Report to the California Legislature

ENVIRONMENTAL HEALTH CONDITIONS

IN CALIFORNIA’S

 PORTABLE CLASSROOMS

A joint report submitted by:

California Air Resources Board

California Department of Health Services

Pursuant to Health and Safety Code § 39619.6

(Assembly Bill 2872, Shelley, Statutes of 2000)

November 2004

California Environmental Protection Agency

Air Resources Board

 Arnold Schwarzenegger

 Governor

 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

i

ACKNOWLEDGEMENTS

We are particularly grateful to the many school administrators, teachers, and facility managers

who took time from their very busy schedules to respond to detailed questionnaires and to allow

entry to their campuses during difficult times following the terrorist attacks of September 11th.

Without their cooperation and assistance, this study would not have been possible.

We acknowledge the dedication and perseverance of the Research Triangle Institute (RTI) field

technicians and survey specialists who overcame many obstacles: Lewis Cauble, David DeKort,

Heather Lesnik, Molly Burton, Rebecca Premock, John Roberts, Jane Serling, Michael Phillips,

and Jeremy Morton. We also acknowledge the skill and perseverance of the RTI research staff

who provided the overall study design, obtained and analyzed environmental samples, and

analyzed a very large and complex data set: Gerry Akland (Principal Investigator), Roy

Whitmore (Co-principal Investigator), Andy Clayton, James Blake, Marlene Clifton, Linda Ellis,

Reshan Fernando, Tricia Webber, Karin Foarde, Larry Michael, Doris Smith, and Annette

Green.

We appreciate the valuable input received from the following groups:

• California Portable Classrooms Study Dust Analysis Panel, who provided helpful

suggestions concerning the analyses of the floor dust samples: Martha Harnly and Janet

Macher (Department of Health Services), Myrto Petreas (Department of Toxic Substance

Control), and Randy Segawa (Department of Pesticide Regulation).

• Many government agency representatives who provided thoughtful comments on the study

design and draft reports, especially Duwayne Brooks and Tony Hesch, Department of

Education; Richard Lam, Bob Blaisdell, and Jim Carlisle, Office of Environmental Health

Hazard Assessment; Deborah Gold and Bob Nakamura, Cal/OSHA; Kathy Frevert and

Dana Papke, Integrated Waste Management Board; Sandra McNeel, Department of Health

Services; Carol Shellenberger and Rich Sheffield, Office of Public School Construction;

Panama Bartholomy and Richard Conrad, Division of the State Architect; Shelly Rosenblum

and Barbara Spark, U.S. Environmental Protection Agency, Region 9; and many others.

• Many staff from many schools and districts, who provided information prior to the study,

assisted with pre-tests and the pilot study, and provided input on the results and

recommendations of the study, and a special thanks to the Los Angeles Unified School

District (LAUSD), and especially Jay Brakensiek, for information, checklists, and photos from

LAUSD’s Facility Inspection Program.

• Stakeholders from the public and private sectors, who attended the public workshops and

shared their experiences and suggestions concerning indoor environmental quality in

classrooms.

• Researchers who shared their experience and results from related studies: Richard Corsi

and Vince Torres (University of Texas, Austin); Mike Lubliner, Rich Prill, and Mike McSorley

(Washington State University); Michael Brauer and Karen Bartlett (University of British

Columbia); Lisa Heschong (Heschong-Mahone Group); and Derek Shendell (University of

California Los Angeles).

• Manufacturers and their representatives who shared information on their processes,

products, and concerns, especially Scott Alexander, Mobile Modular Management

Corporation; Maury Tiernan, Geary Pacific; the School Facilities Manufacturers’ Association;

and Joe Sublett, Enviroplex, who provided a special tour of his facility at the start of the

study.
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• Susan Lum, ARB website management and data file review; Helena Lee, ARB student

assistant, for researching noise and lighting standards and guidelines; and Jacqueline

Cummins, ARB, for secretarial support.

Finally, we honor our colleague and study group member, Dr. Kai-Shen Liu, of the California

Department of Health Services, who died suddenly during this project. Dr. Liu played a key role

in the early development of the study design and in the Phase I statistical analyses. He is

warmly remembered and missed by all.
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DISCLAIMER

The mention of commercial products, their source, or their use in connection with

material presented in this report is not to be construed as actual or implied endorsement

of such products by the State of California.

ALTERNATIVE FORMS OF REPORT

If you are a person with a disability and desire to obtain this document in an alternative

format, please contact Jacqueline Cummins at (916) 445-0753 or

jcummins@arb.ca.gov. TTY/TDD/Speech-to-speech users may dial 7-1-1 for the

California Relay Service.

This report also is available electronically on ARB’s website at:

http://www.arb.ca.gov/research/indoor/pcs/pcs.htm
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S T A T E OF C A L I F O R N I A

ARNOLD SCHWARZENEGGER

Governor

TERRY TAMMINEN S. KIMBERLY BELSHÉ

Agency Secretary Agency Secretary

California Environmental California Health and Human Services

 Protection Agency Agency

CALIFORNIA AIR RESOURCES BOARD

ALAN C. LLOYD, Ph.D., Chairman

SANDRA BERG

DORENE D’ADAMO

MARK J. DeSAULNIER

HENRY GONG, Jr., M.D.

LYDIA H. KENNARD

RONALD O. LOVERIDGE

BARBARA PATRICK

PATRICIA SALAS PINEDA

BARBARA RIORDAN

RON ROBERTS

CATHERINE WITHERSPOON, Executive Officer

CALIFORNIA DEPARTMENT OF HEALTH SERVICES

SANDRA SHEWRY, Director
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AUTHORS

Principal Authors

Peggy L. Jenkins, M.S., Manager

Indoor Exposure Assessment Section, ARB

Thomas J. Phillips, M.S.

Staff Air Pollution Specialist, ARB

Jed Waldman, Ph.D., Chief

Indoor Air Quality Program, DHS

Staff Contributors

Whitney Webber, ARB

Kai-Shen Liu, M.P.H., Ph.D., DHS

Janet Macher, M.P.H., Sc.D., DHS

Feng C. Tsai, Ph.D., DHS

Report Reviewers

Richard Bode, Chief, Health and Exposure Assessment Branch, ARB

Bart Croes, P.E., Chief, Research Division, ARB

Michael Scheible, Deputy Executive Officer, ARB

Leon Alevantis, M.S., P.E., Deputy Chief, Indoor Air Quality Section, DHS

C. Peter Flessel, Ph.D., Chief, Environmental Health Laboratory Branch, DHS

Raymond Richard Neutra, M.D., Dr.P.H., Chief, Environmental & Occupational Disease

Control Division, DHS
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TABLE OF CONTENTS

DISCLAIMER ..................................................................................................................iii

ACRONYMS .................................................................................................................viii

ABBREVIATIONS AND SYMBOLS................................................................................. x

GLOSSARY OF TERMS.................................................................................................xi

EXECUTIVE SUMMARY................................................................................................. 1

1. INTRODUCTION.................................................................................................. 24

1.1 Mandate and Need for the Study.................................................................... 24

1.2 Definition of Portable Classrooms .................................................................. 25

1.3 Purpose and Scope of the Study.................................................................... 25

1.4 Stakeholder Participation................................................................................ 26

2. BACKGROUND.................................................................................................... 28

2.1 Indoor Environmental Conditions and Potential Health Effects ...................... 28

2.2 Potential Economic and Performance Impacts............................................... 29

2.3 Indoor Environmental Regulations and Guidelines for Public Schools ........... 30

2.3.1 Environmental Contaminants ................................................................... 31

2.3.2 Ventilation and Comfort............................................................................ 32

2.3.3 Noise and Lighting.................................................................................... 32

2.3.4 Mold.......................................................................................................... 33

2.4 Design and Construction of Portable Classrooms.......................................... 35

2.4.1 State Relocatable Classroom Program .................................................... 36

2.4.2 California Collaborative for High Performance Schools............................ 37

2.4.3 U.S. EPA IAQ Design Tools for Schools .................................................. 38

2.4.4 State Workgroup on Relocatable Classrooms.......................................... 38

2.4.5 Innovative Design Initiatives..................................................................... 38

2.4.6 Portable Classroom Manufacturers .......................................................... 39

2.4.7 LAO Blueprint for School Facility Finance ................................................ 39

2.5 School Operation and Maintenance (O&M) Practices .................................... 40

2.5.1 LAUSD’s Facility Inspection Program....................................................... 40

2.5.2 U.S. EPA’s IAQ Tools For Schools Program............................................ 41

2.5.3 Lead-Safe Schools ................................................................................... 42

2.5.4 Integrated Pest Management (IPM) ......................................................... 43

2.5.5 School-based Asthma Management Program.......................................... 43

2.5.6 Statewide Organizations........................................................................... 44

3. STUDY METHODS AND RESULTS .................................................................... 45

3.1 Methods.......................................................................................................... 45

3.1.1 Phase I ..................................................................................................... 46

3.1.2 Phase II .................................................................................................... 46

3.2 Results ........................................................................................................... 48

3.2.1 Classroom and School Characteristics..................................................... 48

3.2.2 Building Materials and Other Pollutant Sources ....................................... 48

3.2.3 Environmental Problems .......................................................................... 49

3.2.4 Building Operation and Maintenance ....................................................... 49

3.2.5 Classroom Ventilation............................................................................... 50

3.2.6 Air Pollutant Measurements ..................................................................... 53
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3.2.7 Floor Dust Contaminants.......................................................................... 59

3.2.8 Moisture and Mold.................................................................................... 64

3.2.9 Pollen ....................................................................................................... 67

3.2.10 Noise ........................................................................................................ 68

3.2.11 Lighting..................................................................................................... 68

3.2.12 Specially Selected Classrooms ................................................................ 69

3.3 Summary of Results ....................................................................................... 69

4. RELATED STUDIES IN CALIFORNIA SCHOOLS............................................... 71

5. INFORMATION FROM OTHER STATES ............................................................ 75

6. SUMMARY OF STAKEHOLDER INPUT.............................................................. 76

6.1 Pre-Study Workshops .................................................................................... 76

6.2 Post-Study Workshops................................................................................... 77

7. RECOMMENDATIONS AND DISCUSSION ........................................................ 78

8. SUMMARY AND CONCLUSIONS ....................................................................... 84

8.1 Results ........................................................................................................... 84

8.2 Recommendations ......................................................................................... 86

8.3 Conclusions.................................................................................................... 87

REFERENCES.............................................................................................................. 89

APPENDIX I : Health and Safety Code Section 39619.6........................................I-1

APPENDIX II : DHS Pre-Survey.......................................................................II-1

APPENDIX III : RTI/ARB-DHS Project Executive Summary....................................III-1

APPENDIX IV : Recommendations to Schools for Reducing Formaldehyde..............IV-1

APPENDIX V : LAUSD Checklist.......................................................................V-1

APPENDIX VI: Working Draft Suggestions for Preventive and Remedial Actions........VI-1

LIST OF TABLES

Table 2-1. Selected Guidelines and Standards Relevant to School Environments. ..... 34

Table 3-1. Study Design, Phases I and II..................................................................... 45

Table 3-2. Phase II, Summary of Environmental Measurements. ............................... 47

Table 3-3. Percent of classrooms with certain building characteristics, Phase I. ......... 48

Table 3-4. Percent of classrooms with environmental problems reported by teachers,

Phase I. .............................................................................................................. 49

Table 3-5. HVAC Maintenance Characteristics, Phase II............................................. 50

Table 3-6. HVAC Operation Characteristics, Phase II.................................................. 52

Table 3-7. Indoor Formaldehyde Concentrations, Phase I and II. ................................ 54

Table 3-8. Percent of Classrooms with Moisture Indicators, Phase II. ......................... 65

Table 3-9. National Concentration Guidelines for Outdoor Airborne Mold Spores and

Plant Pollen*....................................................................................................... 67

Table 3-10. Classroom Noise and Lighting Conditions Exceeding Standards.............. 68

Table 3-11. Summary of Contaminant Levels in Air and Floor Dust, Phase II.............. 70
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ACRONYMS

ACRONYM DEFINITION 

AAAAI American Academy of Allergy Asthma and Immunology

AAQS Ambient Air Quality Standards

AB Assembly Bill

ACSA Association of California School Administrators

AHERA Asbestos Hazard Emergency Response Act

ALA American Lung Association

ANSI American National Standards Institute

ARB California Air Resources Board

ASHRAE American Society of Heating, Refrigerating, and Airconditioning Engineers

CAASA California Asthma Among the School-Aged

Cal/EPA California Environmental Protection Agency

Cal/OSHA California Department of Industrial Relations, Division of

Occupational Safety and Health

CASBO California Association of School Business Officers

CASH Coalition for Adequate School Housing

CCR California Code of Regulations

CDC U.S. Center for Disease Control

CDE California Department of Education

CDFA California Department of Food and Agriculture

CEC California Energy Commission

CHPS California Collaborative for High Performance Schools

CIWMB California Integrated Waste Management Board

CLPPP Childhood Lead Poisoning Prevention Program

DGS California Department of General Services

DHS California Department of Health Services

DOE U. S. Department of Energy

DPR California Department of Pesticide Regulation

DSA Division of the State Architect, California Department of General

Services

EPA U.S. Environmental Protection Agency

GAO U.S. General Accounting Office

HEPA High efficiency particulate arrestance

HSC California Health and Safety Code

HVAC Heating, ventilating, and air conditioning

IAQ Indoor air quality

IDEC Indirect-direct evaporative cooling

IEQ Indoor environmental quality

IESNA Illuminating Engineering Society of North America

IPM Integrated Pest Management

IREL Interim (Indoor) Reference Exposure Level

LAO California Legislative Analyst’s Office
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LAUSD Los Angeles Unified School District

LEEDTM Leadership in Energy and Environmental Design

LBNL Lawrence Berkeley National Laboratory

NAAQS National Ambient Air Quality Standards

NIOSH National Institute for Occupational Safety and Health

O&M Operation and Maintenance

OEHHA California Office of Environmental Health Hazard Assessment

OPSC Office of Public School Construction, California Department of

General Services

OSHA U.S. Occupational Safety and Health Administration

PAH Polycyclic aromatic hydrocarbon

PBO Piperonyl butoxide

PCS Portable Classrooms Study

PEL Permissible Exposure Limit

PM Particulate matter

PRG Preliminary Remediation Guidelines

REL Reference Exposure Limit

RH Relative Humidity

RTI Research Triangle Institute

SB Senate Bill

SBS Sick Building Syndrome

SCE Southern California Edison

SFMA School Facilities Manufacturers Association

UC University of California

UCLA University of California, Los Angeles

U.S. EPA United States Environmental Protection Agency

VOC Volatile Organic Compound, Volatile Organic Chemical

WHO World Health Organization
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ABBREVIATIONS AND SYMBOLS

TERM DEFINITION 

o

C degrees Celsius

cfm cubic feet per minute

CFU colony forming unit

cm2 square centimeter

CO carbon monoxide

CO2 carbon dioxide

dBA decibel (referenced to 1 ampere)

o

F degrees Fahrenheit

kg kilogram (one thousand grams)

l/min. liters per minute (flow rate)

m2 square meter

m3 cubic meter

μg microgram (one-millionth of a gram)

μg/g micrograms per gram (concentration)

μg/cm2 micrograms per square centimeter (surface area)

μg/m3 micrograms per cubic meter (concentration)

mg milligrams (one-thousandth of a gram)

mg/kg milligrams per kilogram (concentration)

ml milliliter (one-millionth of a liter)

ng nanogram (one-billionth of a gram)

ng/g nanograms per gram (concentration)

No. number

% percent

pCi/l picoCurie per liter

PM2.5 Particulate matter with aerodynamic diameter less than 2.5 microns

PM10 Particulate matter with aerodynamic diameter less than 10 microns

ppb parts per billion (such as one grain of sand in a billion grains of

sand)

ppm parts per million (such as one grain of sand in a million grains of

sand)

§ section

T temperature
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GLOSSARY OF TERMS

TERM DEFINITION 

Active/Passive Sampling Active sampling depends on a mechanical process like

pumping to collect the sample at a known rate; this was used

for VOC and aldehyde sample collection. Passive sampling

involves non-mechanical processes, usually diffusion, in

which the air is sampled at whatever rate it passes across a

badge surface or tube opening. Passive tube samplers were

used in Phase I for the formaldehyde sample collection.

Air Changes per Hour ACH, the volume of air moved in one hour. One air change

per hour in a room, home, or building means that the

equivalent of the volume of air in that space will be replaced

in one hour.

Air Flow Rate The rate at which air moves into a space. Expressed in units

of air changes per hour or cubic feet per minute.

Air Handling Unit HVAC (heating, ventilation and air conditioning) unit. Refers

to equipment that includes a blower or fan, heating and/or

cooling coils, and related equipment such as controls,

condensate drain pans, and air filters. Does not include

ductwork, registers, or grilles, or boilers and chillers.

Allergen A chemical or biological substance (e.g., pollen, animal

dander, or house dust mite proteins) that induces an allergic

response, characterized by hypersensitivity.

Ambient Air Quality State (ARB) and federal (EPA) enforceable regulations

Standards (AAQS) designed to protect the public from the harmful effects of

traditional pollutants in outdoor air.

Asthma A chronic disease of lung tissue which involves inflamed

airways, breathing difficulty, and an increased sensitivity to

allergens and contaminants in the air.

Biological Contaminants Agents derived from or that are living organisms (e.g.,

viruses, bacteria, fungi, and mammal, arthropod, and bird

antigens) that can be inhaled and can cause many types of

health effects including allergic reactions, respiratory

disorders, hypersensitivity diseases, and infectious diseases.

Also referred to as biological agents.
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Comfort measures Factors that determine human perception of thermal comfort,

including temperature, relative humidity, and draft

Dampers Controls that vary airflow through an air outlet, inlet, or duct.

A damper may be immovable, manually adjustable, or part of

an automated control system.

Detection Limit Limit of detection, the lowest detectable concentration of a

pollutant for a sampling and/or analytical procedure. This

varies with different measurement methods.

Fungi A group of organisms that lack chlorophyll, including molds,

mildews, yeasts, mushrooms.

Integrated Pest An ecosystem-based strategy that focuses on long-term

Management (IPM) prevention of pests or their damage through a combination

of techniques including non-chemical prevention and control

measures, habitat manipulation, modification of cultural

practices, and use of least hazardous pesticides.

Mail survey An information gathering study that utilizes the mail for

distributing and returning the information, using

questionnaires or other written forms.

Micron A unit of length equal to one millionth of a meter; a

micrometer.

