered in quantities that minimize the accumulation of excess stock, and stored in flame-resistant, lockable, safety cabinets. In addition to storing hazardous materials safely, they must be disposed of in a way that is consistent with common sense and applicable local, state, and federal regulations. This decision is sometimes complicated by the degradation of certain hazardous materials, which can become an especially serious problem. (In one school in New England, the local bomb squad had to be called in to remove old, degraded ether from a chemistry lab.) Good record keeping of hazardous material use and supplies can minimize these types of occurrences.

For more information about hazardous materials management, visit the National Clearinghouse for Educational Facilities' Hazardous Materials resource list at http://www.edfacilities.org/rl/hazardous_materials.cfm, which provides a list of links, books, and journal articles about the identification, treatment, storage and removal of hazardous materials found in school buildings and grounds.

Integrated Pest Management (IPM) - Nearly every school will occasionally experience problems with pest infestation. An IPM program has the goal of eliminating or drastically reducing both pests and the use of toxic pesticides in schools. IPM is based on prevention, monitoring, and nontoxic pest control methods such as sanitation improvements, structural repairs, and mechanical, biological, behavioral, or other nonchemical initiatives. Rather than focusing on pesticide use, IPM aims to identify the conditions that foster pest problems and devise ways to change those conditions to prevent or discourage pest activity. These methods include modifying the environment to inhibit pest breeding, feeding, or habitat and using pest-resistant or pest-free varieties of seeds, plants, and trees. IPM strategies may also include changing the behavior of a building's occupants to help prevent problems-for example, occupant education that leads to decreased food waste and litter, improved cleaning practices, pest-proof waste disposal, and preventive structural maintenance.
 

The identification and use of "least toxic pesticides" becomes necessary when nontoxic methods of pest control have not completely addressed pest concerns. "Least toxic pesticides" include:

		boric acid and disodium octobrate tetrahydrate
		silica gels

		diatomaceous earth
		nonvolatile insect and rodent baits in tamper-resistant containers (or for crack and crevice treatment only)
		microbe-based pesticides
		pesticides made with essential oils (not including synthetic pyrethroids) and without toxic synergists
		materials for which the inert ingredients are nontoxic and disclosed

The term "least toxic pesticides" does not include any pesticide that:

		is determined by the U.S. EPA to be a possible, probable, or known carcinogen, mutagen, teratogen, reproductive toxin, developmental neurotoxin, endocrine disrupter, or immune system toxin;
		is in EPA's toxicity category I or II; or
		is applied using a broadcast spray, dusting, tenting, fogging, or baseboard spraying

Whenever a chemical agent (even a "least toxic pesticide") is used, staff should be instructed to apply it according to the instructions on the label without deviation. In some states, the axiom "the label is the law" applies.

Good practices for pesticide use include:

		requiring that all persons who apply pesticides and other pest control agents be licensed by the state or locality
		requiring that all persons who apply pesticides and other pest control agents renew their certification every three years to keep abreast of evolving technologies and standards
		notifying students, parents, and school staff prior to the application of pesticides in and around schools
		maintaining records of pesticide application for at least three years (more for longer-lasting agents such as termiticides). Records should include the application date, application site (be as specific as possible), pesticide brand name, pesticide formulation, EPA registration number, total application amount (strength, rate, and duration), and the name and identification number of the certified individual applying the pesticide.

Schools that choose to have their own staff apply pesticides should obtain a business license, which documents applicable local and state requirements for the certification of personnel and insurance protection.

For more information about pesticides and integrated pest management, visit www.beyondpesticides.org for summaries of the 33 state laws governing integrated pest management, pesticide restrictions, and right-to-know. Also, visit the National Clearinghouse for Educational Facilities' IPM resource list at http://www.edfacilities.org/rl/pests.cfm, which provides a list of links, books, and journal articles about the use of pesticides, integrated pest management guidelines, specifications, training, implementation and management in school buildings and grounds.

Lead Paint - Lead has been shown to have a detrimental impact on human health. Lead-based paint poses numerous health risks during its application, deterioration, and subsequent release into the air and water. When assessing a building for lead exposure, considerations include building age, facility use, and occupant age and activity. Results from dust, soil, and air sampling are also necessary for designing control strategies. Abatement options include the removal and replacement of affected parts (e.g., windows and doors covered with lead-based paints), stripping of paint (which, because of the associated health risks, must be performed by hazardous waste removal specialists), encapsulation, and enclosure. Actions must also be taken to ensure the appropriate handling and disposal of hazardous materials generated by lead-based paint removal.

