Sensible Guide for 

Healthier School Renovations

Key Environmental Health Considerations 

When Renovating Schools
2

Keep Kids Safe During School Renovations.............. 1

Protect Indoor Air Quality 

During School Renovations .................................. 2-3

Asbestos ............................................................. 4-5

Mold ................................................................... 6-7

Vapor Intrusion.................................................... 8-9

Hazardous Materials and Mercury .................... 10-11

Lead Based Paint............................................. 12-13

Polychlorinated Biphenyls (PCBs)..................... 14-15

Radon .................................................................. 16

Construction and Demolition ................................. 17

Top Ten Things to Know ........................................ 18

References and Resources............................... 19-20

Contents
1

Keep Kids Safe During 

School Renovations

School renovations have the potential 

to increase children’s exposures to harmful 

contaminants which can lead to serious health risks. 

Addressing the unique challenges and opportunities 

of school renovation proactively can help the school 

save money and support student performance. 

School environments play an important role in the 

health and academic success of children. Children 

spend 90% of their time indoors and much of 

that time is spent in school. Recent surveys report 

that 53% of public schools need to spend money 

on repairs, renovations, and modernization – at an 

estimated overall cost of $197 billion, Institute of 

Education Sciences, Condition of America’s Public School 

Facilities: 2012-2013. Indoor environmental quality 

can be compromised during school renovations, 

potentially exposing building occupants to 

damaging hazardous airborne chemicals (indoor air 

contaminants). Common indoor air contaminants 

include asbestos, lead, mold, radon, and 

polychlorinated biphenyls (PCBs). Dermal contact 

or incidental ingestion may also be significant 

exposure pathways for chemicals (e.g., PCBs or lead) 

contained in building materials 

or construction debris.

Children are especially susceptible to the damaging 

effects of environmental hazards. A child’s 

developing biological systems are often more 

sensitive to environmental stressors, and children are 

frequently more heavily exposed to toxic substances 

in the environment than are adults. Children in 

minority, low-income, and other underserved 

populations, as well as children with disabilities, 

can experience higher exposures to multiple 

environmental contaminants where they live, learn, 

and play, and may be at a disproportionate risk for 

associated health effects.

Healthy school environments play an important 

role in the health and academic success of children. 

Exposure to environmental hazards in schools can 

negatively impact the health of students and school 

staff. Unhealthy school environments can also affect 

attendance, concentration, and performance, as well 

as lead to expensive, time-consuming cleanup and 

remediation activities.

During school renovations it’s important to be 

aware of potential environmental hazards and 

know the best practices for healthy and sustainable 

schools. It is also an opportunity to evaluate 

hazardous materials storage, become more energyefficient, integrate pest management by design, and 

incorporate green building practices.

This booklet provides school administrators, facility 

managers, staff and the school community with an 

overview of how to avoid key environmental health 

hazards and ways to minimize children’s exposures 

as they prepare for and undergo renovations. School 

renovations should be consistent with applicable 

local, state and federal environmental health 

regulations. More in-depth guidance on all of these 

risks has been developed by EPA, state agencies, 

and other organizations. School administrators, 

facility managers, and staff should reference the 

information in this booklet and resources listed 

on pages 19-20 to plan and conduct healthier school 

renovations.
2

Protect Indoor Air Quality

Good indoor air quality (IAQ) in schools is a critical 

component of a healthy and comfortable learning 

environment. IAQ affects the health, productivity, 

performance, and comfort of students, teachers 

and staff.

When there is poor IAQ in a school building, students 

and staff may suffer from common symptoms of 

respiratory infections and allergic or other adverse 

health reactions. Renovations may significantly 

alter the IAQ of a school building. IAQ topics 

are particularly relevant for renovation projects and 

present unique challenges. Some of the IAQ issues 

related to construction activities include the presence 

of asbestos, mold, radon, vapor intrusion, lead and 

PCBs. These require planning during the design 

phase and special precautions during the execution 

phase of a renovation or construction project.

IAQ Issues during 

Construction Activities

Construction dust and materials such as adhesives, 

paints, and sealants have the potential to degrade 

IAQ. Poor IAQ increases the risk of developing 

health problems that affect the overall performance 

of students or staff. It is a best management practice 

to conduct construction activities outside of the 

school year whenever possible to reduce impacts 

to students and staff. However, when construction 

activities must be conducted during the school 

year, developing and implementing an IAQ plan 

can help protect the building inhabitants’ health 

by preventing exposure to hazardous chemicals. 

Communication with building occupants is essential 

for reducing impacts. Communication should begin 

during the planning phase of any construction 

activities and should continue through the project’s 

completion. Refer to EPA’s IAQ Design Tools for Schools

website for additional details on IAQ Plans.

Integrating indoor air quality protections and energy efficiency improvements

EPA’s Energy Savings Plus Health IAQ Guidelines for School 

Building Upgrades provides specific assessment protocols 

and recommendations for protecting and even enhancing IAQ 

during school energy efficiency retrofits and other building 

upgrade projects.

http://www2.epa.gov/iaq-schools/indoor-air-quality-designtools-schools 

Download EPA’s School IAQ Assessment mobile app

to keep IAQ on track before, during and after school 

building upgrades.

Protect Indoor Air Quality 
3

Construction Dust

Construction activities generate a lot of dust 

that may contain hazardous chemicals. Exposure 

to construction dust can irritate the eyes and 

nose, causing immediate health effects, and may 

also trigger asthma attacks in students and staff. 

Reducing the amount of dust in the air by sealing 

off areas (particularly ductwork) with plastic sheeting, 

ensuring adequate ventilation, and using highefficiency particulate air (HEPA) filtration attached 

to dust-generating equipment will protect the health 

and comfort of building occupants and may reduce 

the risk of asthma attacks. Other best practices 

include cleaning up at the end of the workday and 

having a separate outdoor staging area for activities 

that generate dust, such as sawing and sanding.

Construction Materials

New building materials should meet building design 

specifications and be in compliance with applicable 

federal, state, local regulations and building codes. 