Microorganism A microscopic organism, usually a bacterium, fungus, or

protozoan.

Natural ventilation The movement of outdoor air into a space through

intentionally provided openings, such as windows and doors,

or through non-mechanical ventilators, by wind, air pressure

differences, or other natural, non-mechanical means.

Permissible Exposure Enforceable pollutant exposure limits determined by OSHA

Limits (PELs) that are designed to protect healthy adult workers in

industrial environments from adverse health effects

associated with pollutant exposure. None of these limits are

targeted toward protecting children.

Pesticides A pesticide is any substance or mixture of substances

intended to prevent, destroy, repel, or mitigate any pest.

Though often misunderstood to refer only to insecticides, the

term pesticide also applies to herbicides, fungicides, and

various other substances used to control pests. Under
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United States law, a pesticide is also any substance or

mixture of substances intended for use as a plant regulator,

defoliant, or desiccant.

Polycyclic aromatic A class of stable organic molecules comprised of

hydrocarbons (PAHs) only carbon and hydrogen. They are a common product of

combustion from automobiles, airplanes, woodburning,

cigarettes, and some types of cooking. Many of these

molecules are highly carcinogenic and very common.

Portable Classrooms Classrooms that are designed and constructed to be

moveable and transportable over public streets, also known

as temporary or relocatable classrooms.

Quality Control (QC) Internal checks on the operation of sample collection and/or

sample analysis. Methods for determining the operation

include blanks, spiked samples, flow checks, and duplicate

samples. QC measures can be used to determine accuracy,

bias, and precision of the data reported.

Real-time Monitoring This type of environmental measurement gives

instantaneous information at the point of sampling;

measurements are recorded as often as every minute, every

second, or in fractions of a second.

Reference Exposure The concentration level at or below which no adverse

Level (REL) health effects are anticipated for a specified exposure

duration. RELs are based on the most relevant, adverse

health effect reported in the medical and toxicological

literature for the population group known to be most

sensitive to the chemical. RELs are designed to protect the

most sensitive individuals in the population by the inclusion

of margins of safety. Since margins of safety are

incorporated to address data gaps and uncertainties,

exceeding the REL does not automatically indicate an

adverse health impact will occur. OEHHA provides acute (1-

hour) and chronic (lifetime, non-cancer), RELs for a number

of chemicals, and has developed an 8-hour “indoor” REL for

formaldehyde.

Relative Humidity The measure of moisture in the atmosphere, expressed as a

percent of the maximum moisture the air can hold at a given

temperature.

Return Air Air removed from a space by the HVAC system to be

recirculated or exhausted.
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Sick Building Syndrome A set of symptoms (including headache, fatigue, and eye

irritation) typically affecting workers in modern airtight office

buildings, believed to be caused by indoor pollutants (such

as formaldehyde fumes or microorganisms).

Stratified Random A study approach in which the study samples are selected

Sampling randomly from each of several, previously determined

subgroups (strata) of the target population. The sampling

rate or selection probability for each strata can differ,

depending on the study design.

Supply Air Air delivered to the conditioned space by the HVAC system

and used for ventilation, heating, cooling, humidification, or

dehumidification. It is usually a combination of outdoor air

and return air.

Target study population For this study, all California K-12 public schools that had

portable classrooms in both the spring and fall of 2001

(spring of 2001 only for Phase I), and all classrooms in those

schools.

Traditional classrooms Classrooms in permanent, site-built school buildings.

Variable Air Volume Air handling system that conditions the air to a

System temperature using a varying amount of outside airflow based

essentially on the outdoor temperature.

Ventilation The process of intentionally supplying and removing air by

natural or mechanical means to and from any space.

Volatile Organic Compounds that evaporate quickly from the many

Compounds (VOCs) housekeeping, maintenance, and building products made

with organic chemicals. These compounds are released

from products that are being used and that are in storage.

Many are carcinogenic, neurotoxins, or mucous membrane

irritants.

Weights Weighting factors that are used in statistical analyses to

(or sample weights) remove the bias due to differential sampling rates and to

reduce the bias due to differential rates of non-response,

yielding results that reflect estimates for the entire population

being studied.
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EXECUTIVE SUMMARY

INTRODUCTION

The California Portable Classrooms Study was a comprehensive study of environmental

health conditions in California’s public school classrooms. It was conducted jointly by

the Air Resources Board (ARB) and the Department of Health Services (DHS) at the

request of Governor Gray Davis and the State Legislature (AB 2872 Shelley; California

Health and Safety Code (HSC) Section (§) 39619.6; see Appendix I). The study was

prompted by concerns that California’s schools, especially portable classrooms, might

not provide healthful environments for students or teachers. These concerns were

based on the potential for mold contamination, inadequate ventilation, poor temperature

control, elevated levels of volatile chemicals, and excessive use of some pesticides.

The study was funded to help understand the extent of these problems and to

determine whether those problems warranted response by the state and/or schools or

school districts.

The results of this comprehensive study provide important information for state and

local decision-makers regarding the degree to which our classrooms provide a safe,

healthful, and productive learning environment for California children. This report to the

California Legislature provides an overview of the study, summarizes conditions

identified in the study that need to be addressed at the State and local levels, and

discusses options for improving conditions in both portable and traditional classrooms.

The information presented in this report is based on the study results, findings from the

scientific literature, and input provided by state agencies, school districts, consultants,

manufacturers, and interested stakeholders.

PURPOSE AND SCOPE OF STUDY

The purpose of the California Portable Classrooms Study was to:

• Conduct a comprehensive study and review of the environmental health conditions

in portable classrooms.

• Identify any potentially unhealthful environmental conditions, and their extent.

• In consultation with stakeholders, identify and recommend actions that can be

taken to remedy and prevent any unhealthful conditions identified.

The Legislature also directed that the study include a review of design and construction

specifications, ventilation systems, school maintenance practices, indoor air quality, and

potential toxic contamination including mold and other biological contaminants.

Recommendations were to be developed to address the need for modified design and

construction standards, emission limits for building materials and furnishings, and other

mitigation actions needed to assure protection of children’s health.
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The study was conducted in two phases. Phase I consisted of a mail survey of 1000

schools randomly selected statewide. For each school, the facility manager and three

teachers (two from portable classrooms and one from a traditional classroom) were

asked to complete detailed questionnaires on all aspects of the classrooms pertaining to

environmental quality. Additionally, formaldehyde sampling tubes were sent to about

two-thirds of the schools, for deployment in the three classrooms. In Phase II,

comprehensive chemical, biological, and environmental measurements were obtained

in 201 classrooms at 67 schools randomly selected statewide. As in Phase I, two

portable classrooms and one traditional classroom were studied at each school.

The State contracted with Research Triangle Institute (RTI), a not-for-profit scientific

research organization, to conduct the primary field work of the study for both Phase I

and Phase II. ARB’s Research Screening Committee, an external scientific peer review

group that assures the quality of research funded by the ARB, reviewed and approved

all experimental design and study materials related to RTI’s participation. ARB and

DHS each conducted certain tasks of the study as well. For example, ARB pre-tested

the passive formaldehyde samplers used in Phase I, managed the RTI contract, and

coordinated stakeholder participation, while DHS conducted a preliminary survey of

school districts, analyzed dust samples for allergens, and reviewed the biological

sampling protocols conducted by RTI and the related results. Both agencies were fully

involved in project oversight, review of the results, and preparation of this report.

STAKEHOLDER PARTICIPATION

As directed in HSC §39619.6, ARB and DHS consulted with relevant state agencies and

stakeholders at key points in the study. A website and email distribution list were

established to keep interested stakeholders up to date on the progress of the study.

ARB and DHS consulted with the Department of Education, the Department of General

Services (including the Division of the State Architect and the Office of Public School

Construction), the Office of Environmental Health Hazard Assessment, and other

interested state agencies prior to the study regarding the overall study design and

detailed information to be obtained, and upon completion of the final research report

from RTI. Stakeholder input was obtained through comment periods and through

several public workshops conducted both prior to the study and upon completion of the

draft report.

BACKGROUND

A “portable classroom” is defined as “a classroom building of one or more stories that is

designed and constructed to be relocatable and transportable over public streets...”

(California Education Code, §17070.15[k]). Portable classrooms also are often referred

to as relocatable classrooms, and occur in a variety of styles and forms. Based on a

DHS survey of school districts, just under one-third (about 30%, or 80,000) of the

State’s 268,000 kindergarten to 12th grade (K-12) public school classrooms in the 2000-
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2001 school year were portable classrooms. It is estimated that about 80,000 to 85,000

are currently in use as classrooms in California.

Typical portable (relocatable) classrooms.
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Portable classrooms serve an important need in California K-12 public schools. They

are more quickly constructed and deployed to school sites, they can be moved from

school to school, and they often have a lower first-cost than traditional, site-built

buildings. These features allow schools great flexibility in meeting fluctuating enrollment

levels. In the late 1990s, the availability of portable classrooms enabled the state to

achieve class size reductions aimed at improving learning achievement. Until 1998, the

State required school districts that were requesting funding to design new schools with

at least 30% of portable classrooms. This requirement was imposed as a cost-saving

measure. With the Leroy F. Green School Facilities Act of 1998 and passage of

Proposition 1A, this restriction was lifted, and school districts were given greater local

control in the design of their schools, along with a revised formula for financing, based

on per-pupil grants.

Health and Economic Impacts

In recent years, concerns have risen among teachers, parents, and the public regarding

potential health risks at schools, especially associated with portable classrooms. The

concerns have focused on immediate health complaints such as eye irritation, allergies,

asthma, headache, and fatigue, as well as the carcinogenic, neurologic, and other risks

of chronic exposures to air toxics, such as formaldehyde, lead, and pesticides.

Chemical contaminants and biological agents, along with other indoor environmental

problems in the classroom, have frequently been the focus of attention.

California public school buildings are used by more than six million children in grades

K-12, close to 300,000 teachers, thousands of administrators and support staff, plus

countless parent and community visitors on a daily basis. Many of these individuals

spend a considerable portion of their time within the confines of school buildings over a

period of years. Thus, ensuring healthful conditions inside classrooms is a critical factor

in both teachers’ and students’ health and performance. Both groups may suffer the

detrimental effects of poor environmental conditions; however, children generally are

more vulnerable than adults to environmental contaminants and injury.

Asthma is among the most significant health problems associated with poor indoor

environmental quality (IEQ) in schools. Asthma is a chronic disease of lung tissue

involving inflamed airways and an increased sensitivity to contaminants in the air.

Asthma is a leading cause of school absences, and it may account for as many as three

million lost days of school missed by California students annually. In California, asthma

prevalence for children is about 10%, and is highest among children 12 to 17 years of

age. Schools with poor IEQ can contain many known asthma triggers – airborne

particulate matter, chemical contaminants, and allergens such as dust mites,

cockroaches, mold spores, and animal dander.

Poor environmental conditions in schools can also affect school productivity and student

performance. The available evidence suggests that IEQ problems, such as low outdoor

air ventilation rates and insufficient light, may reduce the performance of building

occupants, such as students in schools.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

5

An economic analysis of the costs of the impacts of poor IEQ on the educational sector

has not been conducted. However, it is estimated that the benefits of improving IEQ in

schools could total as much as $600 million – from reduced respiratory disease,

reduced allergies and asthma, reduced eye and throat irritation, and worker

performance unrelated to health. This estimate only accounts for the impacts on

teachers and school staff; it omits analogous effects on productivity and performance

among the many more students sharing the school environment.

In addition to the benefits of improved health and productivity, properly maintained

buildings prove to be more cost-efficient, because fewer resources are needed under

prevention-oriented programs than when neglect leads to costly repairs or untimely

replacement for major facilities.

Indoor Environmental Regulations and Guidelines for Public Schools

While school design and construction are subject to codes and regulations (discussed

further below), there are few specific standards or guidelines on environmental

conditions specifically addressing schools. Generally, Cal/OSHA (Department of

Industrial Relations) enforces several regulations relevant to schools as workplaces:

California Code of Regulation (CCR) Title 8 § 3362 requires that workplaces be

maintained in a sanitary condition, and subsection (g) requires that all types of water

intrusion be avoided, and remedied when leakage occurs. Cal/OSHA also enforces the

implementation of the Injury and Illness Prevention Program required under § 3203,

which requires development of a plan and training of appropriate staff to assure the

health and safety of the school employees. Finally, § 5142 requires ventilation systems

to be operated continuously and maintained as they were designed to be, in order to

provide sufficient fresh outdoor air.

The following guidelines and standards are applicable to, or can be applied to, school

environmental conditions, but few are required to be met, and those that are in

regulation are often not well enforced.

♦ Ventilation

Requirements for heating, ventilating, and air conditioning (HVAC) systems in

California stem from several sources.

• Title 24 of the CCR addresses energy efficiency, and also specifies minimum

outdoor air flows for different types of buildings; for classrooms, this is 15 cubic

feet per minute (cfm) per person or 0.15 cfm per square foot, whichever is greater.

• Cal/OSHA (CCR Title 8) enforces an HVAC standard for workplaces that requires

that ventilation systems be operated and maintained to supply at least the

minimum amount of outside air that was required at the time the system was last

permitted.

• The American Society of Heating, Refrigerating, and Air Conditioning Engineers

(ASHRAE) provides professional guidance on minimum ventilation rates based

largely on human health and comfort. While not regulatory, ASHRAE Standards,

specifically Standard 62, Ventilation for Acceptable Indoor Air Quality, is an
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

6

important reference for California’s ventilation codes and recommended comfort

levels. However, ASHRAE’s standards are not set specifically to protect children.

• Carbon dioxide concentrations can serve as an indicator of ventilation sufficiency.

Guidelines using indoor carbon dioxide concentrations as an indoor air quality

indicator are available from ASHRAE and other sources, and range from about

800 to 1,200 parts per million (ppm) as a “not to exceed” level.

♦ Temperature and Relative Humidity

Indoor thermal conditions are generally not subject to regulation. ASHRAE ‘s

Standard 55-1992 provides guidance on thermal comfort, which can be a complex

function of season, occupant activity, clothing, air movement, and other factors.

• ASHRAE’s acceptable temperature range is 68-75°F in the heating season and

73-79°F in the cooling season under typical humidity and airflow conditions.

• ASHRAE’s acceptable range for relative humidity is 30% to 60% under common

conditions; higher humidity also should be avoided to prevent mold growth.

♦ Air Pollutants

There are standards set to protect workers in the work environment, and outdoor air

quality standards and guidelines set to protect the general public. However, none of

these are targeted toward protecting children, and only worker exposure levels are

required to be met within school settings.

• Permissible Exposure Levels (PELs), developed by the California Occupational

Health and Safety Standards Board, are limits for chemical air pollutants in

industrial and other work environments.

• Federal and State ambient air quality standards (AAQS), established by U.S. EPA

and the ARB, respectively, are developed to protect the general public from the

harmful effects of traditional pollutants in outdoor air. California’s AAQS are

currently under review to ensure that they are protective of sensitive populations

including children.

• Chronic and acute Reference Exposure Limits (RELs) developed by Cal/EPA’s

Office of Environmental Health Hazard Assessment (OEHHA) are non-regulatory

guidelines developed to prevent harm from toxic air pollution.

• In the absence of indoor air quality guidelines or standards, the AAQS and

OEHHA’s RELs for acute and chronic effects may serve as useful guidelines for

acceptable classroom air quality, but may not be fully protective of children.

• OEHHA has developed an interim 8-hour REL of 27 ppb, 8-hour averaging time,

for formaldehyde, an almost ubiquitous indoor air pollutant, to identify the level

below which irritant effects would not be expected to occur during typical day-time

occupancy of buildings. Other 8-hour RELs are not yet available.

• Cancer potency factors developed by OEHHA can be used to judge potential

cancer risk.

♦ Noise

Voluntary standards and guidelines for classroom noise have only recently been

developed.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

7

• The American National Standards Institute (ANSI) and the World Health

Organization (WHO) recommend 35 decibels (dBA) as a limit for background

classroom noise.

• The California Collaborative for High Performance Schools (CHPS) set the

maximum noise level for unoccupied classrooms at 45 decibels as a prerequisite

for the designation of a high performance classroom.

• The outdoor noise limit in many California communities is 55 dBA.

♦ Lighting

The Illuminating Engineering Society of North America (IESNA) has established

guidelines of a minimum of 30 foot-candles of light for large type/high contrast

materials, and a level of 50 foot-candles for small type and/or low contrast materials.

♦ Lead in floor dust

The U.S. EPA standard is 40 micrograms of lead in dust per square foot for bare

floors or carpets. The maximum allowable lead level is 250 micrograms per square

foot for interior window sills. These standards are based on surface wipe samples

and were developed for the protection of the most susceptible group, children under

6 years of age.

Design and Construction of Portable Classrooms

Portable classrooms used throughout California are typically 12x40 feet modular units

fitting together in pairs (or more), with a metal roof, and a wall-mounted heat pump with

air conditioning. Generally, the windows are relatively small, but they are usually

operable. Exteriors and floors are usually plywood or composite wood siding, and

interior walls are most often vinyl-covered tackboard. In recent years, designs with a

concrete wall as well as two-stories have become more common. Most importantly,

numerous improvements have been made in roofing, siding, windows, heating and air

conditioning, lighting, and insulation.

All public school facility construction within the State of California, including portable

classrooms, must comply with the California Building Standards Code. This code is

contained in Title 24 of CCR. The State has some of the nation’s most stringent energy

efficiency standards, which are contained in CCR Title 24 (Part 6) and include

provisions on the building envelope, water-heating systems, lighting, and HVAC

systems. The Department of General Services (DGS) oversees the design,

construction, and financing of educational facilities.

♦ The Division of the State Architect (DSA) is responsible for reviewing design plans

and construction for all new school facilities, additions, alterations, and

modernization projects, including portable classrooms. Although the building design

plans and the State Building Standards Code address all aspects of the school

design and construction, the DSA plan-check focuses on three areas: the structural

design (i.e., seismic safety), handicap accessibility (i.e., compliance with the

Americans with Disability Act and related standards), and fire & life safety concerns
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

8

(e.g., sprinklers, fire alarms). DSA also certifies inspectors, which schools are

required to hire to oversee on-site school construction and portable manufacture.

♦ The Office of Public School Construction (OPSC) administers state appropriations

for public school facilities construction and modernization, leasing of relocatable

classrooms, and funding for deferred maintenance. OPSC purchases and maintains

a set of portable classroom units as part of the State Relocatable Classroom

Program. This program was initially established to provide classrooms on an

emergency basis, but portables now are also used by districts impacted by rapid

growth and modernization projects. The State owns approximately 6000 portables

that are leased to school districts on an as-needed/as-available basis. The State

purchases about 200 new portables per year, on average. Funding for portables

comes primarily from lease revenues. Current costs for a portable classroom range

from about $25,000 to $47,000; districts lease them for $4000 per year.