Mercury - Mercury is a silver-colored heavy metal that is liquid at room temperature. A person can be exposed to mercury by breathing contaminated air, swallowing or eating contaminated water or food, or having skin contact with mercury. When liquid mercury is exposed to the atmosphere, it emits vapors that are dangerous to human health. At high doses, mercury exposure can cause a range of nervous system problems, including tremors, inability to walk, convulsions, and even death. At levels more commonly seen in the United States, the effects of mercury exposure are usually more subtle, although still potentially serious, and include damage to the senses and brain.
 

School organizations must be aware of their use of mercury and mercury-containing products and develop policies to ensure that students, staff, and other building occupants are protected from mercury exposure and mercury-related health risks. At a minimum, all mercury-containing equipment (e.g., fluorescent lights, mercury vapor lamps, metal halide lamps, high-pressure sodium lamps, neon lamps, light switches, relays, thermostat probes, thermometers, and laboratory solutions) should be handled according to universal hazardous waste protocols, including during disposal. Moreover, as mercury-containing equipment reaches the end of its useful life, it should be replaced with mercury-free alternatives. Most environmental experts recommend that schools adopt mercury-free purchasing policies, conduct mercury audits, and train teachers and staff to respond appropriately in the event of a mercury spill. Deficiencies in an employer's mercury management and training program that contribute to potential exposure can be cited by environmental and workplace authorities.

For more information about mercury, visit the EPA's mercury site at http://www.epa.gov/mercury/index.html.

Personal Protective Equipment - The personal protective equipment (PPE) program, as initiated by the Occupational Safety and Health Administration (OSHA), the Centers for Disease Control and Prevention (CDC), and many states, is intended to protect employees from the risk of injury and illness by creating a barrier against workplace hazards. In general terms, PPE requires employers to conduct an assessment of their workplace to identify environmental or safety hazards to which employees are exposed that require the use of protective equipment. Employers should have a written program to evaluate hazards, indicate appropriate control measures, provide (and pay for) protective equipment, train staff to use protective equipment properly, certify that such training has occurred, and hold yearly inspections and reviews to determine whether these efforts are preventing employee injury and illness. Deficiencies in personal protective equipment programs that lead to exposure, physical harm, or death can result in citations and monetary penalties.

For a more detailed description of PPE requirements, visit the OSHA PPE site at http://www.osha.gov/SLTC/personalprotectiveequipment/ or the CDC PPE site at http://www.cdc.gov/od/ohs/manual/pprotect.htm.

Polychlorinated Biphenyls (PCBs) - PCBs discharged into the environment pose a risk to humans and wildlife. In schools, PCB sources may include leaking fluorescent lights and electrical transformers. The use of PCB transformers near food or feed sources, or in commercial buildings (including schools), should be prohibited. Surveys must be performed to identify and remedy all potential sources of PCBs.

Radon - Radon is a naturally occurring gas that poses a danger to people if it accumulates in unventilated areas and is inhaled for long periods of time (potentially causing lung cancer). Airborne levels greater than 4 pCi/L are considered "high" and must be remedied. As part of a school's indoor air quality management, radon levels should be tested on a regular basis. Moreover, base levels for radon must be established for all buildings. Radon testers must be certified.

For more information about radon, visit the EPA's Radon resource list at http://www.epa.gov/iaq/radon.

For more information about playground safety, visit the National Clearinghouse for Educational Facilities' Playground Safety resource list at http://www.edfacilities.org/rl/playgrounds.cfm, which provides a list of links, books, and journal articles about playground design for varying age levels, including resources on safety, accessibility, equipment, surfaces, and maintenance.

Storm-Water Runoff - Storm-water runoff is water from rain or snow that runs off of streets, parking lots, construction sites, and residential or commercial property. It can carry sediment, oil, grease, toxics, pesticides, pathogens, and other pollutants into nearby streams and waterways. Once this polluted runoff enters the sewer system, it is discharged into local streams and waterways, creating a major threat to drinking water and recreational waters. To minimize such contamination, storm-water runoff standards have been established by the U.S. EPA, state, and local authorities.