Verifying product content/labels is particularly 

important, especially when building materials are 

imported from other countries that may not have 

as stringent specifications (e.g., asbestos containing 

building materials are still manufactured and used in 

other countries). Schools should strive to ensure that 

quality building materials are installed and potential 

IAQ issues are avoided by selecting low-toxicity, 

lowemitting, moisture-resistant materials during 

renovation design. 

Construction materials such as adhesives, paints, 

or sealants can volatilize as they dry or cure, 

contributing to indoor air quality issues. Properly 

ventilating areas where these construction materials 

are used and stored, and promptly cleaning up any 

spills, can reduce impacts. In addition, construction 

materials should be staged away from classrooms 

and heating, ventilation, and air conditioning 

(HVAC) intakes during renovations. Care should 

also be taken to protect materials from moisture and 

humidity to avoid introducing potential hazards 

such as mold. 

Equipment and 

Vehicle Emissions

Emissions from diesel- or gas-powered construction 

equipment can impact the health and comfort 

of students and staff near the construction site. 

Exposure to these emissions may cause symptoms 

such as headache, nausea, coughing, difficulty 

breathing, or irritation of the eyes, nose, and throat. 

Diesel- or gas-powered equipment should be stored 

and operated away from classrooms, HVAC intakes, 

doors and windows, and playground/sporting areas. 

If possible, use newer or retrofitted equipment and 

limit engine idling.

Best Management Practices:

✔ Plan ahead to maintain good indoor air 

quality during renovations.

✔ Reduce potential exposure to construction 

dust by sealing off work areas from nonconstruction workers, using equipment 

with HEPA filters, and frequently cleaning 

work areas.

✔ Select staging areas for construction 

materials, equipment, and vehicles away from 

classrooms and HVAC intake.

✔ Review product labels and product 

specification sheets to verify content. When 

in doubt, ask the manufacturer to verify 

contents or lack thereof.

During School Renovations
4

Know the risks

Asbestos is a mineral fiber that naturally occurs in 

rock and soil. Because of its fiber strength and heat 

resistance, asbestos has been used in a variety of 

building construction materials for insulation and 

as a fire retardant.

When asbestos containing material (ACM) is in 

good, non-friable condition (meaning it cannot be 

crumbled, pulverized, or reduced to powder by hand 

pressure), emission of asbestos fibers from ACM 

to air generally does not occur. As the condition 

of ACM deteriorates or renovation activities disturb 

ACM, asbestos fibers can be released into air. 

Asbestos fibers can stay suspended for hours and 

up to days, creating an exposure risk. Exposure 

to airborne asbestos fibers can cause serious health 

issues and may lead to asbestosis, mesothelioma, or 

lung cancer. Other cancers, primarily of the digestive 

tract, are also possible.

Know the regulations

Building materials with greater than one percent 

asbestos are considered ACM and are subject to 

federal and state regulations. 

EPA regulations include:

• The Toxic Substances Control Act (TSCA)

• Asbestos Hazard Emergency Response 

Act (AHERA)

• Asbestos Model Accreditation Plan

• Asbestos National Emission Standard for 

Hazardous Air Pollutants (Asbestos NESHAP) 

Know where to find ACM

in Schools

ACM is commonly found in:

• Insulation • Floor tiles and mastic 

• Adhesives • Roofing 

• Millboard • Acoustic ceiling tiles

• Textured paint • Caulking

• Cement sheets/board • Quick-set cement

• Joint/patching compounds

Asbestos
5

Know how to prevent exposure

The NESHAP regulations under the Clean Air Act 

specify work practices for asbestos to be followed 

during school renovations. The regulations require 

the school to notify the appropriate state agency 

before any demolition or renovations of buildings 

that could contain a certain threshold amount of ACM. 

Under AHERA, schools are required to perform an 

inspection to determine whether ACM are present 

and re-inspect ACM every three years. Schools 

are required to develop an asbestos management 

plan (AMP) and designate a person responsible 

for implementing the AMP. Refer to EPA website 

Asbestos in School Buildings and EPA Document 

Model AHERA Asbestos Management Plan for further 

information on drafting an AMP.

When school renovation projects involve ACM, 

special procedures must be performed by licensed 

and trained asbestos abatement professionals. 

Special containment, equipment, and disposal 

procedures are also required. 

Additional, more stringent local and state regulations 

may also apply during renovations when ACM is 

disturbed (e.g., Occupational Health and Safety 

Administration (OSHA) Safety and Health 

Regulations for Construction).

Best Management Practices:

✔ Include the school’s AHERA designated 

person in communications during the design 

phase of renovation projects to ensure ACM 

is properly addressed and no new ACM is 

utilized (e.g., thermal system insulation).

✔ Review the AMP and ACM reports to ensure 

that ACM remains untouched or proper 

ACM abatement procedures are included in 

the design.

✔ When deciding how to address ACM 

during renovations, consider the impact 

to the renovation budget, long-term costs, 

and asbestos management responsibilities 

associated with each alternative. 

✔ Set a project schedule so that asbestos 

abatement occurs outside of the school year 

or during holiday breaks.

✔ Communicate and coordinate with the 

project manager and site manager during 

asbestos abatement and renovation projects.

✔ Be sure to request and review the final air 

clearance sampling results prior to allowing 

students and staff to re-occupy the affected 

area after asbestos abatement.
6

Know the risks

There are several thousand different species of 

molds. They can grow on virtually any organic 

substance, as long as moisture and oxygen are 

present. There are molds that can grow on wood, 

paper, carpet, foods, and insulation. 

All molds have the potential to cause health effects 

that may include irritation of the eyes, skin, nose, 

throat, and lungs. Molds can trigger allergic reactions 

or even asthma attacks in people allergic to mold. 

Some molds are known to produce potent toxins 

or chemical irritants. 

Know where to find mold

Molds grow best in damp and humid conditions. 

They spread by releasing spores. When excessive 

moisture accumulates in buildings or on building 

materials, mold growth often occurs, particularly 

if the moisture problem remains undiscovered 

or unaddressed. It is impossible to eliminate all 

mold and mold spores in the indoor environment. 