The OPSC continually reviews the classroom specifications to assure that they meet

or exceed Title 24 requirements. Current OPSC specifications exceed the minimum

Title 24 standards in several areas, including:

• An interior moisture barrier is required at all metal roof structures to prevent moist

interior air from contacting metal elements and producing condensation.

• Wall insulation requirements have been upgraded from R-11 to R-13, and ceiling

insulation has been upgraded from R-19 to R-22.

• All windows are now dual glazed “low e.”

• Lighting systems include T8 fluorescent type with photoelectric control.

State Relocatable Classrooms have always met or exceeded construction codes in

effect at the time of approval. Additionally, they comply with ASHRAE standards for

temperature control.

OPSC also has taken, and plans to take, other steps to improve the state portable

classroom specifications for their impact on indoor environmental quality. For

example, all adhesives used for carpet or rubber baseboard installation must be

water-based adhesives, and lighting systems are designed to provide 50 footcandles at the desk level. OPSC’s wallboard has been tested and contains no

detectable formaldehyde residue. However, OPSC plans to require that tackboard

wall material and fiberglass insulation contain no detectable formaldehyde. They are

also considering several options for quieting noisy ventilation systems.

OPSC is currently developing several relocatable classroom guides for schools that

lease relocatables through the State Program. The guidebooks will provide

information to custodians, maintenance staff, and teachers to help assure that

classrooms are properly maintained. Additionally, OPSC has arranged for

distribution of the guides whenever new relocatables are delivered to a site.

OPSC also administers the Deferred Maintenance Program (DMF), which provides

funding to school districts for major repairs and upgrades, such as new roofs and
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

9

plumbing. However, funding for the DMF is variable, fluctuating from year to year.

Extreme Hardship Grants are available for urgent projects needed within one year

for health and safety or structural reasons for traditional classrooms.

Programs for Improved School Buildings

Several programs in California are already addressing some of the problems identified

in this study, and others are under development or have been proposed. Some new

programs were begun either before or during the period of this study, and provide

mechanisms to implement some of the recommendations discussed in this report.

These programs include:

♦ State new school construction and modernization bonds. California has recently

made historic investments in new school construction and modernization of older

schools. In 2002, Governor Davis signed legislation to place a $25 billion school

bond package on the state ballot. California voters approved the first bond in

November 2002, providing school districts with $11.4 billion in funding for new

construction and modernization of K-12 schools. Already more than $6 billion has

been allocated to school districts statewide to begin new construction and

modernization projects. New bond funding will reduce the need for portable

classrooms in California schools, and where the need remains, will provide funding

to replace aged portable classrooms with classrooms that meet high environmental

and health standards. The remaining $13 billion bond is scheduled to go before the

voters on the March 2004 primary ballot.

♦ The Los Angeles Unified School District’s (LAUSD) Facility Inspection Program is a

comprehensive self-assessment of all district schools for basic health and safety

conditions (Bellomo, 2003). After their first round of inspections, LAUSD officials

determined that many of the basic problems found could be remedied by custodians

or other school personnel, generally at less than $50 additional cost. Some of these

basic problems included factors such as blocked fire extinguishers and improper use

of electrical cords, important safety items critical to child safety not studied in the

Portable Classrooms Study reported in this document. However, they also included

items such as proper storage of chemicals and implementing an Illness and Injury

Prevention Program, which also are handled by school personnel. LAUSD has

developed a detailed tracking system to assure that problems identified are

addressed. LAUSD’s “Safe School Inspection Guidebook,” a checklist, is provided

in Appendix V, and can serve as a good starting point for other districts and schools

undertaking a self-inspection. LAUSD also has adopted the CHPS criteria for new

school construction (see next bullet).

♦ The Collaborative for High Performance Schools (CHPS) is a consortium of public

agencies and energy utilities in California working to facilitate the design and

construction of “high performance” schools. These schools serve as models of

energy and resource efficiency, as well as provide a healthy and comfortable

environment conducive to the learning process. The core of CHPS is a set of Best
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

10

Practices Manuals that provides an array of options for improved school planning

and design. This approach allows school boards to declare their intentions to build

high performance schools, despite a lack of explicit knowledge of specific

components. The CHPS criteria give facility designers latitude to incorporate

practices in a manner that best fits the district’s needs and budget. Only a very

small percentage of California districts and schools have utilized CHPS’ excellent

guidance to date.

♦ U.S. EPA’s IAQ (Indoor Air Quality)Tools for Schools Program is a program

developed to help schools identify and prevent indoor air quality problems, using a

team approach to school IEQ management. The program provides educational

materials and tools for evaluating the impact of school maintenance functions and

occupants’ daily activities on indoor air quality. U.S. EPA makes their IAQ Tools for

Schools action kits available at no cost, and has funded numerous training

workshops, including many in California. Despite the outreach, awareness and use

of the program among California schools are still relatively low: in this study, 35% of

schools reported that they were familiar with the program, and 11% of California

schools reported that they use all or part of the program. This may be due to a

misperception regarding the level of effort required: the program is adaptable to any

level of resources, and numerous schools in California have successfully

implemented the program and demonstrated its cost-effectiveness.

♦ An Interagency State Workgroup on Relocatable Classrooms was recently formed to

identify opportunities to implement Governor Davis’ sustainable building goals with

respect to portable classrooms. The workgroup is a subgroup of the State

Sustainable Building Task Force formed to implement Executive Order D-16-00.

The workgroup is in the early stages of reviewing and developing revisions to the

State specifications for portable classrooms leased by OPSC. The workgroup will

also be coordinating a program to upgrade existing classrooms.

♦ The Lead-Safe Schools Project began in 1998 as a joint project of the University of

California at Berkeley Labor Occupational Health Program, DHS’s Childhood Lead

Poisoning Prevention Program, and the state Department of Education. The Project

provides training, focused documents, and a hotline for training school maintenance

department staff regarding sources (primarily old paint) and remediation of lead in

California schools. Grant funding for the training recently ended. Starting in 2004,

the Lead-Safe Schools Protection Act (SB 21, Escutia, Statutes of 2002) requires

that schools certify that they will follow all standards for the management of lead

hazards when they apply for state modernization funding.

♦ Integrated Pest Management (IPM). The Healthy Schools Act of 2000 (AB 2260,

Shelley) mandated the Department of Pesticide Regulation (DPR) to promote

voluntary school IPM programs. IPM includes the use of non-chemical practices to

reduce pest populations, using least toxic pesticides to treat infestations above

designated thresholds, and training relevant individuals regarding IPM approaches.

The Act also directed schools to comply with certain requirements to reduce
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

11

exposures to pesticides at schools, such as parental notification of pesticide

applications, warning signs, recordkeeping at schools, and reporting of pesticide use

by licensed pest control businesses that apply pesticides at schools. Meeting these

requirements is the responsibility of individual school districts, and DPR does not

enforce compliance.

♦ Blueprint for School Facility Finance. In a 2001 report, the California Legislative

Analyst recommended changes to the finance system for K-12 school facility capital

outlay (LAO, 2001). The authors identified several key deficiencies with the existing

finance system, and proposed a new "blueprint" for more effectively financing new

school construction and modernization:

• Annual appropriations for capital outlay, rather than the current approach of

intermittent voter-approved bonds;

• Allocation of funds to school districts based on a per-pupil formula, rather than

the current project-specific, first-come, first-served basis;

• More local control and responsibility through an accountability program; and

• Transition funding to address current unmet facility needs.

Because school facilities are such a substantial investment and it is the responsibility

of the districts to ensure their maximum useful life, the LAO felt that facilities

maintenance funding would be more efficient if there were greater local

accountability. The LAO suggested that "districts should set aside a prescribed

annual contribution from their operating budget to fund facility maintenance, or

certify at a public hearing that a lower amount is sufficient to meet their maintenance

needs." The LAO recommendations would lead to a more focused state role in

technical assistance and oversight regarding planning, constructing, and maintaining

school facilities.

METHODS

The sampling approach used in this study was designed to obtain a statistically

representative sample of the “target” study population, which was defined as all public

schools in California with at least one portable classroom in spring 2001. The study

was conducted in two phases. Phase I consisted of a mail survey returned by 384 of

more than 1000 schools randomly selected statewide. For each school, the facility

manager and three teachers (two from portable classrooms and one from a traditional

classroom) were asked to complete detailed questionnaires on all aspects of the

classrooms. Additionally, formaldehyde sampling tubes were sent to about two-thirds of

the schools, for deployment in the three classrooms. In Phase II, a comprehensive

suite of chemical, biological, and environmental measurements were obtained in 201

classrooms at 67 schools statewide. Similar to Phase I, two portable classrooms and

one traditional classroom were studied at each school. Quality control checks were

performed for field and laboratory measurements, and for entry of questionnaire and

inspection data.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

12

RESULTS AND DISCUSSION

Both portable and traditional classrooms were found to have some environmental

conditions that need improvement. However, the most serious problems occur only in a

small percentage of classrooms. Remedies to address the problems identified are

available; however, the solutions would require a combination of actions by the State,

school districts, individual schools, manufacturers, and others. Many of the solutions

are relatively low-cost. For example, improved operation and maintenance would go a

long way to address many of the problems identified. Similarly, routine use of no- or

low-emitting building and classroom materials would typically add only minimal cost,

and quieter HVAC units can cost as little as $300-400 more per unit.

The results and recommendations presented below apply to both portable and

traditional classrooms unless otherwise specified. The primary results include the

following:

Ventilation

• In both types of classrooms, the amount of outdoor air exchange was inadequate

over 40% of the time (carbon dioxide levels exceeded 1000 ppm), and seriously

deficient for about 10% of the time (carbon dioxide levels exceeded 2000 ppm).

This is a critical finding; this latter group clearly did not meet state ventilation

requirements for continued outdoor air, and such deficiencies have been

associated with increased eye and throat irritation, lethargy, headache, and other

symptoms that can impair the learning process and reduce performance.

• 60% of teachers in portables indicated they turn off the ventilation system at times

due to excess noise; 23% of teachers in traditional classrooms reported doing this.

• Portables had more HVAC problems than traditionals, including higher rates of dirty

air filters (40% vs. 27%), blocked outdoor air dampers (11% vs. 3%), and poor

condensate drainage (59% vs. 12%) which can lead to microbial contamination.

Overall, the HVAC systems delivered adequate outdoor air and total airflows when

operated properly, so design capacity did not appear to be a common problem in this

study. Complaints of stuffy room air usually result from the HVAC not being operated

properly. This occurs primarily for three reasons: the thermostat control limits the

amount of time the system fan is operating; the outdoor air damper is blocked or in a

closed position; or the teacher simply turns off the system because the noise is

disruptive to class activities.

Excessive noise is the primary issue that needs to be addressed by HVAC and portable

classroom manufacturers; low noise levels should be specified by schools and the State

when purchasing new portables. In addition, operation and maintenance of HVAC

systems needs to be improved at many schools; training of facility staff and teachers

should be undertaken and regular inspection and maintenance programs followed to

avoid larger problems that can result when ventilation systems are not properly

operated and maintained.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

13

Dirty air filters can reduce

airflow and provide a breeding

ground for mold.

Temperature and Humidity

• 27% of portables and 17% of traditionals experienced temperatures below

ASHRAE’s thermal comfort standards for the heating season. Some classrooms of

both types also experienced temperatures above the ASHRAE standard range for

acceptable indoor temperature during cool weather.

• About 11% of all classrooms had relative humidity (RH) levels below 30%, and

14% had RH levels above 60%, outside of the ASHRAE standards range for

acceptable RH. Portable classrooms had slightly higher RH than traditional

classrooms.

• Properly operating and maintaining HVAC systems should remedy these problems

in most classrooms.

Air Pollutants

• Formaldehyde and other aldehydes:

 Indoor concentrations were elevated above OEHHA’s interim 8-hour REL for

acute eye, nose, and lung irritation in about 4% of the classrooms. This totals

about 10,720 classrooms, or at least 214,400 children (assuming 20 children per

classroom...there usually are more) exposed to formaldehyde levels that could

potentially result in irritant effects.

 Levels in virtually all classrooms exceeded OEHHA’s chronic REL (1.3 ppb) for

irritant effects and OEHHA’s one-in-a-million excess lifetime cancer risk level

(0.13 ppb) for formaldehyde. However, levels of formaldehyde in homes and

offices virtually always exceed these levels as well, and it is generally not

feasible to achieve levels below these guideline levels, because outdoor levels

near schools average about 3-5 ppb.

 Highest levels occurred primarily in the warmer seasons, which increases offgassing of volatiles such as formaldehyde.

 Portable classrooms generally had higher formaldehyde levels than traditionals.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

14

 A higher percentage of portables had building materials known to emit

formaldehyde, including pressed-wood materials and furniture, and carpets.

Formaldehyde emissions and levels in new building materials are estimated to

take about 3 to 5 years to off-gas before they reach relatively low levels.

 Alternative low- and no-emitting materials are available and should be used in

constructing new portable classrooms.

 Other aldehydes (especially acetaldehyde) also were generally found in higher

concentrations indoors than outdoors due to indoor sources.

• Volatile organic compounds (VOCs)

 Many VOCs were present indoors due to numerous common indoor sources, but

at levels similar to or lower than those in other indoor environments.

 Levels were below acute (immediate effects) risk levels.

 Some classrooms would exceed the one-in-a-million excess lifetime cancer risk

level for benzene and chloroform if the exposure continued for a lifetime.

However, the much shorter exposure in classrooms presents a much lower risk.

Also, outdoor levels exceeded the one-in-a-million risk level, and most of the

classroom risk is the result of emissions from common outdoor sources.

• Particulate matter

 Total particle counts were similar for both types of classrooms for PM10 and

PM2.5 size ranges, but the highest levels were seen in portables.

 Outdoor particle counts were usually about twice the indoor counts.

 Vehicle traffic was likely an important particle source for both types of

classrooms: over 50% of both portables and traditional classrooms were within

50 feet of parking lots, roadways, and loading docks. Portables often are sited

with their ventilation units and air intakes facing roadways and parking lots,

which may account for the higher counts in some of the portables.

Dumpsters and

loading docks

next to

classrooms:

odors, dust, and

motor vehicle

exhaust often

infiltrate into

classrooms from

outdoor

sources.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

15

Floor Dust Contaminants

Persistent contaminants were examined in floor dust samples collected with a

specialized vacuum cleaner. Analyses of floor dust can provide insight into potential

past and present contaminant exposures that cannot otherwise be obtained with a

routine air sample. Metals, pesticides, polycyclic aromatic hydrocarbons (PAHs, a

group of semi-volatile organic compounds emitted during combustion processes, many

of which are known or suspected carcinogens), and a variety of allergens were

examined in the dust samples.

• Metals

Elevated levels of lead were measured in some floor dust samples, most likely

from tracked-in soil or paint chips from old paint indoors or outdoors.

Arsenic levels were slightly higher in portables; more importantly, levels in both

types of classrooms appeared to exceed typical levels found in California soils.

Arsenic is a natural soil contaminant, and the primary source would be soil trackin. The elevated levels indicate possible additional school ground contamination

from fertilizers and wood preservatives, some of which contain arsenic.

• Pesticides

 Residues of both generally available and restricted-use pesticides were found in

all floor dust samples, indicating the recent and historical use of pesticides in and

around schools.

 Six pesticides were detected in over 80% of the samples: esfenvalerate,

chlorpyrifos, cis- and trans-permethrin, o-phenylphenol, and piperonyl butoxide.

The sale of chlorpyrifos for use in schools was banned in late 2001, but

chlorpyrifos can last up to a year or more in the environment. The five other

pesticides last just a few weeks.

 Pesticides enter classrooms either during application or by being tracked in on

shoes or clothing from the outdoors.

 Children can be exposed to pesticides through inhalation, ingestion (hand-tomouth activity), and dermal contact. Children in the lower grades tend to spend

a substantial amount of time sitting on the floor, bringing them into closer

proximity to pesticides found in floor dust.

 Further assessment of these pesticide results is underway.

• Polycyclic Aromatic Hydrocarbons

 Most of the 16 PAHs studied also were found in over 80% of the classroom

samples, but levels in the floor dust were low relative to levels found in homes in

recent studies.

 Average levels were similar in portable and traditional classrooms, but portables

had the highest levels. The reason for this is not known.

• Allergens

 Cat and dog allergens were found in more than half of the classroom samples.

The concentrations were generally below sensitization levels; however,

classroom levels could cause symptoms in persons with pre-existing allergies.

 Cockroach and dust mite allergens were found only infrequently.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

16

Moisture and Mold

• In the Phase I mail survey, 69% of the teachers reported smelling musty odors in

their classroom, 43% reported current or previous floods or leaks, and 11%

reported visible mold.

• Field observations by the study technician in Phase II showed that:

 21% of the portable classrooms and 35% of traditionals had visible water stains

on the ceiling, and 13% of portables and only a few traditionals had visible

water stains on the floor.

 17% of all classrooms (12% portables, 20% traditionals) had excess moisture

measured in the walls, ceiling, or floor. Excess moisture was measured as

material moisture content above levels measured in comparable known dry

material.

 3% of portables and almost no traditionals had visible mold on the ceilings; 3%

of all classrooms had visible mold on exterior walls.

Water stains and measurements of excess moisture in building materials often indicate

hidden mold, and at a minimum indicate a moisture problem such as a leak that needs

to be remedied. Any mold present in a classroom or its wall voids, flooring or plenum

should be properly remediated, since mold can trigger allergy symptoms and asthma

attacks in individuals with those sensitivities. Proper remediation may range from

scrubbing a small area with detergent and water to following procedures also used for

asbestos remediation. In all cases, the moisture source must be corrected.

Water leaks in roofs and near HVAC units are common causes of

moisture and mold problems.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

17

Noise

• All classrooms exceeded the recently developed ANSI acoustic standard and the

WHO guideline of 35 decibels background noise for unoccupied classrooms.

• A substantial portion of unoccupied classrooms (50% portables, 38% traditionals)

had measured noise levels exceeding the outdoor nuisance standard of 55

decibels used by some California cities. It is excessive noise levels that lead some

teachers to turn off the HVAC systems.