For more information about storm water runoff, visit the EPA's Storm-Water Runoff regulations site at http://www.epa.gov/fedsite/cd/stormwater.html.

Underground Storage Tanks (USTs) - USTs have been a particularly high-profile environmental issue during the past few decades. Leaking USTs can contaminate groundwater and lead to the accumulation of potentially explosive gases. If USTs contain hazardous materials, both people and the environment can be threatened. Although each state defines USTs somewhat differently (e.g., some states consider commercial heating-oil tanks to be USTs), recommended practices for the use and disposal of any UST include:

		surveying for groundwater channels and reservoirs before selecting a site for UST installation
		considering UST abandonment strategies prior to finalizing installation decisions
		adjusting levels of scrutiny according to the type of liquid or gas to be stored (e.g., hazardous materials demand extra caution)
		instituting a precautionary testing program for all USTs (including tightness-testing, visual inspection by a certified inspector, and soil and groundwater surveying in the vicinity)
		maintaining original UST construction and installation records (and backup copies)
		maintaining detailed inventory records (e.g., percent filled, filling dates, and amounts)
		maintaining detailed records of testing and inspection results
		requiring product suppliers to notify the maintenance manager when new delivery people will be filling the UST so that their work can be reviewed for quality
		keeping a spill response kit on the premises at all times
		removing or sealing the UST according to applicable regulatory standards upon abandonment or discontinued use