However, mold growth can be controlled indoors 

by controlling moisture.

The key to controlling mold is removing the 

source(s) of moisture that caused the mold issue in 

the first place. Check for humidity and condensation 

problems as well as actual water leaks, maintenance 

issues, and HVAC system problems. Fix any issues 

that are identified.

Know how to identify and 

cleanup mold

No EPA or other federal agency threshold limits 

have been set for mold or mold spores. Mold is 

generally identified with visual inspection or by 

smell, but sampling can be done to determine 

the source(s) of the mold contamination and 

the specific mold present. Analytical methods 

recommended by the American Industrial Hygiene 

Association (AIHA) or the American Conference of 

Governmental Industrial Hygienists (ACGIH) should be 

used to identify mold.

The steps needed to clean up mold vary based on 

the magnitude and surface area of mold growth. 

A more cautious or conservative approach to 

remediation is warranted in cases where:

• a particularly toxic mold species has been 

identified or is suspected;

• when extensive hidden mold is expected (such as 

behind vinyl wallpaper or in the HVAC system); 

• when the chances of the mold becoming airborne 

are estimated to be high; or

• sensitive individuals (e.g., those with severe 

allergies or asthma) are present.

Mold
7

If the affected area is small or less than 10 square 

feet, small-scale mold remediation efforts may 

include cleaning or limited building material 

removal and replacement. Always use personal 

protective equipment (PPE) including gloves and 

eye protection when working with mold. Additional 

PPE such as N-95 respirators or respirators with 

HEPA filters may also be necessary to ensure 

compliance with OSHA standards. Building 

occupants should be isolated from the affected 

area by setting up containment areas with proper 

ventilation when mold remediation is underway. 

Know how to prevent exposure

Renovation projects may have to tackle existing 

mold issues (known or hidden) and include mold 

remediation. A key objective of any renovation 

should be to maintain proper moisture control after 

renovations are complete. Thus, the renovation 

design should include proper construction 

techniques and building materials to prevent future 

moisture problems. Renovation design specifications 

need to address:

• moisture control issues related to surface water 

drainage;

• foundation construction/repair; 

• wall construction; 

• roof and ceiling assembly; 

• plumbing system installation/repairs; and 

• HVAC system installation/modifications.

Best Management Practices:

✔ When moisture problems are found, 

promptly initiate repairs to minimize 

mold growth.

✔ If the extent of the mold issue is severe 

and a more time-critical removal (with 

containment) is needed, consider removing 

mold outside of school hours, during 

evenings or weekends, if it cannot be delayed 

to summer or a holiday break.

✔ Do not paint or caulk over surfaces that 

have mold.

✔ Maintain proper moisture control after 

renovations are complete.
8

Know the risks

Vapor intrusion generally occurs when changes in 

pressure and/or temperature cause a chemical to 

evaporate in the underground environment and 

penetrate buildings by migrating through subsurface 

soil and into cracks of the building’s foundation 

slab. Chemicals that may cause IAQ issues through 

vapor intrusion are primarily from a category of 

compounds known as volatile organic compounds 

(VOCs). Semi-volatile organic compounds or 

inorganic chemicals (e.g. mercury) may also volatilize 

and present an IAQ issue. In rare cases, the vapors 

may accumulate in occupied buildings to levels that 

may pose immediate safety hazards (e.g., explosion), 

acute health effects, or odors. However, in most 

cases, vapor concentrations are low and the main 

concern is whether the volatile chemical(s) pose 

an unacceptable risk of developing chronic health 

effects due to long-term exposure at these low levels. 

Chronic health effect(s) vary based on the specific 

volatile chemical, but typically carcinogenic effects 

and/or non-carcinogenic effects are risks associated 

with prolonged exposure to volatile chemicals. For 

example, leukemia and decreased white blood cell 

count are the health effects associated with chronic 

benzene exposure. 

Know where to find vapors

There must be a source of contamination in soil 

or groundwater near the school in order for a vapor 

intrusion issue to exist. EPA considers soil 

or groundwater contamination within 100 feet of 

a school building to be a potential source for vapor 

intrusion (see EPA source). A potential source could 

be a former leaking underground storage tank 

that resulted in contaminated groundwater within 

100 feet of a school building. A review of the 

current and historical land use in the vicinity of 

the school will help identify if there is a potential 

source for vapor intrusion. If a suspected source 

is identified, often, a seasonal vapor intrusion 

evaluation (including sampling and analysis) is 

needed to confirm the presence or absence of 

volatile chemicals. Groundwater, soil gas, ambient 

air, and indoor air- samples may be collected 

by a trained professional and sent to a certified 

analytical laboratory for analysis. The sample results 

are compared to chemical-specific action levels 

(under EPA and/or state regulations and guidance, 

depending on the situation) to determine if source 

removal, cleanup, or vapor intrusion mitigation 

systems are needed. Vapor intrusion mitigation 

methods may include sealing openings (filling 

in cracks in the floor slab and gaps), installing 

vapor barriers, passive venting, installing sub-slab 

depressurization, or adjusting a building’s HVAC 

system to over-pressurize the building.

Know how to prevent exposure

Vapor intrusion is an important consideration when 

planning a renovation. First, if a renovation project 

includes expansion of the school it is important 

to perform due diligence and verify that there are 

no potential sources of vapor intrusion on the land 

where the expansion is set to occur. Second, if 

the renovation project includes an existing school 

building that has a vapor intrusion issue, then 

mitigation methods need to be incorporated into 

the renovation design or the current vapor intrusion 

mitigation system(s) should remain in place.

Vapor Intrusion
9

Best Management Practices:

✔ Review land use records, typically available at 

city and county offices, to determine potential 

sources for vapor intrusion, especially when 

considering school expansion projects.

✔ Maintain a library with any vapor intrusion 

evaluation reports, vapor intrusion mitigation 

systems construction reports, and vapor 

intrusion mitigation systems operation and 

maintenance (O&M) reports for future 

reference.

✔ Be actively involved in the renovation design 

phase when there is an existing vapor

intrusion issue, and ensure that the renovation

designs incorporate adequate vapor intrusion 

mitigation methods or leave the current vapor 

intrusion mitigation systems in place.