• Stakeholders have indicated that a noise level of 45 decibels is achievable with

some associated costs and focused effort; 35 decibels appears technologically and

financially unattainable at this time. California does not have a noise guideline or

standard for classrooms. CHPS has set a maximum level of 45 decibels as the

goal for high performance schools.

Lighting

• About one-third of classrooms do not meet IESNA professional design guidelines

of 50 foot-candles for low contrast materials, and a small percentage of classrooms

do not meet the guideline of 30 foot-candles for high contrast materials.

• Portable classrooms had somewhat lower lighting levels than traditional

classrooms.

Lighting was inadequate in onethird of the classrooms.

Daylighting is best with proper

design and location, but can lead to

glare and shadows if not welldesigned.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

18

RECOMMENDATIONS

Actions are needed at all levels to provide classroom environments that are healthy and

conducive to effective learning for K-12 students. Approaches to prevent and remedy

most of the problems identified in this study are available; while some may be subject to

fiscal constraints, most often what is needed is systematic review and attention to these

issues. Many of the problems identified in this study can be addressed through meeting

existing State standards and guidelines (primarily those of Cal/OSHA), including

requirements to provide continuous outdoor air exchange; improved operation and

maintenance programs; and focused training efforts. Many can be addressed at

relatively low cost.

There are four key approaches needed to remedy the problems identified in this study,

each with several specific recommendations for implementation. The four over-arching

approaches are:

♦ Direct and assist schools to comply with State regulations, especially workplace

regulations related to operation and maintenance.

♦ Develop and promote “Best Practices” for design, construction, operation and

maintenance of school facilities.

♦ Improve support (funding and training) for school facilities and staff.

♦ Establish needed guidelines and standards for school environmental health.

Each specific recommendation below supports one or more of these over-arching

approaches. The specific recommendations are presented in two groups:

Group 1: includes actions that are high priority and would yield high benefits at

relatively low cost. These recommendations should be pursued within the next

one to two years.

Group 2: these recommendations are also a priority, but will require a longerterm effort and/or additional resources in order to be fully implemented. These

actions should be initiated in the next year or so, but may require four to five

years to implement fully.

Group 1: High Priority, High Benefit Actions, with Relatively Low Cost

Group 1 recommendations build largely on regulations, programs and activities that are

already in place but that are not fully met or utilized.

1. Meet State Regulations. Schools, districts, and the state should assure that all

school buildings meet all relevant State regulations, particularly those related to
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

19

operation and maintenance. Many classrooms do not meet various existing State

standards, and meeting those regulations would go far to provide healthful

conditions in classrooms. For example, operating HVAC systems as they were

intended to be operated to assure adequate outdoor air ventilation, per Title 8

Section 5142; developing a health and safety program and training employees to

implement that program, per requirements of the Injury and Illness Prevention

Program regulation; and maintaining sanitary conditions and correcting water

intrusion, leakage, and uncontrolled accumulation of water to reduce the potential for

mold growth – all workplace requirements enforced by Cal/OSHA – would correct

several of the major problems seen in classrooms. To achieve this, many districts

may need to increase their maintenance staffing: many districts do not meet the

maintenance staffing ratios recommended by the California Association of School

Business Officials (CASBO). Some remedies may not be low-cost, depending on

the nature of the non-compliance.

2. Conduct District and School Self-Assessments. Districts/schools should conduct

“self-assessments” of basic safety and health conditions, similar to the selfinspection program undertaken by the LAUSD. In addition to assessing whether

state regulations are being met, self-inspections can also be used to remedy obvious

problems that are not necessarily regulated, and as a first step to begin to

incorporate “Best Practices” into operation and maintenance functions (see below).

The LAUSD’s basic checklist is provided in Appendix V; districts/schools can use all

or part of it to conduct their own walk-throughs and identify key problems in the near

term. Conditions that can be corrected with little or no cost should be remedied

promptly. Plans should be developed to obtain resources to address those that

require additional funds to remedy; for example, noisy HVAC units should be

scheduled for modification or upgrade.

3. Require IEQ Management Plans. The State should require districts and schools to

develop an IEQ Management Plan. Such a plan would complement and extend the

benefits of the self-assessment discussed above. The U.S. EPA’s IAQ Tools for

Schools Kit provides guidance for developing such a plan: see

http://www.epa.gov/iaq/schools/. Visalia, Saugus, Clovis, and San Francisco,

among others, have successfully and cost-effectively implemented IAQ Tools for

Schools in their schools. Districts and schools should implement key provisions of

the program and other preventive operation and maintenance measures that are

high benefit/low cost, including:

a. Appoint an IEQ manager and form an IEQ team.

b. Establish a regular inspection and maintenance schedule; ensure that HVAC

systems are thoroughly cleaned and inspected at least annually.

c. Use checklists for core inspection and preventive actions.

d. Educate the building occupants: e.g., ventilation systems should remain “on”,

and pollutant sources, such as “air fresheners”, should not be brought into the

classroom.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

20

e. Implement procurement policies and practices for classroom furnishings and

supplies that assure good indoor air quality, such as specifying desks and

bookcases that emit no formaldehyde.

4. Establish “Best Practices” Policy. The State should establish a policy to

incorporate “Best Practices” into the design, construction, operation, and

maintenance of new California schools, especially the measures developed by the

Collaborative for High Performance Schools (CHPS). Because of the large number

of new construction and renovation projects statewide at this time, there is a unique

opportunity to foster a new generation of classrooms that provide a healthful

environment conducive to learning. The CHPS Best Practices Manuals provide an

array of options and information that can be used in designing, constructing, and

renovating school buildings. CHPS-based schools have a high potential for reduced

energy consumption, and thus save energy dollars as well. The CHPS manuals and

videos are available at http://www.chps.net/; manuals for operation and maintenance

are under development. Districts and schools should use CHPS Best Practices to

the fullest extent feasible, at a minimum incorporating a few of the low-cost options

that are suitable for their situation. Additionally, specific recommendations gleaned

from this study and from stakeholders’ input, are included in Appendix VI. Key

examples are:

a. Specify no- and low-emitting building materials and furnishings in construction

contracts and solicitations. This should include using exterior grade wood

products or other low-emitting materials in wall & floor materials; noformaldehyde insulation, ceiling tiles, and cabinetry; and other low- or noemitting materials to avoid elevated formaldehyde and VOC levels.

b. Specify HVAC systems that provide sufficient airflow at less than 45 dBA.

c. Design sprinklers and landscaping properly so water does not hit the building,

and drains away from the structures.

5. Expand State Design Review. State-level design review for new buildings and

major renovations should be expanded. Review and approval of elements such as

ventilation system design and building materials should be added to the routine

structural, fire and life-safety, and accessibility plan-check function of the Division of

the State Architect (DSA). The DSA is currently initiating specification revisions and

implementing a more proactive approach in plan reviews, but additional trained staff

are needed for the additional work. DSA and OPSC should be permitted to hire the

needed staff to the extent resources allow.

6. Assure Proper Siting. Portable classrooms should be sited appropriately, away

from highways and busy roads, and with proper grading. Individual portable

classrooms should not be placed over low drainage areas that experience flooding.

The foundation skirt should be at least six inches or more above ground level to

prevent wicking of water up the wall, and adequate crawlspace ventilation should be

specified. Some of these measures may not be low cost for some schools.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

21

7. Limit Noise Levels in Classrooms. Implement an interim state requirement for a

maximum unoccupied classroom decibel level of 45 dBA in new classrooms, and

encourage specific sound reduction measures, especially reduction of noise from

HVAC systems and lights.

Group 2: Priority Actions Requiring a Longer Term Effort and/or Substantial

Additional Resources

8. Assure stable, long-term funding. The State and districts need to develop stable,

long-term funding mechanisms and sources for both school construction and

preventive maintenance. Current funding programs are strained, fluctuating, and

often function on a short timeframe. The current year-to-year fluctuation of the

existing Deferred Maintenance Program does not provide stable, consistent funding

for long-term planning and preventive maintenance. Implementation of the

recommendations of The California Master Plan for Education drafted by a Joint

Legislative Committee and A New Blueprint for California School Facility Finance by

the Legislative Analyst’s Office (May 2001) would provide some substantial

progress, particularly for construction. However, preventive maintenance is not

adequately addressed in these plans, and requires further action.

9. Develop Focused Training. The State should develop and offer coordinated

training programs and materials for facility managers, custodial staff, and teachers,

in cooperation with interested organizations. Those who are closest to the

classroom are often not aware of current “best practices” for operation and

maintenance of classrooms. For example, teachers inadvertently bring pollutant

sources into the room, improperly adjust thermostats, or take other actions that can

have a major impact on the environmental conditions of the classroom. Training is

an important part of U.S. EPA’s Tools For Schools Program. Focused statewide

training programs are needed over the long-term to assure that key school staff

receive appropriate training, so that they can routinely train new staff as they come

on board. DSA and OPSC should develop training programs and materials in

consultation with ARB, DHS, CEC, Cal/OSHA, and other relevant agencies, as well

as CASBO, CASH, and other relevant external groups. These should include:

a. A Training and Certification Program for School Facility Managers. Success

in operation and maintenance is often a function of the strength and

knowledge of facilities directors, yet there are few credentials districts can

apply in their selection of key facility department personnel. Districts should

hire trained, certified facility managers.

b. Development and routine distribution of training materials for custodial staff

on proper vacuuming and cleaning procedures. Effective vacuuming of

carpets requires an efficient vacuum plus a reasonable “residence time” of the

vacuum on the carpet surface in order to effectively remove particles. This

can effectively reduce persistent contaminants in carpeted classrooms.

Vacuums do not need to be true HEPA, but do need to be efficient, and have

virtually no particle leakage in the exhaust. Additionally, use of “safe" liquid or

spray cleaning products is a key component of a healthy building.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

22

c. Development of training materials and programs for teachers that builds on

information in EPA’s Tools for Schools Kit, and includes more specific

information on California ventilation requirements and sources of indoor

pollutants.

10. Implement Integrated Pest Management Programs. Integrated Pest

Management Programs should be implemented at all schools. The passage of the

Healthy Schools Act of 2000 established requirements for schools to notify parents

of pesticide use and to consider IPM. Successful application of IPM has been

sufficiently widespread to support its implementation at all public schools, and to

eliminate the use of pesticides with the greatest potential for toxic effects by school

personnel. A program of preventive housekeeping practices and use of least-toxic

pesticides when application is necessary has many benefits. See the Department of

Pesticide Regulation website at

http://www.cdpr.ca.gov/cfdocs/apps/schoolipm/main.cfm.

11. Retire older portable classrooms. Classrooms should be removed and replaced

when they become unserviceable or do not provide an adequate learning

environment for children. Some older portables are well past the stage at which they

should have been replaced with a new portable or a site-built classroom. New

portable or site-built buildings will generally not only provide an improved

environment but also will be more energy-efficient, with substantially reduced energy

costs relative to the old buildings.

12. Develop and require full building commissioning procedures. These

procedures are “best practices” for new buildings and classrooms. They should

include complete testing of HVAC, lighting, and other building systems under normal

and high-capacity operational conditions.

13. Improve school facility database. The State needs an effective system to

inventory public school facilities. These represent among the State’s greatest set of

assets, yet there is no complete database on the condition, location, or even number

of school buildings.

14. Convene a task force on noise. A task force of experts in audiology, medicine,

education, and related fields should be convened by the State to develop a

California indoor noise guideline or standard for K-12 schools. If needed, promote

technology development to meet such a guideline or standard.

15. Develop State-level chemical exposure guidelines or standards for

classrooms. There is a lack of benchmarks for fully assessing and assuring

healthful environmental conditions specific to classrooms and to the children and

teachers who occupy them. Currently available guidelines and standards applied in

this report may not be fully protective of children.
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23

16. Re-design portable classrooms from the ground up. Although many

improvements have been made in recent years, many portable classrooms

manufactured today are still based on designs and materials that have been

available for 20-30 years or more, and on an assumption of a need for frequent

relocation, which has not proven to be common. Southern California Edison,

Lawrence Berkeley National Laboratory, and several portable classroom

manufacturers have begun to develop very different styles of relocatable classrooms

which use an integrated, “whole-building” approach. These should be fully

developed and used on a trial basis under different conditions to determine if these

newer designs might better meet future classroom needs.

Implementation of some of the recommendations above will clearly incur costs to those

involved, and will require fiscal planning to achieve. However, the cost of not taking

these actions appears high – potentially harmful impacts on children’s and teachers’

health, reduced learning, reduced educational progress, and, in some cases, higher

costs to fix facility problems when they become more serious. Most importantly, State

building, ventilation, and workplace regulations have been developed to assure safety

and health, and must be met.

The LAUSD’s self-inspection program has shown that much can be done at relatively

low cost, and provides a good starting point. The CHPS Best Practices Manuals and

U.S. EPA’s IAQ Tools for Schools Action Kits provide readily available guidance that

can be used by districts and schools at varying levels, based on their individual

resources and situations. The experiences of Visalia, Saugus, Clovis, San Francisco,

and other districts have shown that IAQ Tools for Schools can work well in California.

More detailed recommendations for schools and districts are provided in Appendix VI,

which is a working document that will be updated periodically and made available on

ARB’s website.

CONCLUSIONS

Environmental health conditions that require improvement were identified in this study.

These include a variety of problems, such as inadequate design, operation, and

maintenance of ventilation systems; contaminants present at undesirable levels in the

air and floor dust; excessive noise levels; inadequate lighting; and mold and moisture

problems. A number of programs initiated by the State, school districts, and others

before or during the conduct of this study are already beginning to address some of

these concerns. However, much more must be done to assure that existing problems

are remedied and future problems prevented. The State, school districts, school

administrators, school facility managers, teachers, parents, manufacturers of portable

classrooms, manufacturers of ventilation systems, and others who provide materials

and supplies used by our schools all have an important role in improving the

environmental health conditions of our schools. Most importantly, California needs to

transition from a focus on remediation to a focus on prevention.
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1. INTRODUCTION

The Air Resources Board (ARB) and the Department of Health Services (DHS) jointly

conducted a study of environmental health conditions in California’s portable

classrooms from 2000-03. This study, called the California Portable Classrooms Study,

is the most comprehensive study of environmental conditions in kindergarten through

12th grade (K-12) classrooms to date, and provides important information for State and

local decision makers working to assure a safe, healthful, and productive learning

environment for California children. This report to the California Legislature provides an

overview of the study, summarizes conditions identified in the study that need to be

addressed at the State and local levels, and discusses options for assuring healthful

conditions in both portable and traditional classrooms. The information presented in this

report is based on the study results, as well as information provided by state agencies,

school districts, consultants, and interested stakeholders.

1.1 Mandate and Need for the Study

The California Portable Classrooms Study was conducted at the request of Governor

Gray Davis and the State Legislature (AB 2872 Shelley, 2000, California Health and

Safety Code Section 39619.6; see Appendix I for full text), with an allocation of

$1 million for the study. Their request was prompted by concerns that California’s

schools, especially portable classrooms, might not provide adequate environments for

young students, and that they experienced unacceptable levels of problems such as

mold contamination, inadequate ventilation, poor temperature control, elevated

chemical contaminant levels, and excessive use of pesticides (Daisey and Angell, 1998;

Ross and Walker, 1999; U.S. GAO 1995, 1996). Questions were raised regarding the

true extent of these problems and whether they warranted state-level responses, school

or school district level responses, or a combination of actions at all levels.

These questions and assertions posed a serious concern because portable classrooms

have served an important need in California K-12 public schools. About one-third (30%,

or 80,000) of the State’s 268,000 K-12 public classrooms in the 2000-01 school year

were portable classrooms (DHS, 2003: see Appendix II). Portable classrooms are more

quickly constructed and deployed to school sites. They have a lower initial cost than

traditional, site-built buildings, and thus are often more affordable under the school

budgeting processes in California. They can be obtained in a period of months rather

than years, allowing schools to accommodate rapidly changing enrollment needs due to

student population fluctuations. Their availability enabled the state to pursue class size

reductions in the 1990s to help facilitate improved learning achievement.

Until 1998, the State required school districts requesting funding to design and construct

schools with at least 30% portable classrooms. This requirement was imposed as a

cost-saving measure, with the expectation that districts would move classrooms rather

than build new ones as student demographics changed. However, student growth

continued and relatively few portables were being relocated. With the Leroy F. Green

School Facilities Act of 1998 and passage of Proposition 1A, this restriction was lifted,
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

25

and school districts were given greater flexibility in the design of their school, along with

a revised formula for financing, based on per-pupil grants.

1.2 Definition of Portable Classrooms

The California Education Code (Section 17070.15 (k)) defines “portable classroom” as

“a classroom building of one or more stories that is designed and constructed to be

relocatable and transportable over public streets, and with respect to a single story

portable classroom, is designed and constructed for relocation without the separation of

the roof or floor from the building, and when measured at the most exterior walls, has a

floor area not in excess of 2000 square feet.” Portable classrooms also are often

referred to as relocatable classrooms, and occur in a variety of styles and forms.

However, “modular” classrooms, which typically have some elements constructed offsite, may be either permanent structures or movable, and thus are not necessarily

synonymous with the terms “portable” or “relocatable”.

1.3 Purpose and Scope of the Study

The objectives of the California Portable Classrooms Study were to:

• Conduct a comprehensive study and review of the environmental health conditions

in portable classrooms.

• Identify any potentially unhealthful environmental conditions, and their extent.

• In consultation with stakeholders, identify and recommend actions that can be

taken to remedy and prevent such unhealthful conditions.

The Health and Safety Code directed that the study include review of design and

construction specifications, ventilation systems, school maintenance practices, indoor

air quality, and potential toxic contamination including mold and other biological

contaminants. Recommendations were to be developed to address the need for

modified design and construction standards, emission limits for building materials and

furnishings, and other mitigation actions needed to assure protection of children’s

health.

The study was conducted in two phases. Phase I consisted of a mail survey of more

than 1000 schools randomly selected statewide. For each school, the facility manager

and three teachers (two from portable classrooms and one from a traditional classroom)

were asked to complete detailed questionnaires on all aspects of the classrooms.