Ensuring School Safety Requires Avoiding "The Dirty Dozen" of Playground Safety 1. Improper protective surfacing - The surface or ground under and around playground equipment should be soft enough to cushion a fall. Improper surfacing material under playground equipment is the leading cause of playground-related injuries. Hard surfaces such as concrete, blacktop, packed earth, or grass are not acceptable in fall zones. In fact, a fall onto one of these hard surfaces could be life-threatening. Acceptable surfaces include hardwood fiber, mulch, sand, and pea gravel. These surfaces must be maintained at a depth of 12 inches, kept free of standing water and debris, and prevented from becoming compacted through routine maintenance efforts. Synthetic or rubber tiles and mats also are appropriate for use under play equipment. 2. Inadequate fall zone - A "fall zone" or "use zone" is the area around and beneath playground equipment where a child might fall. A fall zone should be covered with protective surfacing material and extend a minimum of 6 feet in all directions from the edge of stationary play equipment such as climbers and chin-up bars. The fall zone at the bottom or exit area of a slide should extend a minimum of 6 feet from the end of the slide for slides 4 feet or less in height. For slides higher than 4 feet, add 4 feet to the entrance height of the slide to determine how far the surfacing should extend from the end of the slide. Swings require a much larger fall zone. It should extend twice the height of the pivot or swing hanger in front of and behind the swings' seats. It should also extend 6 feet to the side of the support structure. 3. Protrusion and entanglement hazards - A protrusion hazard is a piece of hardware that might be capable of impaling or cutting a child if a child should fall against it. Some protrusions also are capable of catching strings or items of clothing, causing entanglement that could result in strangulation. Examples of protrusion and entanglement hazards include bolt ends that extend more than two threads beyond the face of the nut, hardware configurations that form a hook or leave a gap or space between components, and open "S"-type hooks. Rungs or handholds that protrude outward from a support structure may be capable of causing eye injury. Special attention should be paid to the area at the top of slides and sliding devices. Ropes should be anchored securely at both ends and not be capable of forming a loop or a noose. 4. Entrapment in openings - Enclosed openings on playground equipment must be checked for head entrapment hazards. Children often enter openings feet first and attempt to slide through the opening. If the opening is not large enough it may allow the body to pass through the opening and trap the head. Thus, no openings on playground equipment should measure between 3 1/2 inches and 9 inches in diameter. 5. Insufficient equipment spacing - Improper spacing between pieces of play equipment can cause overcrowding of a play area, which may create hazards. Fall zones for equipment that is higher than 24 inches above the ground cannot overlap. Therefore, there should be a minimum of 12 feet between two play structures to provide room for children to circulate and prevent the possibility of a child falling off one structure and striking another. Swings and other pieces of moving equipment should be located in an area away from other structures. 6. Trip hazards - Tripping hazards are created by play structure components (or other items) on the playground. Exposed concrete footings, abrupt changes in surface elevations, containment borders, tree roots, tree stumps, and rocks are all common tripping hazards that are found in or near play equipment. 7. Lack of supervision - Playground supervision directly relates to the overall safety of the environment. A play area should be designed so that it is easy for a caregiver to observe children at play. 8. Age-inappropriate activities - Children's developmental needs vary greatly from age 2 to age 12. In an effort to provide a challenging and safe play environment for all ages, playground equipment must be appropriate for the age of the intended user. Areas for preschool-age children should be separate from areas intended for school-age children. 9. Lack of maintenance - A systematic preventive maintenance program is required to keep playgrounds in "safe" condition. There should not be missing, broken, or worn-out components, and all hardware should be secure. The wood, metal, or plastic should not show signs of fatigue or deterioration. All parts should be stable, without apparent signs of loosening. The surfacing material also must be maintained, and signs of vandalism should be noted, remedied, and subsequently monitored. 10. Pinch, crush, shearing, and sharp-edge hazards - Components in the play equipment should be inspected to make sure there are no sharp edges or points that could cut skin. Moving components such as suspension bridges, track rides, merry-go-rounds, seesaws, and some swings should be checked to make sure that there are no moving parts or mechanisms that might crush or pinch a child's finger. 11. Platforms without guardrails - Elevated surfaces such as platforms, ramps, and bridgeways should have guardrails that will prevent accidental falls. Equipment intended for preschool-age children should have guardrails on any elevated surface higher than 20 inches. Equipment intended for school-age children should have guardrails on elevated surfaces higher than 30 inches. 12. Equipment not recommended for the public - Accidents associated with the following equipment have resulted in the Consumer Product Safety Commission recommending that they not be used in playgrounds:   heavy swings (such as animal-figure swings) and multiple-occupancy glider-type swings;   free-swinging ropes that may fray or form a loop;   swinging exercise rings and trapeze bars that are considered to be athletic equipment and, therefore, are not recommended for public playgrounds. Overhead hanging rings with short chains (generally four to eight rings) are acceptable on public playground equipment. To receive a copy of "The Dirty Dozen" brochure, send a request, along with a self-addressed, stamped envelope, to the National Playground Safety Institute, 22377 Belmont Ridge Road, Ashburn, VA 20148. * Pressure-treated wood is another important concern for outdoor facilities. While it lasts longer than untreated wood, it can release chemical contaminants (including arsenic) that make the area dangerous for children and adults. Thus, the use of treated wood should be phased out in the school setting. When pressure-treated wood is removed from the playground, both the wood and the soil or sand on which it rested should be removed because of the likelihood of soil contamination. Adapted from the National Playground Safety Institute, a program of the National Recreation & Park Association (http://www.uni.edu/playground/about.html).

Environmentally Friendly Schools

There is a growing emphasis on creating environmentally friendly school buildings, sometimes referred to as "green schools," "sustainable schools," or "high-performance schools." The term "environmentally friendly" was once considered to be synonymous with both higher initial costs and higher operating costs. However, this assumption is no longer valid. School buildings and budgets can benefit immensely from the "green" concept when properly applied. This goal is best accomplished by emphasizing long-term, sustainable systems, including the concept of building life-cycle costs (i.e., the total cost of acquisition and ownership of a building or system over its useful life, including capital costs, energy costs, and maintenance and operating costs).

The sustainable high-performance school concept seeks to introduce a comprehensive environmental approach to all aspects of school design, construction, operations, and maintenance. The benefits include:

		improved occupant health, motivation, and productivity
		improved flexibility when designing facilities
		reduced energy use, water use, maintenance costs, insurance costs, and operation costs

The U.S. Green Building Council (http://www.usgbc.org) provides evaluation tools through the Leadership in Energy and Environmental Design (LEED) initiative. LEED is an assessment system designed for rating new and existing buildings. It evaluates environmental performance from a "whole building" perspective over the building's entire life cycle, and provides a definitive standard for what constitutes a "green" building. LEED is based on accepted energy and environmental principles and strikes a balance between proven effective practices and emerging concepts.