✔ Vapor intrusion can be a highly complex 

issue and challenging to address. Reach out to 

available EPA and state resources with questions 

and concerns regarding vapor intrusion, such as 

the EPA Vapor Intrusion website.

Vapors Rise 

Through Soil

Soil

Contaminated 

Groundwater

Clean Groundwater

How Vapor Intrusion Works
10

Know the risks

Hazardous materials, such as glues, sealants, acids, 

bases, oxidizers, compressed gases, flammable 

solvents, and mercury can often be found in schools. 

During renovation activities, these hazardous 

materials may need to be cleaned out or relocated. 

Improper disposal, spills and other accidents can 

pose health and safety risks to students and staff 

as well as incur considerable expenses, including 

potential liabilities/lawsuits. Hazardous materials 

and chemicals are associated with a variety of 

serious health problems, including cancer, brain and 

nervous system disorders, reproductive disorders, 

organ damage, and asthma. Chemicals also can 

irritate the skin, eyes, nose and throat. Some 

chemicals pose significant physical safety hazards, 

such as fire or explosion risks.

Mercury is a hazardous chemical of particular 

concern because the nervous system is very sensitive 

to all forms of mercury. Exposure to high levels 

of metallic, inorganic, or organic mercury can 

permanently damage the brain and kidneys. Effects 

on brain functioning may result in irritability, 

shyness, tremors, changes in vision or hearing, and 

memory problems. Short-term exposure to high 

levels of metallic mercury vapors may cause lung 

damage, nausea, vomiting, diarrhea, increased 

blood pressure or heart rate, skin rashes, and/or 

eye irritation.

Know the regulations

Hazardous materials and chemicals may need to be 

managed and disposed of as hazardous waste under 

Resource Conservation and Recovery Act (RCRA) 

or state regulations. Refer to EPA’s Schools: Chemical 

Management Regulation webpage for additional 

information. Specifically, mercury wastes must 

be properly managed and disposed of if it meets 

the toxicity characteristics of RCRA hazardous 

waste. Mercury-containing batteries, thermostats, 

and lamps are managed under the Universal Waste 

Program, provided the state does not regulate the 

wastes more stringently. 

Know where to find hazardous 

materials and mercury

Hazardous materials may be found in science 

laboratories or classrooms, art classrooms, shop or 

mechanic classrooms, or maintenance closets. 

Some materials containing mercury may be found 

throughout school buildings and some common 

sources of mercury in schools include:

• Glass thermometers

• Fluorescent (CFL) lamps and light bulbs 

• Science equipment

• Thermostats, switches, and other electrical devices

Hazardous Materials 

and Mercury
11

Best Management Practices:

✔ Establish a chemical management program 

for preventing and/or controlling a variety of 

health and safety hazards in schools. 

✔ Ensure all chemicals are properly labeled and 

stored before renovations begin. Ensure that 

OSHA materials safety data sheets (MSDS) 

for each product are readily displayed near 

chemical storage areas.

✔ Renovation provides an opportunity for 

schools to remove inappropriate, outdated, 

unknown and unnecessary chemicals from 

schools. EPA’s Schools: Chemical Management 

Regulation webpage provides the tools to 

successfully implement a cleanout. 

✔ If possible consider removing all mercury 

compounds and mercury-containing 

equipment from the school, and discontinue 

their use. 

✔ Isolate and label the mercury-containing 

devices to ensure proper handling and 

disposal. Dispose of mercury and mercurycontaining devices at a facility permitted 

to accept hazardous waste and/or 

universal waste. Contact your county, state 

environmental, or solid waste office for 

services available in your area.

✔ Never crush or break fluorescent lamps, 

because mercury will be released.

Know How to Prevent 

Exposures

Having a chemical management program can help 

schools reduce the risk of chemical exposures and 

accidents. Program information can help renovation 

project managers plan for and mitigate risks. 

Individuals with knowledge of chemical hazards 

should be consulted before attempting to move any 

chemicals, as some may have become shock-sensitive 

or explosive over time. If hazardous chemicals need 

to be temporarily relocating during renovations, 

designate a temporary storage area that has proper 

ventilation, and adequate space to accommodate the 

chemical-specific handling and storage requirements, 

including temperature control. 

When renovations remove mercury-containing 

equipment, special handling and disposal requirements

are necessary to avoid a release. Schools should 

conduct and maintain an up-to-date inventory 

list of all mercury-containing equipment prior to 

renovation; so, proper removal procedures can be 

incorporated into the renovation ahead of time. 
12

Know the risks

Lead is a naturally occurring metal that has been 

used in a variety of products, including primer, 

varnish, paints, plumbing pipes, batteries, glassware, 

and metal products (e.g., solder). Lead exposure 

can occur through ingestion or inhalation. Lead 

based paint (LBP) is of particular concern for 

schools because it can chip and become dust, and 

be ingested through hand-to-mouth contact, or be 

sanded and inhaled as dust particulates.

There is no safe level of lead exposure. It can 

cause several health effects, including anemia, 

decreased kidney function, high blood pressure, and 

reproductive issues. Children under the age of six 

are especially susceptible to lead exposure and may 

have additional health effects including behavior and 

learning problems, lower IQ, hyperactivity, slowed 

growth, or hearing problems. In rare cases, ingestion 

of lead can cause seizures, coma and even death.

LBP was banned as a consumer product in 1978. 

Current EPA regulations define LBP as paint 

containing more than 0.5% lead by weight or surface 

coatings containing more than 1.0 milligram per 

square centimeter (mg/cm2) of lead.

Know the regulations 

EPA regulates lead renovation, repair, and painting 

(RRP) under the TSCA Sections 402(a) and 404 as 

well as 40 CFR Part 745 Subpart E. Additional state 

and federal regulations may apply to LBP (e.g., the 

Residential Lead-Based Paint Hazard Reduction Act 

of 1992 and OSHA Safety and Health Regulations 

for Construction).