Additionally, formaldehyde sampling tubes were sent to about two-thirds of the schools,

for deployment in the three classrooms. In Phase II, a comprehensive chemical,

biological, and environmental measurements were obtained in 201 classrooms at 67

schools randomly selected statewide. Similar to Phase I, two portable classrooms and

one traditional classroom were studied.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

26

The State contracted with Research Triangle Institute (RTI), a not-for-profit scientific

research organization, through a competitively bid process to conduct the primary field

work of the study for both Phase I and Phase II. For Phase I this included selecting and

enrolling the sample of schools; formatting, mailing and analyzing the questionnaires;

and analyzing the formaldehyde data. In Phase II, RTI planned the details of the field

study; developed and refined sampling, analysis, and quality control protocols; handled

the many contacts with schools and districts; conducted all on-site sampling and

inspections; analyzed the samples collected; and prepared a final study report. ARB

directed the field contract, air monitoring, and data analysis; obtained equipment used in

the study; pre-tested the passive formaldehyde samplers used in Phase I; coordinated

the stakeholder participation; and contributed funds for analysis of classroom carpet

dust, a known reservoir for persistent contaminants such as pesticides and metals.

DHS developed and administered a preliminary survey of districts to obtain key

information on the numbers and ages of portables in each district; directed the school

and classroom sampling approach and the assessment of ventilation systems;

performed allergen analyses in the laboratory; and directed and reviewed the biological

sampling conducted by RTI.

The study was endorsed by the Superintendent of Schools at the time, Ms. Delaine

Eastin. The Superintendent’s endorsement was a key factor in obtaining the

cooperation of schools and school districts throughout the study.

ARB’s Research Screening Committee, an external scientific peer review group that

assures the quality of research funded by the ARB, reviewed and approved the Request

for Proposals for the contractor, the proposals received, and the draft final report from

RTI. Additionally, a small advisory panel was convened for review of the floor dust

sample collection and analysis, because this is a relatively new area of investigation in

the indoor air quality field.

A Project Executive Summary covering the key scientific results from the research study

is attached as Appendix III. The two-volume Phase I and Phase II final reports from the

field study are available on ARB’s web site at

http://www.arb.ca.gov/research/indoor/pcs/pcs.htm or upon request.

1.4 Stakeholder Participation

As directed in HSC § 39619.6, ARB and DHS consulted with relevant state agencies

and stakeholders at key points in the study. A website and email distribution list were

established to keep interested stakeholders up to date on the progress of the study.

ARB and DHS consulted with the Department of Education (CDE), the Department of

General Services (DGS; primarily the Division of the State Architect [DSA] and the

Office of Public School Construction [OPSC]), the Office of Environmental Health

Hazard Assessment (OEHHA), and other interested state agencies prior to the study

regarding the overall study design and detailed information to be obtained, and upon

completion of the final research report from RTI.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

27

Four public workshops were held at the beginning of the study−two each in northern

and southern California−to obtain input from interested parties on the basic study design

and specific information that should be obtained in the study. The information obtained

resulted in some modifications to the study design and improvements in the

questionnaires.

Four public workshops, again two each in northern and southern California, were also

held during the review period for the public draft of this document. The first workshop

was webcast, and all workshops included telephone accessibility, so that the public

could participate without being physically present at the workshops. Many useful

comments were received, and the report was modified as appropriate. Some of the

information received highlighted new products that are low- or no-emitting.

Summaries of the comments received during both sets of workshops are provided in

Section 6 of this report.
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2. BACKGROUND

California public schools house more than six million children in kindergarten through

12th grade, close to 300,000 teachers, thousands of administrators and support staff,

plus countless parent and community visitors on a daily basis. Many of these

individuals spend a considerable portion of their time for years within the confines of

school buildings. School indoor environmental conditions – temperature, humidity,

ventilation, lighting, noise, cleanliness, odor, and exposures to chemical contaminants

and biological agents – can affect both the health and productivity of teachers and

students, and thus support, or hinder, educational goals.

2.1 Indoor Environmental Conditions and Potential Health Effects

In recent years, concerns have risen among teachers, parents, and the public regarding

potential health risks at schools, especially associated with portable classrooms. The

concerns have focused on health complaints, similar to “sick building syndrome” or SBS

(more currently called “building-related symptoms: allergies, eye or respiratory irritation ,

headache, lethargy, etc.), as well as the risks of chronic exposures to air toxics, such as

formaldehyde, lead, mercury, and pesticides. The health impacts range from mild SBS

symptoms and an array of respiratory symptoms, to the perception of poor indoor air

quality, such as bothersome odors, to patent illness, such as increased rates of

infectious diseases (e.g., influenza and the common cold), asthma, and chronic

sinusitis. Chemical toxins and biological agents, along with other indoor environmental

problems in the classroom, are frequently the focus of concern.

Both students and school staff may suffer the detrimental effects of poor environmental

conditions; however, children are far more vulnerable than adults to environmental

contaminants and types of injury. Children’s breathing rates and metabolic rates are

significantly greater than adults relative to body mass. For example, in the same

environment as adults, children will breathe in and absorb proportionally greater doses

of airborne toxins. Because of their behavior, they also accidentally ingest more soil

than adults. Their immune systems are less mature.

Asthma is among the most significant health problems associated with poor indoor

environmental quality (IEQ) in schools. Asthma is a chronic disease of lung tissue

involving inflamed airways and an increased sensitivity to contaminants in the air.

Notably, the prevalence rate in the U.S. increased 74% from 1980 to 1995 (CDC, 2002).

Disproportionately higher rates are found among low-income populations, minorities,

and children living in inner cities. Schools with poor IEQ contain many known asthma

triggers – airborne particulate matter, chemicals, and allergens from dust mites,

cockroaches, and mold spores. Asthma is the number one cause of chronic school

absences, and it may account for as many as 3 million lost days of school missed by

California students annually (Taylor 1992). Currently, about 10% of California’s children

suffer from asthma (CHIS, 2003), with the highest prevalence found among 12-17 year

olds.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

29

Exposure to mold growth has been associated with worsening of asthma, allergies, and

eye, nose or throat inflammation. However, health-based criteria for evaluating

exposures to the spores, cell components, or chemical emissions from indoor mold

growth are not currently available. Numerous studies have found that indicators of

excess moisture such as musty odor and visible mold in buildings increase the risk for

respiratory symptoms and other health effects, and some studies have found

correlations of health effects with elevated levels of mold spores in schools and other

buildings (Meklin et al., 2002, Bornehag et al., 2001, Haverinen et al., 1999).

2.2 Potential Economic and Performance Impacts

Just as poor environmental conditions in schools may directly cause occupants’ ill

health, it also affects school productivity and student performance (U.S. EPA, 2003).

An extensive literature review was recently published, which identified limitations in

conclusive data; however, the available evidence suggests that IEQ problems, such as

low ventilation rate and less daylight or light, may reduce the performance of occupants,

including students in schools (Heath & Mendell, 2002).

An economic analysis has not been done specifically for the educational sector;

however, Fisk (2000) determined that the impacts of poor IEQ across the U.S.

workforce are as much as $250 billion per year (1996 dollars). Fisk’s results, scaled to

California educators, indicates that accrued benefits from improved IEQ in schools are

as great as $600 million (California Sustainability Blueprint report, 2002) − from reduced

respiratory disease, reduced allergies and asthma, reduced SBS symptoms, and worker

performance unrelated to health. This takes into consideration only the impacts on

teachers and school staff; it omits analogous effects on productivity and performance

that could be expected among the many more students sharing the school environment.

Improved IEQ in schools can reduce asthma-related medical cost (e.g., emergency

room visits and hospitalization) for children and staff, but it can also improve the

productivity and academic performance. Smedje et al., (2000) reported that the

incidence of asthmatic symptoms was lower in pupils who attend schools (in Sweden) in

which new ventilation systems have been installed. Students with exacerbated asthma

suffer chronic school absences, which can cause delays in academic progress. At the

same time, school districts suffer an economic loss, because revenues to California

schools are determined by student attendance.

It can be expected that a more comfortable setting would be more productive, but there

is limited data to quantify this. Among comfort parameters (temperature, relative

humidity, light, noise, and odor), a study of school lighting has produced the most

striking results. Researchers investigating lighting in an Orange County (CA) school

district determined that increasing/greater daylighting (natural light, such as that through

windows) improved learning rates (Heschong Mahone Group, 1999). The effect, as

determined by standardized test scores among elementary school students, was as

much as a 12% improvement over the school year.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

30

In addition to the benefits of improved health and productivity, properly maintained

buildings prove to be more cost-efficient, because fewer resources are needed under

prevention-oriented programs than when neglect leads to costly repairs or untimely

replacement for major facilities. A recent demonstration project in a Washington, DC

public school suggests that, when IAQ is allowed to deteriorate because HVAC systems

are not maintained, the required cost of repair after a 22 year period can be 5 to 30

times higher than the cumulative cost of annual maintenance needed to preserve IAQ

throughout that period.

2.3 Indoor Environmental Regulations and Guidelines for Public Schools

While school design and construction are subject to codes and regulations (see next

section), there are few specific standards or guidelines on environmental conditions

specifically addressing schools. In fact, IEQ standards exist only for schools as

workplaces, ostensibly to protect teachers and staff from potential health risks related to

occupational exposure. The California Occupational Safety and Health Standards

Board promulgates workplace safety and health regulations in Title 8 of the California

Code of Regulations. Cal/OSHA (Department of Industrial Relations, Division of

Occupational Safety & Health) enforces the standards for workplaces in California.

These include the General Industrial Safety Orders that buildings “... shall be kept

clean, orderly and in a sanitary condition [and] maintained in such conditions as will not

give rise to harmful exposure...” (CCR Title 8 Section 3362). Subsection (a) requires

the clean-up of unsanitary conditions, including mold, and subsection (g) was recently

added, requiring employers to correct exterior water intrusion, leakage from interior

water sources, and other uncontrolled accumulation of water, in order to prevent mold

growth. The State Education Code also establishes that it is the duty of the governing

(school) board to furnish, maintain, and repair school facilities (Education Code Section

17565 et seq.).

Cal/OSHA also enforces Title 8, Section 3203, the Injury and Illness Prevention

Program regulation, that requires employers to develop, implement, and maintain a

health and safety program that includes periodic inspections, correction of hazards,

communication with employees, training, and other actions. In addition, Cal/OSHA

enforces Permissible Exposure Limits (PELs), which are usually 8-hour time-weightedaverage standards. These standards are developed by the Occupational Safety and

Health Standards Board for the protection of working adults, often for specific chemicals

used in industrial processes/settings. They are generally based only on acute or irritant

effects, and are not necessarily intended to address the effects of chronic (long-term)

exposures.

Table 2.1 (at the end of this section) provides a summary listing of the standards and

guidelines discussed below.
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2.3.1 Environmental Contaminants

In general, PELs are usually much higher than indoor contaminant levels found in nonindustrial settings, and Cal/OSHA rarely finds PEL violations in schools (exceptions may

include chemical laboratories and industrial arts classrooms). However, these

standards are likely insufficient to protect vulnerable school occupants such as pregnant

teachers. School personnel include more vulnerable sub-populations than the “healthy

worker”, such as adults with chronic conditions, such as hypertension, and diabetes.

Likewise, PEL standards are not designed to protect children.

For the general public, the National Ambient Air Quality Standards (NAAQS) are set by

the U.S. EPA to regulate the outdoor concentrations of traditional pollutants to protect

public health. These standards for outdoor air do not apply to indoor settings, but may

serve as the minimum requirement for indoor air quality. California has its own state

ambient standards set by the ARB that are equivalent to or more stringent than the

federal NAAQS. With California Senate Bill 25 (SB 25, the Children’s Environmental

Protection Act), existing California ambient air standards are being reviewed to ensure

that children and infants are protected (ARB, 2000; ARB 2002). ARB also has

developed indoor air quality guidelines for some pollutants in homes. National and state

AAQS may be found at http://www.arb.ca.gov/aqs/aqs.htm, and ARB’s indoor air quality

guidelines are available at http://www.arb.ca.gov/research/indoor/guidelines.htm.

OEHHA has developed and published Reference Exposure Limits (REL) as guidelines

to prevent harm from air pollution. These non-regulatory health-based RELs were

developed by reviewing available scientific evidence of toxic chemicals, considering

both chronic and acute effects, to protect public health. In many cases, the REL is a

factor of 100 to 1000 times less than the corresponding PEL. Acute RELS are usually

applicable to exposures of about one hour, while chronic RELS address exposures that

last many years. In the absence of indoor standards, OEHHA’s RELs provide levels for

comparison to assure a healthful environment. Some RELs have been specifically

applied to indoor pollutants in non-industrial settings (Broadwin et al., 2000). For

example, an 8-hour REL for formaldehyde, the most widespread of indoor pollutants,

was set at 27 ppb to identify the level below which non-carcinogenic adverse health

effects would not be expected to occur. OEHHA’s RELs may be viewed at

http://www.oehha.ca.gov/air/acute_rels/acuterel.html (acute) and

http://www.oehha.ca.gov/air/chronic_rels/index.html (chronic).

Regulatory standards exist for lead and asbestos in schools, based on federal

regulations (see Table 2.1). Lead is a toxin that can cause learning disabilities,

decreased intelligence, kidney damage, and a host of other effects. U.S. EPA (2001a)

set a limit on the maximum allowable amount of lead in surface dust, based on wet-wipe

sampling. Children under 6 years of age are especially susceptible to its adverse

impacts, and toddlers are especially prone to ingesting lead through exposures to

contaminated surface dust, as well as deteriorating lead-based paint surfaces.
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32

In the absence of a regulatory standard for indoor radon, a voluntary guideline specifies

concentrations of 4 pCi/l or more as an action level to trigger re-testing and remediation

to reduce long-term indoor radon levels (U.S. EPA, 1993). Asbestos and radon were

not measured in the Portable Classrooms Study because of cost considerations and

because they are not expected to be a greater problem in portable classrooms relative

to traditional classrooms. Furthermore, federal law requires the assessment of

asbestos hazards in all schools (U.S. EPA, 1987), and a statewide investigation of

radon in California schools is already available (Zhou et al., 1998).

2.3.2 Ventilation and Comfort

Requirements for heating, ventilation and air conditioning (HVAC) of schools are

determined primarily by the California Energy Commission (CEC) and Cal/OSHA.

Design requirements for outdoor air ventilation rates in public and commercial buildngs,

including schools, are specified in the California Building Standards Code (CCR Title

24, §121). Although CEC’s focus in regulating HVAC performance is on energy

efficiency, minimum design levels are specified to assure sufficient outdoor air for

specific indoor environments. For the typical classroom, the greater of 15 cubic feet per

minute (cfm) per person or 0.15 cfm per square foot, is required; for special purpose

classrooms such as laboratories or auto shops, higher ventilation rates may be

required. While CEC’s standards address equipment design, Cal/OSHA’s mechanical

ventilation standard (CCR Title 8, §5142) addresses HVAC operation and maintenance

in workplaces. That standard requires that ventilation systems be operated

continuously when rooms are occupied to supply at least the minimum amount of

outdoor air as was required at the time the system was last permitted. It also requires

at least annual inspection of the HVAC system(s), and that maintenance records for the

HVAC system(s) be kept and be available during a Cal/OSHA inspection.

Non-regulatory guidelines exist for HVAC systems in school settings. The American

Society of Heating, Refrigerating, and Air Conditioning Engineers’ Standard 62,

Ventilation for Acceptable Indoor Air Quality, sets professional standards for minimum

outdoor air ventilation rates (ASHRAE, 2001), and Standard 55, Thermal Environmental

Conditions for Human Occupancy, sets indoor comfort levels for temperature and

humidity (ASHRAE 1992). While not intended as a health standard, ASHRAE Standard

62 has been historically adopted into state and local building codes, and continues to

serve as a foundation for related elements of the California energy standard. With its

continuous maintenance, addenda and appendices, Standard 62 continues to serve as

the most explicit guideline available that address IAQ in schools and commercial

buildings.

2.3.3 Noise and Lighting

Acceptable noise and lighting illumination levels for classrooms have been established

by non-government organizations, similar to ASHRAE, and serve as target values in the

absence of government standards. The American National Standards Institute (ANSI, a

non-government standard-setting organization) and the World Health Organization
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33

(WHO) have established a standard and guideline, respectively, of 35 decibels (dBA) for

background noise levels in (unoccupied) classrooms. This is a controversial noise limit,

as it is not easily met in standard classroom construction. The Collaborative for High

Performance Schools (CHPS), a California based non-profit organization, recommends

a maximum unoccupied background noise level of 45dBA and a 0.6-second maximum

(unoccupied) reverberation times. CHPS encourages designers to move beyond these

minimum prerequisites and achieve background noise levels of 35 dBA for all

classrooms. The ANSI and WHO recommendation for other indoor (non-school)

settings is 45 dBA, and the outdoor community standard used in many cities is 55 dBA.

For lighting, the Illuminating Engineering Society of North America (IESNA)

recommends lighting illumination levels for various kinds of visual tasks involving

materials with different print sizes and of high or low contrast. The California Energy

Code dictates the amount of lighting power (electricity) per classroom area that may be

used, to require the use of efficient lighting equipment to meet IESNA recommended

lighting illumination levels.

2.3.4 Mold

Floods, leaks, and water intrusion have long been concerns of school facility staff,

because these problems can cause safety hazards, as well as degrade building

structures and components. Recently, awareness has increased that dampness and

indoor mold can cause a variety of health effects and symptoms, including allergic

reactions, and can act as asthma triggers. Widespread publicity about “toxic mold” has

served as stark encouragement to school facility staff to be especially vigilant in

inspecting and repairing potential water intrusion problems quickly.

Unlike toxic chemicals, such as mercury or lead, there are no numeric standards to

apply in situations where indoor mold contamination is found. Therefore, the results of

this study cannot be compared to a standard. California recently passed legislation that

directs DHS to consider the feasibility of adopting permissible exposure limits for indoor

mold contamination (SB 732, Ortiz, Statutes of 2001). The form that SB 732 regulations

might take remains uncertain, as a number of expert panels have stated that PELs are

not appropriate for assessing mold exposure risk (ACGIH, 1999; NYC DOH, 2000). The

current SB 732 implementation plan includes convening a task force to advise DHS on

the development of practical guidelines to assess the health threat posed by the

presence of mold and to establish guidelines for identification of mold, visible or hidden

in an indoor environment, and for the remediation of mold. Despite the absence of

PELs or numeric standards, practical guidance has been developed for assessment and

clean-up procedures of indoor mold contamination (e.g., NYC DOH, 2000; U.S. EPA,

2001b).

Several guidance documents have been published specifically for school environments.

DHS has produced “Mold in Your School,” and the U.S. EPA released "Mold

Remediation in Schools and Commercial Buildings" in March 2001. This document

presents approaches for the assessment and remediation/cleanup of mold and moisture
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

34

Table 2-1. Selected Guidelines and Standards Relevant to School Environments.

 PARAMETER STANDARD, CODE or GUIDELINE SOURCE

Ventilation Mechanical: outside air ventilation rate: 15 cubic

feet per minute (cfm) per person or 0.15 cfm per ft2

,

whichever is greater.