Under the RRP Rule, paint is assumed to be LBP 

unless analytical data shows otherwise. The RRP rule 

requires that firms performing renovation, repair, 

and painting projects that disturb lead-based paint 

in child-occupied facilities built before 1978 have 

their firm certified by EPA (or an EPA authorized 

state), use certified renovators who are trained 

by EPA-approved training providers and follow 

lead-safe work practices. A child-occupied facility 

is narrowly defined as a building, or portion of a 

building, constructed prior to 1978, visited regularly 

by the same child, under 6 years of age, on at least 

two different days within any week (Sunday through 

Saturday period), provided that each day’s visit lasts 

at least 3 hours and the combined weekly visits 

last at least 6 hours, and the combined annual visits 

last at least 60 hours.

The RRP rule also has a pre-renovation education 

component and requires distribution of a lead 

hazard information pamphlet regarding the potential 

risk of exposure from renovation activities within a 

child-occuplied facility.

Know where to find LBP

Schools constructed after 1978 are unlikely to have 

an issue with LBP, but old painted furniture or 

bookcases could potentially have LBP present. 

Schools built prior to 1978 may still have LBP present 

on interior or exterior walls under new layers of paint. 

LBP can also be found on playground equipment or 

sport/recreational areas (e.g., athletic field bleachers).

Dried paint can be tested for lead by collecting paint 

chips and sending them to an accredited analytical 

laboratory. Alternatively, a trained and certified lead 

inspector can use an X-ray fluorescence analyzer on 

paint chips or surfaces to provide real-time results 

on whether LBP is present or absent. If LBP is 

Lead Based Paint

EPA Lead-Safe Certified Guide to Renovate Right
13

Best Management Practices: 

✔ Maintain records and reports showing the 

locations of LBP in the school, LBP testing 

results, and areas where LBP abatement has 

been performed. 

✔ Hire a certified lead-safe contractor if 

renovations will disturb paint in childoccupied facilities. 

✔ Be actively involved in renovation design 

phase when LBP is present and 

share available LBP reports with the 

renovation firm. 

✔ If the LBP records are incomplete or not 

current for areas where renovations are 

planned, conduct additional LBP testing 

prior to renovation. It is much less costly 

to test than to clean up lead dust released 

throughout the school during renovations. 

✔ Conduct lead dust sampling after LBP 

abatement projects have been performed. Be 

sure to request and review the final clearance 

sampling results prior to allowing students 

and staff to re-occupy the affected area after 

LBP abatement.

present on painted surfaces it can be removed 

or enclosed.

Know how to prevent exposure

Common renovation activities, like sanding, cutting 

and demolition, can create hazardous lead dust 

and chips. LBP can cause challenges for school 

renovation projects, even if it doesn’t meet the 

definition of child-occupied facility, because LBP 

should be left untouched or must be addressed 

with lead-safe work practices under OSHA Safety 

and Health Regulations for Construction. In 

schools built prior to 1978, it is a best management 

practice to identify LBP early so the renovation 

design accounts for LBP. Special work practices and 

disposal procedures are required if LBP abatement 

is needed. Therefore, LBP abatement has to be 

sequenced before renovations. 

Did you know?

Lead can leach into drinking water as it moves through a building’s lead-pipe distribution system. Even though the drinking 

water you receive meets federal and state standards, your school may have elevated lead levels due to plumbing materials 

and water use patterns. Consider testing the drinking water and correcting any problems during renovations to reduce lead 

exposure to students and staff. Refer to 3Ts for Reducing Lead in Drinking Water in Schools for additional information.

In addition, dyes or pigments in LBP may also contain polychlorinated biphenyls (PCBs). Recommend concurrently testing 

paint for lead and PCBs.
14

Polychlorinated biphenyls (PCBs) are a class of 

synthetic organic chemicals that were widely used in 

building construction, including schools built between 

about 1950 and the late 1970s. The manufacture and 

use of PCBs were banned by the TSCA and phased 

out by 1979, except for certain limited uses. PCBs 

are toxic and continue to be closely regulated.

If PCBs are present in buildings, the scope and 

process of renovation often becomes substantially 

more complex and time-consuming. The potential 

presence of PCBs in schools also presents regulatory 

compliance issues. The process and specific cleanup 

requirements are less straight forward than for the 

other materials addressed in this booklet.

EPA has several web pages (listed at the end of 

this booklet) that provide guidance on addressing 

PCBs in schools and other buildings, including 

building renovation.

Know the risks

Exposure to elevated levels of PCBs has been 

demonstrated to cause cancer in animals and noncancer effects on the immune, reproductive, nervous, 

and endocrine systems in animals and humans. 

Studies in human populations provide supportive 

evidence for potential cancer and non-cancer health 

effects of PCBs. Exposure in school buildings 

during renovation may occur through inhalation 

of PCBs in the air (vapors or dust-borne); ingestion 

of PCB-containing dust; and through direct 

dermal contact.

Know the regulations 

PCBs are regulated by EPA under the TSCA 

through the PCB Manufacturing, Processing, 

Distribution in Commerce, and Use Prohibitions 

Rule (40 CFR Part 761). The regulation is very 

complex and the presence of PCBs can substantially 

complicate renovation.

A few of the relevant TSCA regulatory requirements 

for schools include: 

• Prohibition on PCB uses not allowed in the 

TSCA PCB regulations; 

• Proper disposal of PCB-containing material; 

• EPA approval when cleaning up or leaving

PCBs in place. 

Know where to find PCBs

Fluorescent light ballasts and caulking are the most 

common sources of PCBs in schools. Most schools 

have implemented programs for removing fluorescent

light ballasts but some ballasts or residues may 

remain. PCB-containing caulk has been found in 

window glazing and around window frames, door 

frames, in masonry columns and in other building 

materials. However each building is different and 

PCBs may also be found in electrical equipment, 

floor tile mastic, adhesives, sealants, paint, and other 

construction materials. Additionally, residues from 

previous PCB releases may still be present and 

may have been absorbed into other porous

building materials. 