Natural ventilation: allowed when openable

window area is 5% or more of floor area, space is

within 20 ft, and airflow is unobstructed.

Demand control ventilation (optional): CO2

below 1000 ppm, or CO2 [outside] + 600 ppm

Thermal comfort (guideline): Temperature and

relative humidity

Operation & maintenance: continuous operation of

ventilation system to provide minimum amount of

outdoor air when occupied; annual inspection and

written log

CCR Title 24, §121(b)

CCR Title 24, §121(c)4

ASHRAE 55-1992

CCR Title 8, §5142

Noise Classroom standard (unoccupied): 35 dBA

(decibels)

Classroom guideline: 45 dBA,

WHO guidelines:

 Classroom: 35 dBA

 Indoor community: 45 dBA

 Playground guideline: 55 dBA

CHPS classroom guideline: 45 dBA and 0.6 s

reverberation time (Max)

Outdoor community standard: 55 dBA

ANSI (2002)

Crandell (1992)

WHO (1999)

CHPS (2003)

City of Los Angeles,

others

Lighting Large print/high contrast: 30 foot-candles

Small print/high contrast or large/low contrast:

50 foot-candles

IESNA (2000)

Formaldehyde Acute REL: 76 ppb (1-hr average)

Interim REL: 27 ppb (8-hr average)

Chronic REL: 2.4 ppb (long-term average)

 REL= Reference Exposure Limit

 ppb=part per billion

OEHHA (1992)

Broadwin (2000)

OEHHA (2001)

Lead dust Federal standards: 40 micrograms of lead per

square foot (μg/ft2

) on bare floor or carpet; 250

μg/ft2 for interior window sills.

U.S. EPA (2001a)

Asbestos AHERA-Asbestos Hazard Emergency Response

Act

Cal/OSHA PEL: 0.1 fiber per cc of air

U.S. EPA (1987)

CCR Title 8, §5208(c)

Radon Voluntary Action Level: 4 picoCurie (pCi) per liter

of air

U.S. EPA (1993)

Mold Workplace prevention and clean-up required in

California (includes schools)

Voluntary guidance for assessment and

remediation – no numerical standards or limits

CCR Title 8, §3362

U.S. EPA (2001b)

NYC DOH (2000)
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35

problems in schools, including measures designed to protect the health of building

occupants and clean-up staff. It was designed primarily for building managers and

custodians. Also published in 2001, the Minnesota Department of Health developed

“Recommended Best Practices for Mold Investigations in Minnesota Schools”. This

guidance document was created to assist public school staff in investigating the causes

of indoor mold concerns and in finding cost-effective solutions. This document is aimed

at school staff, such as Indoor Air Quality Coordinators, facilities and maintenance

personnel, health and safety staff, and other school officials. Both documents counsel

school officials to make reasonable judgments as to whether their situation can be

handled in-house and to recognize their limits in addressing more serious, widespread

problems, when they should hire professional services.

2.4 Design and Construction of Portable Classrooms

Since the mid-1970s, the basic shape of portable classrooms used throughout

California has remained mostly unchanged: 12x40 feet modular units fitting together in

pairs (or more), with a metal roof, and a wall-mounted heat pump with air conditioning.

Generally, the windows are relatively small, although they are often operable. Exteriors

and floors are usually plywood or composite wood siding, and interior walls are most

often vinyl-covered tackboard. In recent years, designs with a concrete wall as well as

two-stories have become more common. Most importantly, numerous improvements

have been made in roofing, siding, windows, heating and air conditioning, lighting, and

insulation.

General requirements for school facilities are given in regulations (CCR Title 5, Section

14001), which address educational goals, master planning and future needs, structural,

fire and public safety requirements, siting to mitigate toxic hazards, “ (d) designed for

the environmental comfort and work efficiency of the occupants; (e) designed to require

a practical minimum of maintenance.” All public school facility construction within the

State of California, including portable classrooms, must comply with the California

Building Standards Code. This code is contained in Title 24 of the California Codes of

Regulation (CCR). The State has among the nation’s most stringent energy efficiency

standards, which are contained in CCR Title 24 (Part 6) and include provisions on the

building envelope, water-heating systems, lighting systems, and heating, ventilation and

air conditioning (HVAC) systems. The Department of General Services (DGS) oversees

the design and construction of educational facilities. The Office of Public School

Construction (OPSC) within DGS administers the State funding of public school facilities

construction and modernization, relocatable (portable) classrooms, and deferred

maintenance.

The Division of the State Architect (DSA) within DGS is responsible for reviewing design

plans and construction for new school facilities, additions, alterations, and

modernization projects, including portable classrooms. Although the building design

plans and the California Building Standards Code address all aspects of the school

design and construction, the DSA plan check in the past has focused exclusively on

three issues: the structural design (i.e., seismic safety), handicap accessibility (i.e.,

compliance with the Americans with Disability Act and related standards), and fire & life
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36

safety (e.g., sprinklers, fire alarms, etc.). Beginning in 2001, DSA has added

compliance with the California Energy Code as an area of emphasis in plan check. In

addition, throughout construction, school districts are required to retain a DSA-certified

inspector to monitor all construction activities and to liaison between the building

contractors and DSA regarding code compliance. In the case of portable classrooms,

DSA offers an expedited review focused on the fire & life safety components, provided

the classrooms will be duplicates of previously approved designs. Compliance with the

California Energy Code is included in the review of relocatable school buildings.

2.4.1 State Relocatable Classroom Program

For the State Relocatable Classroom Program, the OPSC has purchased and maintains

a set of approximately 6000 portable classroom units to make available to school

districts on an as-needed/as-available basis. These classrooms are intended for

districts impacted by excessive growth or for periods their facilities are closed during

modernization or for unforeseen emergencies. The State purchases about 200 new

portables per year, on average. Funding for portables comes primarily from lease

revenues. Current costs range from about $25,000 to $47,000; districts lease them for

$4000 per year. Districts are responsible for all maintenance of the leased units, which

are retained by a district anywhere from less than one year to more than ten years.

When a unit is returned to OPSC, they inspect the unit, make necessary repairs

(charged to the former lessee), and generally deploy the unit to another district in need

fairly quickly. In addition to the annual lease, school districts are responsible for the

costs of installation, including site preparation and utility hook-up.

With DSA assistance, DGS issues bid specifications for contractors each time OPSC

purchases units for the State program. Depending on funding, OPSC will issue a

contract to build several hundred classrooms. The DGS specifications are for the

“basic” classroom (DGS, 2000), and these often serve as the template for non-State

program portable classroom purchases. Nonetheless, school districts may submit

design plans of their own for approval when they are purchasing units for themselves.

The OPSC continually reviews the classroom specifications to assure that they meet or

exceed Title 24 requirements. Current OPSC specifications exceed the minimum Title

24 standards in several areas, including:

• An interior moisture barrier is required at all metal roof structures to prevent moist

interior air from contacting metal elements and producing condensation.

• Wall insulation requirements have been upgraded from R-11 to R-13, and ceiling

insulation has been upgraded from R-19 to R-22.

• All windows are now dual glazed “low e.”

• Lighting systems include T8 fluorescent type with photoelectric control.

State Relocatable Classrooms have always met or exceeded construction codes in

effect at the time of approval. Additionally, they comply with ASHRAE standards for

temperature control.
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37

OPSC also has taken and/or plans to take other steps to improve the state portable

classroom specifications for their impact on indoor environmental quality. For example,

all adhesives used for carpet or rubber baseboard installation must be water-based

adhesives, and lighting systems are designed to provide 50 foot-candles at the desk

level. OPSC’s wallboard has been tested and contains no detectable formaldehyde

residue. However, OPSC plans to require that tackboard wall material and fiberglass

insulation contain no detectable formaldehyde. They are also considering several

options for quieting noisy ventilation systems, such as insulated return air plenums.

Finally, the exterior moisture barrier, currently saturated felt or Kraft building paper, may

be changed to Tyvek.

The Office of Public School Construction (OPSC) is currently developing several

relocatable classroom guides for school districts that lease State relocatables through

the State Relocatable Classroom Program administered by the OPSC. The OPSC

anticipates that these guidebooks will be distributed in the next several months to

custodians, teachers, and maintenance staff in all school districts in California. These

guidebooks will provide districts with information to assist in ensuring that classrooms

are properly maintained, and will provide helpful information to district personnel. In

addition, the OPSC has made arrangement with the contracted manufacturer to include

these guides when a relocatable is delivered to a site, as well as OPSC staff will

distribute during its routine inspections of these classrooms.

OPSC also administers the Deferred Maintenance Program (DMF), which provides

funding to school districts for major repairs and upgrades, such as new roofs and

plumbing. However, funding for the DMF is variable, fluctuating from year to year.

Extreme Hardship Grants are available for urgent projects needed within one year for

health and safety or structural reasons.

2.4.2 California Collaborative for High Performance Schools

The Collaborative for High Performance Schools (CHPS) is a California consortium of

public agencies and energy utilities working to facilitate the design and construction of

“high performance” schools. These are school facilities that aim to be models of energy

and resource efficiency, as well as healthy and comfortable settings supporting quality

education. CHPS uses a whole building design approach, as well as providing

designers with specific guidance on component systems, that incorporates the best of

current knowledge and technologies. The core of CHPS is a set of Best Practices

Manuals, which address high performance school planning and design (CHPS, 2003).

Recently, the U.S. Department of Energy adapted the CHPS Best Practices Manual

Volume II (Design) for a national audience (U.S. DOE, 2003). In addition to its

publications, CHPS provides ongoing training to school facility staff, architects, and

engineers.

CHPS developed their own grading criteria using a point system, similar to the U.S.

Green Building Council’s Leadership in Energy & Environmental Design (LEEDTM)

scoring (U.S. Green Building Council, 2003). This approach allows school boards to
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38

declare their intentions to build high performance schools, despite a lack of explicit

knowledge of specify components. The CHPS scoring gives facility designers latitude

to incorporate practices in the manner that best fits the district’s application. CHPS has

helped secure funding for a number of demonstration projects throughout the state.

Several school districts, notably Los Angeles Unified, have established policies to

require all new facilities to meet the CHPS criteria.

2.4.3 U.S. EPA IAQ Design Tools for Schools

The U.S. EPA recently unveiled a new on-line resource called IAQ Design Tools for

Schools to help school districts with information resources for designing new school

facilities and repairing existing facilities. Its primary focus is on IAQ. It also develops

the concept of designing High Performance Schools, using an integrated, "whole

building" approach to addressing each of the important – and sometimes competing –

priorities, such as energy efficiency, indoor air quality, day-lighting, materials efficiency,

and safety, with consideration of tight budgets and limited staff. IAQ Design Tools for

Schools builds largely on the CHPS program (see above), but it is web-based, has a

national focus, and contains a broader array of resource materials on IAQ issues. The

web site can be viewed at: http://www.epa.gov/iaq/schooldesign/.

2.4.4 State Workgroup on Relocatable Classrooms

An interagency workgroup was started recently to identify opportunities to implement

Governor Davis’ sustainable building goals with respect to portable classrooms. This

subgroup is part of the interdepartmental Sustainable Building Task Force

(http://www.ciwmb.ca.gov/GreenBuilding/TaskForce/) comprised of representatives from

more than 40 state agencies with fiscal, construction, energy, health, and environmental

policy expertise. It was formed after Executive Order D-16-00 was issued directing

state agencies to promote sustainability in the planning, design, and construction of

state facilities (State of California, 2000). The Relocatables Workgroup is reviewing and

revising the DGS building specifications for relocatable classrooms with respect to

sustainability goals, including enhanced IAQ, and pursuing a variety of projects focused

on addressing concerns regarding portable classrooms.

2.4.5 Innovative Design Initiatives

There have been ongoing efforts to “rethink” the design of portable classrooms. In

1998, Southern California Edison (SCE) sponsored a workshop with architects,

engineers, manufacturers, and school district officials, as well as outside consultants

with expertise in energy analysis, modular buildings, and lighting design. SCE funded a

demonstration project incorporating ideas from the 1998 workshop (SCE, 1998). A

follow-up workshop was conducted in April 2003, and additional pilot portable

classrooms are in development (SCE, 2003).

In 2000, the California Energy Commission funded a project with Lawrence Berkeley

National Laboratory investigating both low VOC-emitting materials and novel HVAC
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39

system design, to reduce chemical sources and increase classroom ventilation rates

(Apte, 2002). Starting in mid-2003, CEC anticipates funding several projects on

classroom ventilation technology for K-12 schools, including applications for portable

classrooms (CEC, 2003).

2.4.6 Portable Classroom Manufacturers

The School Facility Manufacturers' Association (SFMA), formed in 1987, is a trade

organization for the manufacturers of modular school buildings, architects, suppliers and

others in related businesses, specific to California. Because portable classrooms

require DSA approval, units are seldom imported from out-of-state. Essentially all

portable classrooms purchased or leased by California school districts are

manufactured by one of about 10 companies. Portable classrooms are one application

of factory-built modular building construction; consequently, many of these

manufacturers also build products for a variety of commercial applications, e.g., offices,

emergency rooms, airports, clinics, and retail centers. The Modular Building Institute

(MBI) formed in 1983 is the national trade organization for manufacturers, dealers and

material suppliers in both the portable classroom and commercial factory-built structure

industry.

In 1999, California manufacturers of portable classrooms were sued under Proposition

65 by “As You Sow” for alleged exposures to formaldehyde above the “Safe Harbor”

limits. The manufacturers disputed the claims of the lawsuit, but in 2002 the parties

reached a settlement under the direction of the State Attorney General’s Office. The

manufacturers agreed to minimize the use of particleboard (a common construction

material that contains formaldehyde). Particleboard does not meet the structural

requirements of DSA, and therefore is infrequently used in portable classrooms except

in cabinetry. Many manufacturers also have shifted to using insulation that emits no

formaldehyde.

2.4.7 LAO Blueprint for School Facility Finance

In a 2001 report, the Legislative Analyst recommended changes to the finance system

for K-12 school facility capital outlay. They identified several key deficiencies with the

existing finance system: (a) state funding levels are unpredictable, which impedes

planning school construction projects, (b) the process for allocating state funds is

inherently imprecise and controversial, and (c) rules of state-district partnership are not

clear. The report proposes a new "blueprint" for more effectively financing new

school construction and modernization:

• More predictable state funding by annual appropriations for capital outlay, rather

than current intermittent voter-approved bonds;

• Allocation of funds to school districts based on a per-pupil formula, rather than

the current project-specific, first-come, first-served basis;
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

40

• More local control and responsibility through an accountability program; and

• Transition funding to address current unmet facility needs.

Because school facilities are such a substantial investment and it is the responsibility of

the districts to ensure their maximum useful life, the LAO felt that facilities maintenance

funding would be more efficient if there was greater local accountability. The LAO

suggested that "districts should set aside a prescribed annual contribution from their

operating budget to fund facility maintenance, or certify at a public hearing that a lower

amount is sufficient to meet their maintenance needs." The LAO’s recommendations

would lead to a more focused state role in technical assistance and oversight regarding

planning, constructing, and maintaining school facilities.

2.5 School Operation and Maintenance (O&M) Practices

Effective operations and maintenance (O&M) of school facilities are as essential as

good design and construction to assure a safe and healthy learning environment. An

effective maintenance plan requires adequate funding, properly trained facility

maintenance staff, and administrative support to keep school facilities in good condition.

The required activities include the daily janitorial services, routine inspection and

maintenance of facilities including its subcomponents (e.g., HVAC systems, building

envelope, landscaping, etc.), and planning for major repairs and modernization needs.

Daily janitorial and routine maintenance services are funded from the general budget for

school operations.

There is a relatively wide range in the services supported among districts, reflecting

their relative wealth and commitment to O&M as a priority. Not surprisingly, budget cuts

most often reduce facility maintenance programs first, as a way to “keep cuts out of the

classroom”. Thus, during lean times, maintenance suffers disproportionately. Major

repairs and modernization needs are funded separately from routine activities in most

school districts. Districts apply to OPSC’s Deferred Maintenance Program for costsharing of major repairs, such as roof replacement, HVAC system upgrades, and other

non-routine maintenance. However, funds are not always available in the Program.

2.5.1 LAUSD’s Facility Inspection Program

The Los Angeles Unified School District’s (LAUSD) Facility Inspection Program is a

broad self-assessment of all district classrooms for basic health and safety conditions.

After their first round of inspections, LAUSD officials determined that many of the basic

problems found could be remedied by custodians or other school personnel, generally

at less than $50 additional cost. Some of these basic problems included factors such

as blocked fire extinguishers and unrestricted electrical cords, important safety items

critical to school environments and child safety not studied in the Portable Classrooms

Study. However, they also included items such as proper storage of chemicals and

implementation of an Illness and Injury Prevention Plan, which also are handled by

school personnel. Problems requiring experienced specialists from the main district
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

41

office or from the private sector cost more to remedy. LAUSD has developed a detailed

tracking system to assure that problems identified are addressed. LAUSD’s “Safe

School Inspection Guidebook”, a set of checklists, is provided in Appendix V, and can

serve as a good starting point for other districts and schools undertaking self-inspection.

2.5.2 U.S. EPA’s IAQ Tools For Schools Program

In 1995, the U.S. EPA launched their IAQ Tools for Schools Program (U.S. EPA, 1995;

http://www.epa.gov/iaq/schools/). In the absence of federal legislation on IAQ, this

voluntary program provides schools with information they need to understand IAQ

issues and to solve and prevent IAQ problems. The program uses a team approach to

school IEQ management and emphasizes staff and occupant training, communication,

and routine maintenance for school facilities. The IAQ Tools for Schools Action Kit

contains instructional materials with modular components for use in starting a program

at a school or throughout a district. The self-contained IAQ management plan contains

materials and tools, such as occupant checklists, that can be used to perform a building

walk-through, assess conditions, and take remedial and preventive actions. An

important focus is occupant education and involvement, because occupant activities

can have a major impact on indoor air quality: occupants can unwittingly contribute to

contaminant and allergen levels in the air, and often improperly adjust or turn off

ventilation systems. U.S. EPA makes their kits available at no cost to schools across

the U.S., and has funded numerous training workshops.

In California, U.S. EPA has trained more than 2000 individuals from districts throughout

the state. Despite the outreach, awareness and use of the IAQ Tools for Schools

program among California schools is still relatively low: based on the Phase I survey

data from this study, 35% of district facility staff were aware of IAQ Tools for Schools,

and 11% of districts use all or part of the program. U.S. EPA attributes resistance

among school decision-makers to the program to the following: (1) misperceptions that

the program is labor- or resource-intensive; (2) lack of understanding that poor indoor

environmental quality affects both health and productivity, including test scores; and (3)

fear that raising awareness of IAQ will open a “Pandora’s box” of complaints. U.S. EPA

is partnering with organizations of school officials (e.g., ACSA, the Association of

California School Administrators, and CASBO, the California Association of School

Business Officers) to overcome these misperceptions.

IAQ Tools for Schools Programs have been successfully implemented by many schools

and districts throughout California. Most notably, Saugus Union School District, which

previously experienced tremendous community concerns regarding hazards in

classrooms, is an EPA Tools for Schools Excellence Award Winner and a model for

other districts. Visalia Unified School District has become a model for the cost-effective

treatment of mold problems through its program, and San Francisco Unified School

District has developed their program by utilizing groups such as the PTA and the United

Educators of San Francisco, in light of understaffed custodial and maintenance levels.

Fresno Unified School District and the Fresno Teachers Association, with assistance

from U.S. EPA, are working jointly to implement the program throughout its 95 schools.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

42

At Northgate High School in the Mt. Diablo Unified School District, U.S. EPA is

facilitating a pilot project in which the school’s environmental club is implementing the

program; already students have found problems that can be remedied at little or no

cost.

Implementation has been successful in many other states. In the west, a pilot study

was developed in the states of Washington and Idaho to create individualized, more

streamlined IAQ Tools for Schools programs, with seemingly good results. School staff

are assisted by an experienced IAQ/building science specialist to conduct walk-through

assessments at each school, to identify actual problems plus provide on-site training for

staff. The modified program is practical and action-oriented, and the assistance of an

unbiased and qualified expert is made available to give on-site guidance, training, and

resources (Prill et al., 2002).

California Assembly Concurrent Resolution No. 75 (Chan), enrolled in June 2003,

recognizes the significance of school indoor environments to the childhood asthma

problem, and “encourages California school districts to implement the Indoor Air Quality

Tools for Schools Program for the benefit of asthmatic children and for the health, wellbeing, learning, and productivity of the entire school population“.

2.5.3 Lead-Safe Schools

Lead exposure in the school environment is one of the few cases where an

environmental toxin is regulated (see Section 2.3.1). In 1992, the Legislature directed

DHS to conduct a study of lead hazards in the state’s public elementary schools and

childcare facilities, as part of the Lead-Safe Schools Protection Act. The CLPPP study

surveyed a random sample of 200 schools and daycare facilities, and identified the

prevalence of lead hazards, including lead-based paint, contaminated soil, and drinking

water with lead concentration above the federal action level in a report issued in 1998

(DHS, 1998). Most notably, some lead-based paints was found in close to 80% of

schools and daycare centers, although only 38% of these also have paint that is

deteriorated.

The Lead-Safe Schools Project was established in October 1998 jointly by U.C.

Berkeley's Labor Occupational Health Program, CLPPP and the state Department of

Education. The program provides training, focused documents, and a hotline aimed at

school maintenance staff. The joint project has conducted 81 training programs around

the state for school maintenance department staff (as of March 2003), with participants

representing 425 of the targeted 882 school districts in California.

The Lead-Safe Schools Protection Act (SB 21, Escutia, Statutes of 2002) requires that,

starting in 2004, schools shall certify they will follow all standards for the management

of lead hazards, when they apply for state modernization funding. The Act allows

districts to use deferred maintenance funds for the assessment of lead-containing

materials and the management of specific lead hazards.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

43

2.5.4 Integrated Pest Management (IPM)

The Healthy Schools Act of 2000 (AB 2260, Shelley) mandated the Department of

Pesticide Regulation (DPR) to promote school Integrated Pest Management (IPM)

programs. IPM includes implementing non-chemical practices to reduce pest

populations, using least toxic pesticides to treat infestations above designated

thresholds, and training relevant individuals regarding IPM approaches. The Act also

directed schools to comply with certain requirements to reduce exposures to pesticide

at schools, such as parental notification of pesticide applications, warning signs,

recordkeeping at schools, and pesticide use reporting by licensed pest control

businesses that apply pesticides at schools. Meeting these requirements is the

responsibility of individual school districts, and DPR does not enforce compliance. DPR

started promoting school IPM earlier, but the Act lead to a more coordinated outreach

program, production of guidance documents, formation of an advisory group,

performance of baseline and follow-up surveys, and creation of a California School IPM

web site (http://www.cdpr.ca.gov/cfdocs/apps/schoolipm/main.cfm)

According to the DPR’s 2002 survey (Geiger and Tootelian, 2002), 87% of districts were

aware of the Healthy School Act, 71% reported themselves to be in compliance with at

least three of the four Act’s requirements (posting, record keeping, annual notification,

and maintaining lists for special notification), and 49% of school districts were fully

compliant. Nonetheless, the Act does not explicitly require that schools alter their pest

management program with respect to which pesticides are used. A survey by a public

interest group identified that while district record keeping about pesticide use has

improved under the Act, the use of pesticides with “very hazardous ingredients” has not

decreased (McKendry, 2002).

2.5.5 School-based Asthma Management Program

As concern about the increase of childhood asthma has also risen, a number of

programs have been developed to target school environments, both to reduce children’s

exposures to asthma triggers, plus as a convenient contact point to provide information

and aid in medical management for the disease. The U.S. EPA (2002a) provides

resources and information on their web site Managing Asthma in the School

Environment. The American Lung Association has conducted its Open Airways for

Schools program since 1992 to inform, educate and empower students to better

manage their asthma with the assistance of parents, teachers, school nurses, and

physicians, through in-class lessons taught by trained volunteers. DHS has developed

a “Strategic Plan for Asthma in California” in consultation with a variety of agencies and

organizations. Many local agencies and non-profit organizations are partnering to

support school-based asthma management activities, such as the California Asthma

Among the School-Aged (CAASA) program, funded by the California Endowment.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

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2.5.6 Statewide Organizations

Several statewide organizations are active in providing guidance to school officials

regarding facility O&M. The Coalition for Adequate School Housing (CASH) is an

association of school districts, architects, attorneys, facility manufacturers and planners,

financial institutions, consultants, and vendors (http://www.cashnet.org/). CASH’s

Maintenance Network focuses on strengthening maintenance efforts statewide and

increasing public and legislative awareness and funding for school maintenance issues.

The California Association of School Business Officers (CASBO) represents the group

of school officials most directly involved in making O&M policy decisions: Chief

Financial Officers and operations managers (http://www.casbo.org/). CASBO makes

recommendations about staff and budget needs for schools per their size (e.g., they

publish manuals such as “Custodial Handbook” and “Maintenance Staffing Formula”).

While committed individuals are working hard to promote these goals, there are no state

regulations or guidelines on the O&M practices or minimum funding levels for school

districts. CASBO has recently noted that districts in California continue to be

understaffed relative to CASBO’s recommended staffing levels. Their concerns are

increased by the current fiscal crisis in the state: facilities are likely to suffer serious

impacts as schools grapple with the deepest cuts in state history by reducing

maintenance funds.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

45

3. STUDY METHODS AND RESULTS

The study was conducted in two major phases, a mail survey followed by a field study.

In the mail survey, Phase I, questionnaires for school facility managers and teachers

and passive formaldehyde samplers were sent to randomly selected schools during

April-June of 2001. In the field study, Phase II, field technicians inspected classrooms

and obtained numerous environmental measurements from October 2001 through

February 2002. In both phases, three classrooms (two portables and one traditional

classroom) were randomly selected at each school to participate in the study. The

following section summarizes the methods and results of the study. More detailed

information is available in the final contractor reports for Phases I and II.

3.1 Methods

The sampling approach for this study was designed to be statistically representative of

the “target” study population, which was defined as all public schools in California with

at least one portable classroom in spring 2001. The sample of schools was drawn

randomly from the California Public School Directory 2000 (CDE, 2002). A preliminary

mail survey of all public K-12 school districts in 2000-2001 found that there were about

80,000 portable classrooms in California, or about 30% out of a total of 268,000

classrooms estimated to exist in California in 2001 (DHS, 2003).

To ensure that proportionate numbers of schools were selected among the school

categories that might have different IEQ-related characteristics, the sample was also

stratified by north-south regions of the state, by school type (elementary, middle, or high

school), and by urbanization of the area (urban, suburban, or rural). The study data

were weighted to adjust for this stratification, and for unequal response rates in certain

categories, thereby providing a representative estimate for the target population. As

shown in Table 3-1, Phase I included 1,133 classrooms across the state, and Phase II

included 201 classrooms across the state.

Table 3-1. Study Design, Phases I and II.

Study

Phase

Sampling

Period

Sample

Size

QuestionnairesBuilding

Inspection

Environmental

Measurements

I: Mail

Survey

April-July,

2001

1133 rooms;

384 schools

Teacher &

Facilities

No Formaldehyde only;

7-10 days

II: Field

Study

Oct. 2001 –

Feb. 2002

201 rooms;

67 schools

Teacher &

Facilities

Yes Numerous

measurements;

6 hours (Table 3-2)
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

46

3.1.1 Phase I

Two questionnaires, a Facilities Questionnaire and a Teacher Questionnaire, were

created collaboratively by ARB and DHS. The questionnaires were based on

questionnaires from other studies, on guidance documents, and on information obtained

during public workshops held across the state. The questionnaires were used during

both study phases to obtain information from facility managers and teachers about

classroom characteristics and the environmental quality conditions and complaints at

the sampled schools. The Facility Questionnaire provided school-level and classroomlevel information on the physical conditions, operation, and maintenance of building

facilities and grounds for 384 schools statewide. The Teacher Questionnaire provided

classroom-level information, such as the presence of potential pollutant sources and

observations of moisture, air quality, noise, and lighting problems.

In addition, airborne formaldehyde was measured in a sub-sample of the Phase I

classrooms. ARB pre-tested the passive formaldehyde samplers (small glass tubes

with a special adsorbent), and, in consultation with the manufacturer, developed

protocols that achieved improved sensitivity and precision. These samplers have been

widely used in previous mail survey studies, including those in a large study of

manufactured homes conducted by DHS (Sexton et al., 1989; Liu et al., 1991). The

samplers were mailed with the Phase I survey materials and placed in the classrooms

by school or district personnel for 7 - 10 days.

3.1.2 Phase II

Phase II was a field study of environmental conditions in classrooms from 67 schools in

a stratified-random sample of all schools with at least one portable classroom both in

the spring of 2001 and in the 2001-02 school year. Field technicians inspected the

HVAC system and classroom interiors and exteriors, and recorded measurements of air

flows, noise levels, lighting levels, and moisture content of the interior walls, floor, and

ceiling. The field technicians also collected a wide array of environmental samples and

measurements during one school day at each school, as summarized in Table 3-2.

Indoor and outdoor data were collected for many of the measurements.

Most measurements were obtained across the six hours a day when the classrooms

were typically occupied. HVAC testing, noise measurements, and sampling for

culturable airborne molds and pollens were conducted during lunch breaks.

Environmental samples were stored on ice and shipped weekly by overnight delivery.

Quality control checks were performed for field and laboratory measurements, and for

entry of questionnaire and inspection data. The measurements of air pollutants and

dust contaminants showed good precision (an average of 10% or less across sample

types). Only the measurements and data meeting acceptance criteria were used in the

study.

Of the 67 schools studied in Phase II, 14 schools were specially selected into the Phase

II sample based on their Phase I results (high complaints of environmental problems or
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

47

Table 3-2. Phase II, Summary of Environmental Measurements.

Sample Classroom

Air

Outdoor

Air

Floor

Dust

Comments

Airborne

Aldehydes X X 13 aldehydes, including

formaldehyde

VOCs

(volatile organic

compounds)

X

Note: only

sampled in

half the

schools

X 9 VOCs, including benzene,

toluene, xylenes, chlorinated

hydrocarbons

Mold Spores &

Pollens

X X 22 mold and pollen species

Culturable

microorganisms

X X Specially selected schools

only

Particle counts X X Continuous. 2 cut points:

<2.5 and <10 um

Floor Dust

Pesticides X 20 species studied

Metals X 18 elements, including lead

PAHs

(polycyclic aromatic

hydrocarbons)

X 16 species studied

Allergens X 5 types (cat, dog, 2 dust

mite, cockroach)

Environmental

CO2

(carbon dioxide)

X X Continuous

Temperature,

Relative Humidity

X X Continuous

Noise X X Unoccupied classroom and

outdoor measurements

Light X 3 locations in room

Moisture X Walls, floor, and ceiling

measured

high formaldehyde levels), to help determine whether classrooms with apparent or

reported problems actually had serious environmental problems.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

48

3.2 Results

Results from Phase I and II are discussed below. When portable and traditional

classrooms are compared, the results are given as “portable vs. traditional.” The term

“all classrooms” refers to the total of all portable and traditional (permanent) classrooms

combined. When results are compared among portable, traditional, and all classrooms,

the results are weighted to provide the statewide estimates. When the results are

characterized as statistically significant, this reflects a 95% confidence level.

3.2.1 Classroom and School Characteristics

There was a substantial difference in the estimated age distributions for portable and

traditional classrooms. For instance, 55% of the portables were 10 years old or less,

whereas only 12% of the traditional classrooms were that new. This disparity is

undoubtedly partly responsible for many other concomitant differences, e.g., differences

in structural characteristics, HVAC characteristics, and types of environmental

problems/complaints, all of which are discussed below.

Portable classrooms were more prevalent in elementary schools than in middle or high

schools. Most of the portable classrooms (90%) were devoted to general instruction; a

smaller portion (75%) of the traditional classrooms were used this way.

The schools were mostly suburban schools (74%) and mostly elementary schools

(59%). Only about 29% of the schools were less than 30 years old, and the majority

(54%) of the schools had 10 or fewer portable classrooms. Nearly all portables had airconditioning systems installed, but only about three-fourths of traditional classrooms

had air-conditioning.

3.2.2 Building Materials and Other Pollutant Sources

As shown in Table 3-3, portable classrooms were reported more frequently than

traditional classrooms to have carpeted floors, vinyl tackable wallboard, and pressed

wood bookcases – building features that are associated with indoor aldehyde, VOC,

and/or particle emissions. Portables were also reported more often to have suspended

ceilings and metal roofs – building features associated with indoor moisture-related

problems. Similar results were found in Phase II.

Table 3-3. Percent of classrooms with certain building characteristics, Phase I.

Classroom

Type

Carpeted

floors

Vinyl tackable

wallboard

Pressed wood

bookcases

Suspended

ceilings

Portable 71 79 55 87

Traditional 34 28 48 62

All 48 47 51 72
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

49

3.2.3 Environmental Problems

Most types of environmental complaints were reported more often for portable

classrooms than for traditional classrooms (Table 3-4). Teacher complaints of air

quality (stuffy air and musty odors) and noise were reported more frequently in portable

classrooms (Table 3-4). Plumbing leaks and thermal (temperature) complaints were

more prevalent in traditional classrooms. Pest-related problems (not shown in table)

were reported about the same in both room types (over 30%).

The dominant thermal complaint in portable classrooms in Phase I was that they were

too cool, but in traditional classrooms it was that they were too warm. This difference is

consistent with the lower occurrence of air-conditioners in traditional classrooms.

Also, a large fraction of teachers in portable classrooms (60%) reported that they turn

off the HVAC system due to high noise levels, an activity that had previously been

reported anecdotally and in other studies. This behavior was reported significantly less

often for traditional classrooms (23%).

Table 3-4. Percent of classrooms with environmental problems reported by

teachers, Phase I.

Classroom

Type

Stuffy

Air

Musty

Odor

Roof

Leaks

Plumbing

Leaks

Thermal Noise Lighting

Portable 45 69 27 8 22 53 27

Traditional 33 59 21 18 35 41 13

3.2.4 Building Operation and Maintenance

Facility management staff reported a program of routine HVAC maintenance at most

schools (94%), although only two-thirds of the facility managers (67%) kept HVAC

maintenance logs. However, some schools may rely on their HVAC contractors to

maintain logs. Annual HVAC inspection, maintenance, and record-keeping are required

by Cal/OSHA regulations (CCR Title 8, Sec. 5142).

The majority of the schools conducted annual maintenance activities for the HVAC

system (e.g., cleaning the coils, checking the condensate pan and heat exchanger), and

most facility staff reported that the air filters were checked or replaced quarterly. About

5% of the facility managers reported never inspecting major components of the HVAC

system, such as the outdoor air damper setting, condensate drain pan, and coils; it is

not clear if this maintenance was done by contractors instead. About half of the schools

(57%) swept, vacuumed, and dusted the classrooms five days a week; most other

schools did so several times a week.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

50

Over half of the school facility managers (52%) received some type of environmentally

related complaint within the last year. About one third (35%) of the facility managers

were aware of the U.S. EPA’s program for managing indoor air quality in schools (Tools

for Schools), but only 11% of the facility managers used the program.

3.2.5 Classroom Ventilation

3.2.5.1 Ventilation Systems

Phase I surveyed the characteristics of HVAC systems and the use of doors and

windows for ventilation in portable and traditional classrooms. Results showed that

portables had more modern HVAC equipment and controls than did traditionals, i.e.,

they more often had air conditioning (95% vs. 77%) and an adjustable thermostat in the

room (77% vs. 50%) controllable by the teacher (45% vs. 27%). These factors may help

explain why teachers in traditional classrooms more frequently complained that the

rooms were too warm.

“Natural ventilation” from open doors and windows can sometimes help remove indoor

pollutants from classrooms, if the wind speed, direction, temperature differences, and

cross-flow patterns are sufficient. More portables than traditionals had windows that

open (87% vs. 66%), but the fractions of teachers reporting they kept their windows

open “frequently” were very similar for the two room types. More portables had doors

that open to the outside (100% vs. 77%), but exterior doors to portables were reported

to be kept open less often, likely because of outside noise.

Portables are more often equipped with packaged HVAC systems with heat pumps

(81% vs. 63%), have wall air handling units (81% vs. 32%) and have automatic supply

fan operation (87% vs. 65%). Ease of access is an important factor in how well HVAC

systems are maintained over time. The much higher prevalence of wall units in

portables may help explain why portable classroom HVAC systems have better access

for maintenance compared to traditional classrooms, which often have roof top units.

3.2.5.2 Ventilation Inspection

Phase II provided detailed measurement and observational information. As shown in

Table 3-5, poor HVAC conditions were found more often in portables.

Table 3-5. HVAC Maintenance Characteristics, Phase II.