Polychlorinated 

Biphenyls
15

Best Management Practices: 

✔ Replace PCB-containing fluorescent light 

fixtures with energy-efficient lighting (e.g. LED 

lighting) as a green building practice; a complete 

lighting retrofit reduces the PCB hazards and 

increases energy efficiency by 30-50 percent

✔ Evaluate the potential for the presence 

of PCB-containing building materials prior 

to renovation 

✔ Comply with OSHA regulations and employ 

personal protective equipment for dustgenerating work

✔ During renovation with the potential for PCBcontaining building materials, set appropriate 

controls in place to minimize spreading dust 

during the renovation and/or repair activity 

✔ Maximize use of manual tools that minimize 

generation of heat and dust

✔ Employ properly trained workers to clean areas 

potentially contaminated by PCB-containing 

materials using wet cloths and vacuums with 

HEPA filters

✔ Check TSCA requirements for proper disposal 

of different cleanup-related materials

Know how to prevent exposure

The TSCA regulates use of PCBs and places the 

responsibility for compliance on the user; in this 

case the school. EPA guidance on preventing 

exposure is presented on EPA’s website regarding 

PCBs in buildings. The information on many of the 

technical and regulatory issues for PCB-containing 

caulk is useful for addressing the similar issues for 

other PCB-containing materials.

Renovation projects may have to deal with PCBcontaining materials or electric equipment during the 

design phase. This may include testing of materials,

obtaining EPA approval, worker protection and 

management and disposal of any PCB-containing 

materials or equipment. Disposal of PCB-containing 

materials must be at an approved facility.
16

Know the risks

Radon is an odorless, colorless, tasteless radioactive 

gas that is produced by the decay of naturally 

occurring uranium in soil and water. Radon can 

be found in both outdoor and indoor air. Ionizing 

radiation emitted from radioactive chemicals is a 

proven carcinogen and prolonged exposure to radon 

may cause lung cancer. EPA estimates that about 

21,000 lung cancer deaths each year in the U.S. are 

radon-related.

EPA estimates that nearly one in five U.S. schools 

have at least one ground level room with short-term 

radon levels above 4 picoCuries per liter (pCi/L); 

the level at which the EPA suggests mitigation 

(see EPA source).

Know where to find radon

Radon enters any type of building (new or 

old) through cracks in the foundation and can 

accumulate in rooms on or below ground level. 

EPA’s national long-term goal for radon is that 

air within buildings is consistent with ambient air 

outside of buildings. Radon levels in indoor air can 

be determined by long-term or short-term testing. 

Know how to prevent exposure

When renovations change the dynamics of the 

HVAC system of a building, such as adding/

removing walls or changing air flow patterns, the 

radon levels can also change. Renovations that 

change HVAC air exchange rates or pressure 

differentials can result in a radon issue when there 

was not one before, or reduce an existing radon issue. 

EPA recommends that all schools conduct an 

initial short-term test and follow-up with testing 

if the radon level is above 4 pCi/L. Follow-up 

testing should include short-term and long-term 

testing to get a better understanding of the schoolyear average radon level. If the follow-up testing 

indicates that radon levels are above 4 pCi/L, 

schools should take steps to reduce the radon levels.

Radon

Best Management Practices:

✔ Maintain records of radon testing and 

installed radon mitigation systems. Review 

these records and incorporate radon 

reduction methods into the renovation 

design and/or leave existing radon mitigation 

systems in place. For additional information 

on radon reduction, refer to EPA’s Radon 

Website (http://www2.epa.gov/radon).

✔ Conduct post-renovation radon testing to 

verify that radon is not an IAQ issue.

✔ Disseminate information to parents, students, 

and staff as needed.
17

Know the risks

School renovations often generate construction 

and demolition (C&D) debris which can include 

concrete, wood, metals, glass, and salvaged building 

components. Sometimes these materials may contain 

asbestos, lead-based paint, mercury, or other chemicals

that present a hazard to human health and the 

environment. Therefore, it’s important to characterize 

materials early on in a project to avoid releases on 

school grounds and to ensure that the C&D debris 

are properly managed.

C&D debris can consist of three types of waste: 

(1) inert or nonhazardous waste; (2) hazardous waste 

as regulated by the EPA under the Resource 

Conservation and Recovery Act (RCRA); and 

(3) items that contain hazardous components that 

might be regulated by some states. 

Know what is in C&D debris

C&D debris needs to be characterized to determine 

if it is hazardous and needs to be handled as 

hazardous waste. Demolition of an old building may 

result in lead-based paint debris, asphalt waste, or 

treated wood debris. Renovation personnel may use 

screening test results, analytical data, or consult the 

hazardous waste regulations for listed wastes 

to determine whether the waste is hazardous. 

Know the regulations 

Schools are subject to the hazardous waste regulations 

of RCRA, the same as any other business within 

the US. Keep in mind that other EPA regulations may 

apply; depending on what C&D debris contains. 

For example, C&D debris containing asbestos may be 

subject to NESHAP, and waste containing PCBs may 

be subject to TSCA. Removal of mercury containing

material or equipment (i.e., fluorescent lamps, 

switches, thermostats) requires special handling and 

disposal under the universal waste rules. Also, be 

aware that the department of transportation (DOT) 

or state regulations may be more stringent than the 

EPA regulations. 

Know how to prevent exposure

Developing a waste management plan before 

renovation work begins can help schools identify 

what hazardous wastes may be present in C&D 

debris, and proper ways to contain the waste to 

prevent pollution and possible exposure. In addition, 

determining whether any C&D debris can be reused 

or recycled can help schools save money on disposal 

fees and help the environment.

Construction & 

Demolition

Best Management Practices: 

✔ Develop a waste management plan to predict 

the types and quantities of waste that will 

be generated during the renovation project, 

identify proper containment of these 

materials, and identify ways to reduce the 

amount of waste that goes to landfills 

(i.e., reuse onsite, recycle, donate or sell). 

✔ Hire contractors that are trained and certified 

to handle and transport the types of wastes that

will be generated during the renovation project.

Sustainable Building Practices

If the C&D debris do not include chemicals that can present a hazard such as lead or asbestos, project managers should 

consider alternatives such as recycling or reuse. This practice will conserve landfill space, save money in avoided disposal 

fees and potentially generate income from the sales of salvageable materials. 
18

Top Ten Things 

to Know About 

Designing Healthier 

School Renovations

1. When embarking on renovation projects, it is recommended 

that schools establish a process for disseminating 

information and receiving feedback. For example, schools 

may opt for establishing a school renovation committee, with 

a diverse membership including parents, teachers and staff, 

to make renovations a publicly transparent and inclusive 

process. Whenever possible, conduct renovation activities 

outside of the school year to reduce impacts to students 

and staff. 

2. When school renovation projects involve disturbing asbestos 

containing materials (ACM), special abatement procedures 

must be performed by licensed and trained asbestos abatement 

professionals prior to performing demolition or construction 

activities to avoid releasing harmful asbestos fibers.

3. Since the key to controlling mold is removing the source(s) 

of moisture that caused the mold issue in the first place, an 

objective of any renovation should be to maintain proper 

moisture control after renovations are complete.

4. When renovations alter the dynamics of the heating, 

ventilation, and air conditioning (HVAC) system, radon 

levels can also change. Plan ahead to ensure the 

post-renovation HVAC system adequately mitigates 

radon and conduct radon testing after renovations.

5. If a renovation project includes expansion of the 

school, verify that there are no potential sources 

of vapor intrusion within 100 feet of the 

construction footprint. If the renovation project 

includes an existing school building with a vapor 

intrusion issue, incorporate mitigation methods 

into the renovation design or leave the current 

vapor intrusion mitigation system(s) in place.

6. Prior to starting renovations a clean-out or relocation of 

chemicals may be required. Create and implement a chemical

management program that addresses proper handling and 

disposal of chemicals as well as what to do in the event of a 

spill and/or emergency.

7. Child-occupied facilities must follow the renovation, 

repair, and painting (RRP) rule during school renovations. 

Although lead-based paint (LBP) abatement may not 

be required, when school renovations projects do include 

removal of LBP, special abatement procedures should 

be performed by an EPA certified lead-safe contractor prior 

to performing demolition or construction activities to avoid 

generating hazardous lead dust and chips.

8. Renovation projects may have to deal with polychlorinated 

biphenyls (PCB)-containing materials (e.g., caulking) or

electric equipment (e.g., transformers) during the design 

phase and may include testing of materials, obtaining 

EPA approval for removal, worker protection and

management, and proper disposal. 

9. Renovation projects can generate a significant 

 amount of construction and demolition (C&D) 

 debris and this material may need to be 

 characterized to determine if it is hazardous waste

 and regulated. If the debris is not hazardous 

 waste, consider recycling or reuse to conserve 

 landfill space, save money in avoided disposal 

 fees, and potentially generate income from the 

 sales of salvageable materials.

10. New construction and renovation projects are 

 great opportunities for schools to become 

 more energy-efficient, integrate pest 

 management design, incorporate green 

 building practices, and use sustainable 

 products. 
19

Indoor Air Quality (IAQ)

EPA IAQ Tools for School

http://www2.epa.gov/iaq-schools

EPA Toolkit for Safe Chemical Management 

in K-12 Schools

http://archive.epa.gov/schools/toolkit.html

EPA IAQ Design Tools for Schools

http://www2.epa.gov/iaq-schools/indoor-air-quality-designtools-schools

EPA IAQ Design Tools for Schools - Construction

http://www2.epa.gov/iaq-schools/construction-part-indoor-airquality-design-tools-schools

EPA IAQ Design Tools for Schools - Renovation

http://www2.epa.gov/iaq-schools/renovation-and-repair-partindoor-air-quality-design-tools-schools

Energy Efficiency Plus Health: IAQ Guidelines for 

School Building Upgrades

http://www2.epa.gov/iaq-schools/iaq-guidelines-school-buildingupgrades-energy-savings-plus-health 

EPA IAQ Reference Guide

http://www2.epa.gov/iaq-schools/indoor-air-quality-toolsschools-action-kit

EPA Managing Asthma in the School Environment

http://www2.epa.gov/iaq-schools/managing-asthma-schoolenvironment

EPA Clean Construction 

http://www2.epa.gov/cleandiesel

Indoor Air Quality - Healthy School Environments

http://www2.epa.gov/schools-air-water-quality

OSHA Indoor Air Quality Website 

https://www.osha.gov/SLTC/indoorairquality/index.html

NOISH Indoor Environmental Quality, Dampness and 

Mold in Buildings Website

http://www.cdc.gov/niosh/topics/indoorenv/mold.html

NIOSH Good Practice Guidelines for Maintaining 

Acceptable Indoor Environmental Quality During 

Construction and Renovation Projects

http://www.cdc.gov/niosh/topics/indoorenv/constructionieq.html

Asbestos

EPA Asbestos

http://www2.epa.gov/asbestos

EPA Asbestos in School Buildings

http://www2.epa.gov/asbestos/school-buildings 

EPA Asbestos NESHAP

http://www2.epa.gov/asbestos/asbestos-neshap

Mold

EPA Mold Remediation in Schools & 

Commercial Buildings

http://www2.epa.gov/mold/mold-remediation-schools-andcommercial-buildings-guide

EPA Mold and Moisture

http://www2.epa.gov/mold/mold-and-indoor-air-quality-schools

EPA Moisture Control Guidance for Building Design, 

Construction and Maintenance

http://www2.epa.gov/indoor-air-quality-iaq/moisture-controlguidance-building-design-construction-and-maintenance-0

Radon

EPA Radon

http://www2.epa.gov/radon

EPA Radon in Schools

http://www2.epa.gov/radon/radon-schools

ATSDR Toxicological Profile for Radon 

http://www.atsdr.cdc.gov/toxprofiles/tp.asp?id=407&tid=71

Vapor Intrusion

EPA Vapor Intrusion 

http://www2.epa.gov/vaporintrusion

EPA CLU-IN Vapor Intrusion

http://www.clu-in.org/issues/default.focus/sec/Vapor_Intrusion/

cat/Overview/

Hazardous Materials & Mercury

Mercury Concerns During Renovations for a Healthy 

School Environment

http://www2.epa.gov/schools-healthy-buildings/mercuryconcerns-during-renovations-healthy-school-environment 

Toolkit for Safe Chemical Management in K-12 Schools

http://www2.epa.gov/schools-chemicals/toolkit-safe-chemicalmanagement-k-12-schools

Chemical Use and Management in Schools

http://www2.epa.gov/schools-chemicals

Mercury in Schools Case Studies

http://www2.epa.gov/schools/case-studies-about-mercurycleanups-schools

EPA Schools and Mercury

http://www2.epa.gov/mercury

EPA Steps to Take When a CFL Breaks

http://www2.epa.gov/cfl/cleaning-broken-cfl

EPA Recycling CFLs

http://www2.epa.gov/cfl/recycling-and-disposal-after-cfl-burnsout#whererecycle

ATSDR Don’t Mess with Mercury

http://www.atsdr.cdc.gov/dontmesswithmercury/

Lead

EPA Lead 

http://www2.epa.gov/lead

EPA Renovation, Repair and Painting Program

http://www2.epa.gov/lead/renovation-repair-and-painting-program

EPA Renovation, Repair and Painting Program: Operators 

of Childcare Facilities

http://www2.epa.gov/lead/renovation-repair-and-paintingprogram-operators-childcare-facilities

References and

Resources
20

EPA Lead-Safe Certified Guide to Renovate Right

http://www2.epa.gov/sites/production/files/documents/

renovaterightbrochure.pdf

PCBs

Renovations and PCBs for a Healthy School Environment

http://www2.epa.gov/schools-healthy-buildings/renovationsand-polychlorinated-biphenyls-pcbs-healthy-school-environment

EPA Steps to Safe Renovation and Abatement of 

Buildings That Have PCB-Containing Caulk

http://www3.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/guide/

EPA PCB-Containing Fluorescent Light Ballasts in Schools

http://www3.epa.gov/epawaste/hazard/tsd/pcbs/pubs/ballasts.htm

EPA TSCA Disposal Requirements for Fluorescent 

Light Ballasts

http://www3.epa.gov/epawaste/hazard/tsd/pcbs/pubs/

ballastchart.pdf

EPA PCB Site Revitalization Guidance Under the TSCA 

http://www3.epa.gov/epawaste/hazard/tsd/pcbs/pubs/pcbguid3-06.pdf

ATSDR Toxicological Profile for Polychlorinated Biphenyls 

http://www.atsdr.cdc.gov/toxprofiles/tp.asp?id=142&tid=26

Miscellaneous

EPA Healthy School Environments – Design and 

Construction Overview

http://www2.epa.gov/schools-healthy-buildings/overviewdesign-and-construction-healthy-school-environment

EPA School Siting Guidelines 

http://www2.epa.gov/schools/school-siting-guidelines

EPA’s State School Environmental Health Guidelines 

http://www2.epa.gov/schools

The School Superintendents Association Healthy 

School Environments

http://www.aasa.org/healthyschoolenvironments.aspx

Collaborative for High Performance Schools, 

Operations Report Card

http://www.chps.net/dev/Drupal/orc

National Institute of Occupational Safety and Health 

(NIOSH) Safety Checklist for Schools

http://www.cdc.gov/niosh/docs/2004-101/default.html

Collaborative for High Performance Schools (CHPS) 

http://www.chps.net

National Institute of Environmental Health Sciences (NIEHS) 

http://www.niehs.nih.gov

American Clearinghouse on Educational Facilities

http://www.acefacilities.org/

Center for Environmental Innovation in Roofing

http://www.roofingcenter.org/

National Clearinghouse for Educational Facilities

http://www.ncef.org/rl/index.cfm

Sheet Metal and Air Conditioning Contractors National 

Association, Inc., Indoor Air Quality Guidelines for 

Occupied Buildings under Construction

http://asc67.org/ASC_Previous_Problems/R7/Commercial/2007/

Student%20Disk/14.4%20SMACNA%20Guidelines.pdf

Construction Industry Compliance Assistance Center, 

funded in part by EPA 

http://www.cicacenter.org/

Integrated Pest Management

EPA Integrated Pest Management (IPM) in Schools 

http://www2.epa.gov/managing-pests-schools

California Integrated Pest Management – Building 

Design and Renovation

http://apps.cdpr.ca.gov/schoolipm/architects_designers/main.cfm

The San Francisco Department of the Environment’s 

Pest Prevention by Design Guidelines

http://www.sfenvironment.org/download/pest-prevention-bydesign-guidelines

Construction and Demolition

RCRA in Focus: Construction, Demolition, and Renovation

http://www3.epa.gov/epawaste/inforesources/pubs/infocus/rif-cd.pdf

C&D Debris: What You Can Do

http://www3.epa.gov/epawaste/conserve/imr/cdm/whatyoucan.htm

Calculating Effectiveness: The Waste Management Plan

http://www3.epa.gov/region9/waste/solid/pdf/cd5.pdf

Sustainable Design and Green Building Toolkit 

for Local Governments

http://www2.epa.gov/smartgrowth/sustainable-design-andgreen-building-toolkit-local-governments

Green School Design

ASHRAE Energy Design Guide for Savings in Schools 

http://www.ashrae.org/publications/page/aedg50pct

ASHRAE Standard for the Design of High-Performance 

Green Buildings

https://www.ashrae.org/resources--publications/bookstore/

standard-189-1

Green Building Council Website 

http://www.usgbc.org 

Green Building Initiative Green Globes

http://www.thegbi.org/green-globes/

Net Zero Building Design

http://living-future.org/netzero

RoofPoint

http://www.roofpoint.org/

USGBC Center for Green Schools Resources

http://www.centerforgreenschools.org/guides.aspx

Earth911 Recycling Search

http://search.earth911.com/

References and

Resources

http://www2.epa.gov/children

EPA-909-R-15-002

January 2016

Pr ni ted on

0

1

yce R

%

0

c

el d Paper ¥Printed on

1

00

%

Recycled Paper ¥