Classroom

Type

Outdoor Air Damper

Blocked (%)

Drain Test

Failure (%)

Filter Loading:

Medium or Heavy (%)

Portables 11 59 40

Traditionals 3 12 27
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

51

A significant number of outdoor air dampers were blocked in portables (11%), and over

half of the portables failed the test for the HVAC condensate drain (59%). Nearly half of

the portables had air filters with medium or heavy loading. These conditions can have

negative impacts on indoor environmental quality, such as:

• Closed outdoor air dampers result in insufficient outdoor air ventilation.

• Malfunctioning or blocked condensate drains result in standing water, a potential

source of mold and bacteria.

• Increased dust loading on filters can cause decreased airflow and may become a

breeding ground for mold.

• Many of these problems are indications of inadequate maintenance and/or poor

design.

Dirty HVAC filters can

reduce airflow and

become a breeding

ground for mold.

3.2.5.3 Ventilation and Thermal Comfort Measurements

CO2 Levels. Carbon dioxide (CO2 ) levels were measured continuously throughout the

day as an indicator of building ventilation sufficiency. Indoor CO2 levels reflect the CO2

exhaled by building occupants and the outdoor air CO2 levels. Indoor levels typically

are higher than outdoor levels, but substantially elevated indoor levels result from

insufficient outdoor air ventilation of the classroom. Groups such as ASHRAE and

Health Canada have recommended that indoor CO2 levels not exceed 800-1200 ppm,

depending on outdoor CO2 levels; the 2005 California Energy Code for certain types of

ventilation systems requires that CO2 levels not exceed 1000 ppm (CEC, 2003).

Average CO2 levels in portable classrooms were 1064 ppm; traditional classrooms were

not significantly different (Table 3-6). Outdoor CO2 levels were typically about 425 ppm

over the day, with short-term peaks over 650 ppm. Indoor CO2 levels were elevated

over 1000 and 2000 ppm for a substantial portion of the day, indicating that nearly half
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

52

the classroom hours have inadequate or marginal ventilation, and that about 10% of the

classroom hours clearly have inadequate ventilation.

Table 3-6. HVAC Operation Characteristics, Phase II.

Classroom

Type

Mean

Indoor CO2

(ppm)

Mean

Outdoor CO2

(ppm)

Mean % of

Class Hours

@ CO2 >

1000 ppm

Mean % of

Class Hours

@ CO2 >

2000 ppm

Outdoor

Air Flow

(mean

cfm/ft2

)

Portables 1064 425 42 9 0.95

Traditionals 1074 425 43 10 0.80

Outdoor Air Flow. Study technicians measured outdoor, return, and total supply

airflow rates for a subset of classrooms while the HVAC system was operating. The

State design standard for classroom ventilation is typically 15 cfm of outdoor air per

person, or 0.15 cfm/ft2, whichever is greater. Nearly all classrooms had outdoor air flow

capacities greater than 0.15 cfm/ft2. When the air flow capacity was expressed in cfm

per chair in the classroom (a surrogate for cfm/person), about 10-20% of the

classrooms had HVAC systems with outdoor airflow capacities of less than 15 cfm per

chair.

The airflow measurements were also expressed per square foot of floor area. The

typical portable classroom is ~1000 ft2 and houses between 20 and 35 persons. The

standard of 15 cfm/person converts to a required outdoor airflow rate of 300 to 525 cfm

(or 0.3 to 0.5 cfm/ft2). Flow rate measurements indicated that all classrooms with

operational HVAC units were capable of providing outdoor air above this minimum

requirement. No significant differences were found between portable and traditional

classrooms, except that portables had higher flow rates per square foot of floor area

(see Table 3-6).

Most HVAC systems were capable of delivering adequate outside air and total airflow

when operated properly, but a small percentage of classrooms may have inadequate

flow for maximum occupancies, due to improper system design. The stuffy air

complaints by teachers can result from inadequate outdoor airflow capacity, but they

probably result most often from improper operation of the HVAC system. This occurs

primarily for three reasons:

• the outdoor air dampers are closed or blocked;

• the thermostat control is limiting the amount of time the system fan is operating

(i.e., the fan operates only when the system needs to heat or cool the

classroom); or

• the teacher simply turns off the system because the noise is disruptive to class

activities.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

53

Thermal Comfort. HVAC systems should not only provide healthful indoor air quality

but also provide a comfortable thermal environment. Temperature levels were

significantly different, with 27% portable and 17% traditional classrooms experiencing

levels cooler than ASHRAE thermal comfort standards for the heating season. Both

classroom types experienced temperatures notably warmer than the ASHRAE standard

levels for a large percentage of the day, even though the weather was generally cool

during sampling. About 14% of all classrooms had relative humidity (RH)

measurements above 60% for a substantial part of the day; such levels are not only

uncomfortable, but can lead to increased moisture and mold problems, increased dust

mite populations (allergy and asthma triggers), and other problems. About 11% of both

types of classrooms had RH levels below 30%, which can lead to dry mucous

membranes and increased susceptibility to respiratory infections.

3.2.6 Air Pollutant Measurements

Some classrooms had air pollutant levels that exceed levels of health concern. To

assess the level of health concern, measured levels are compared to available

guidelines and standards based on health and comfort. The cancer guidelines used

here for comparison are based on unit risk estimates for pollutants that are carcinogens.

These cancer unit risk estimates are based on an assumption of a lifetime exposure to

the pollutant at a concentration of 1 :g/m3

 (OEHHA, 1992). Clearly students and

teachers do not spend their entire life in classrooms, but the concentrations of these

pollutants in other indoor environments such as homes and office buildings where they

spend most of their time are often similar to those concentrations in schools, or even

higher. The combined lifetime exposures to carcinogens in indoor and outdoor

environments are of concern, but the cancer risks from indoor exposures may be

somewhat lessened for those pollutants that off-gas from building materials over time.

The measured levels of pollutants and the level of health concern are discussed below.

3.2.6.1 Aldehydes

Of the 13 specific aldehydes measured in the study, only two−formaldehyde and

acetaldehyde−were detected in more than 75% of the samples. Five other aldehydes

were measurable in at least 25% of the samples. For virtually all of the aldehydes, the

indoor levels were higher than the outdoor levels, indicating the presence of indoor

sources.

Formaldehyde. ARB (1992) has identified formaldehyde as a Toxic Air Contaminant,

based on its potential to cause cancer. Formaldehyde can also irritate the eyes and

respiratory system, and affect the immune system. For these non-cancer effects,

OEHHA has established an Acute Reference Exposure Level (REL) of 76 ppb for

1-hour exposure (OEHHA, 2000), and a Chronic REL of 2 ppb for long-term exposure

(OEHHA, 2002). As indicated in Table 2-1, OEHHA has also extrapolated an Interim

Reference Exposure Level (IREL) of 27 ppb for an 8-hour exposure to formaldehyde

(Broadwin, 2000), which is the most directly relevant guideline for assessing Phase II

results.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

54

Indoor concentrations were routinely elevated over outdoor concentrations (measured in

Phase II), as shown in Table 3-7. This is consistent with the findings of previous

studies, indicating that indoor sources of formaldehyde emissions are ubiquitous and

sizable.

Table 3-7. Indoor Formaldehyde Concentrations, Phase I and II.

Location Sample size (n) Mean (ppb) 95th Percentile

(ppb)

% Exceeding

27 ppb, IREL

Health Guideline*

Phase I Phase II Phase I Phase II Phase I Phase II Phase I Phase II

Outdoor NA 62 NA 3 NA 8 NA 0

Portable 644 135 32 15 72 26 50 4

Traditional 267 64 24 12 55 22 29 3

All

Classrooms 911 199 27 13 62 24 37 ~3 - 4

*IREL (Indoor Reference Exposure Level) for formaldehyde: 27 ppb, 8-hr average. Established by

OEHHA, based on eye irritation and effects of the respiratory and immune system (Broadwin, 2000).

Indoor formaldehyde air concentrations in portables averaged 32 ppb in Phase I, and

15 ppb in Phase II. Traditional classrooms were lower, averaging 24 ppb in Phase I and

12 ppb in Phase II. Both the means and 95th percentile concentrations were notably

higher in Phase I, and higher for portables compared to traditional classrooms in both

Phase I and II. The higher indoor levels in Phase I were expected because the Phase I

sampling was conducted during warmer weather when indoor formaldehyde levels are

usually higher, and because the sample size was substantially larger, increasing the

probability of including classrooms with more extreme levels in the sample. Phase I

also included nights and one or two weekends in the sampling period, during which the

classrooms were probably not ventilated. Also, in Phase II sampling, technicians

operated the ventilation system to make flow measurements, which might have reduced

formaldehyde levels relative to what they might have been under normal operation

conditions. Average school-year levels of indoor formaldehyde are likely to fall between

the Phase I and II measurements.

Using Phase II measurements over six hours during cooler weather as a very

conservative estimate, a minimum of about 4% of the classrooms, and more likely a

higher percentage, had indoor formaldehyde levels above the IREL of 27 ppb. This

totals about 10,720 classrooms, or 214,400 children (assuming 20 children per

classroom) exposed to formaldehyde levels that could potentially result in irritant effects.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

55

Like most indoor environments, all of the classrooms exceeded the Chronic REL.

However, because outdoor formaldehyde levels typically average about 3-5 ppb, it is

generally not possible to reduce indoor levels below the chronic REL. Also, as in

homes and offices, all classrooms greatly exceeded 0.13 ppb of formaldehyde, the level

equivalent to a risk of one excess cancer case per million persons (ARB, 2002). These

results indicate that a small but substantial percentage of classrooms have levels that

may cause short-term irritant effects, and that nearly all classrooms (like other indoor

environments) have formaldehyde levels that may cause long-term irritation and

contribute to cancer risk.

Modeling results showed that several factors were associated with elevated indoor

formaldehyde levels, including the following:

• Composite wood products in building materials or furnishings, including plywood

and particleboard, and pressed wood bookcases and cabinets, all of which can

emit large amounts of formaldehyde.

• Temperature and humidity, which affect the emission rate of formaldehyde.

• Classroom age, which reflects the off-gassing of formaldehyde sources over

time. (Formaldehyde typically off-gasses from building materials over a 3-5 year

period, so newer classrooms generally have higher emission rates).

Formaldehyde sources

include new cabinets,

doors, bookcases, and

other pressed wood

materials. These

materials generally offgas over the first several

years.

Because new materials containing formaldehyde generally off-gas over time, older

classrooms (both portable and traditional) generally would be expected to have lower

formaldehyde levels, as found in this study. However, there are many sources of

formaldehyde in modern society, and other sources often are brought into classrooms.

Sources can also include permanent press clothing, cosmetics, various art and
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

56

classroom supplies, and a variety of consumer products, as well as new bookshelves

and furnishings added to older classrooms. Guidance for reducing and preventing

elevated formaldehyde levels in classrooms is provided in Appendix IV.

Acetaldehyde. ARB (1993) has identified acetaldehyde as a Toxic Air Contaminant,

based on its potential to cause cancer. Additionally, short-term exposure to

acetaldehyde can cause eye, skin, and respiratory tract irritation, while long-term

exposure can affect the upper airway, red blood cells, kidneys, and growth (ARB, 1993).

OEHHA (2000) has established a chronic REL for acetaldehyde of 5.0 ppb. Outdoor

sources of acetaldehyde include combustion sources such as tailpipe exhaust, stacks,

and fires, as well photochemical oxidation of hydrocarbons (smog). Indoor sources of

acetaldehyde include combustion sources such as cigarettes, fireplaces, woodstoves,

gas appliances, and cooking activities. Acetaldehyde can also be emitted from some

building materials such as composite wood products, rigid polyurethane foams, and

some consumer products such as adhesives, coatings, lubricants, inks, and nail polish

remover (Kelly, 1996; ARB, 1997).

Acetaldehyde levels in portable classrooms in Phase II averaged 6.6 ppb. Outdoor

levels averaged slightly less (4.4 ppb), and may be higher during warmer seasons due

to increased photochemical production. Traditional classrooms had slightly lower indoor

levels of acetaldehyde. Factors contributing to indoor levels included those identified for

formaldehyde, except that outdoor air concentration was significantly correlated and

classroom age was not.

About 75% of the portable and traditional classrooms exceeded the chronic REL, and

about 25% of the outdoor measurements exceeded this guideline. Nearly all

classrooms and outdoor concentrations exceeded 0.21 ppb, the concentration that

poses a risk of one excess cancer case per million persons (OEHHA, 2002). These

results also suggest that a large portion of the classrooms have indoor acetaldehyde

levels that can cause chronic irritation and perhaps other health effects, especially when

considering the concurrent exposures to formaldehyde and other aldehydes and irritants

also found in the classrooms and other buildings.

3.2.6.2 Volatile Organic Compounds (VOCs)

Seven of the nine measured VOCs were measured above their detection limits in 80%

of the samples. The other two were detected in at least 50% of the samples. As in

most indoor air quality studies, the measured indoor VOC concentrations were higher

than those observed outdoors. Average indoor classroom concentrations ranged from a

high of 6 :g/m3

 for toluene (slightly less for m,p-xylene) to less than 0.5 :g/m3 for

chloroform. For all others, the averages were in the range of 1 to 2 :g/m3.

Benzene. Benzene is a carcinogen; ARB (1984) has identified it as a Toxic Air

Contaminant. Short-term exposure to benzene can cause mild irritation. Long-term

exposure can reduce the numbers of blood cells, platelets, and immune system
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

57

components in the blood. OEHHA has established an Acute REL of 1300 :g/m3 for

6-hour exposures, and a Chronic REL of 60 :g/m3

 (OEHHA, 2000; 2002).

Indoor benzene concentrations in portable classrooms averaged 1.3 :g/m3, with a 95th

percentile value of 3 :g/m3. Outdoor levels of benzene averaged 1.75 :g/m3, while the

95th percentile value was 3 :g/m3

. In traditional classrooms, the mean was similar to

that of portables, but the 95th percentile value was higher at 4.6 :g/m3

. Modeling results

showed that indoor air benzene concentrations were associated with outdoor

concentrations, and suggested that the presence of carpet and outdoor activities such

as construction might contribute.

These results indicate that classroom levels of benzene are well below the RELs, and,

hence, do not pose a risk of non-cancer hazards. However, both the outdoor and

indoor concentrations of benzene exceeded by two orders of magnitude the level of

0.03 :g/m3

, the concentration that poses a risk of one excess cancer case per million

persons (OEHHA, 2002). The results suggest that, because outdoor sources of

benzene are the primary sources for both indoor and outdoor levels, schools should be

carefully sited and operated to minimize exposure to vehicle and equipment emissions.

Building materials and other products should be screened to assure they do not contain

benzene.

Chloroform. Chloroform is a carcinogen; ARB (1990) has identified it as a Toxic Air

Contaminant. Chloroform is released into indoor air by vaporization from a number of

sources including: chlorinated tap water, pools, and spas; household bleach products;

and office and household products manufactured using chloroform as a solvent. Shortterm exposure to chloroform can affect the nasal lining, reproductive system, and

development. Long-term exposure can affect the liver and kidneys. OEHHA (2000,

2002) has established an Acute REL of 150 :g/m3 for a 7-hour exposure, and a Chronic

REL of 300 :g/m3.

Indoor chloroform concentrations in portable classrooms averaged 0.30 :g/m3

 in

portables and 0.48 :g/m3 in traditional classrooms. The 90th percentile values were

lower in portables (0.42 vs. 0.91 :g/m3

). Outdoor levels of chloroform averaged

0.45 :g/m3

, while the 90th percentile value was over 1.12 :g/m3. Modeling results

showed that indoor air chloroform concentrations were associated primarily with outdoor

concentrations, and to some extent with temperature, classroom age, school type, room

age, ventilation, and outdoor activities such as construction.

These results indicate that classroom levels of chloroform are well below the RELs, and,

hence, do not pose a risk of non-cancer hazards. However, about 75% of the outdoor

and indoor concentrations were above 0.19 :g/m3, the concentration that poses a risk of

one excess cancer case per million persons (OEHHA, 2002). The results suggest that

outdoor sources of chloroform are the primary source of indoor chloroform levels; thus,

schools should be carefully sited and operated to minimize exposure to outdoor

emissions of chloroform. In addition, use of cleaning products containing bleach should

be minimized, and indoor areas of heavy tap water use should be well ventilated.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

58

3.2.6.3 Particle Counts

Real time counts of particulate matter were measured in each classroom and outdoors.

It should be noted that particle counts cannot be directly associated with mass

concentration standards. However, the measurements provide a relative indication of

mass for comparison purposes.

The mean counts for the two particle sizes of primary interest, <2.5 microns and

<10 microns, were about the same in portable and traditional classrooms, but portable

classrooms showed higher counts at the upper percentile levels, especially for the

smaller size range. Outdoor counts were usually higher than indoor counts, especially

for the smaller size fractions.

One possible explanation for the increased fine particle counts is that portables may be

closer to vehicle traffic and other outdoor particle sources. In this study, over 50% of

portable and traditional classrooms were located within 50 feet of parking lots and

roadways. Portables usually have wall-mounted rather than roof-mounted HVAC units,

and are sometimes sited with their air handling units near roadways and parking lots for

security reasons, which could lead to increased particle infiltration into those rooms.

Recent research (Sioutas et al., 2003) has shown dramatically higher levels of fine

particles very near roadways. Other likely sources of particles (and VOCs and other

pollutants) include portable equipment such as leaf blowers and lawn mowers used for

landscape maintenance. In addition, carpets and rugs were found more often in the

portable classrooms, and could be a source of the particles, either due to resuspension

of previously deposited particles or chemical reactions at the carpet surface that

produce fine aerosols (Fan et al., 2003). Further analysis is needed to confirm the

relationships of potential indoor and outdoor particle sources, and to examine the

particle count patterns throughout the day.

Vehicle

traffic near

air intakes

of

classrooms

can be a

major

source of

small

particles,

volatile

organic

compounds,

and other

pollutants.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

59

3.2.7 Floor Dust Contaminants

Some persistent (long-lived) environmental contaminants can accumulate in floor dust

over time. This is especially a concern for younger children who spend time on the floor

and can be exposed to the dust contaminants by hand-to-mouth contact and skin

contact, and by inhalation of resuspended floor dust by walking, vacuuming and other

activities. Contaminated floor dust can also be a concern for older children who place

backpacks and books on the floor.

Contaminated floor dust is

especially a concern in rooms

used by very young children,

because they spend a substantial

amount of time on the floor and

may be exposed through

ingestion, inhalation, and even

through dermal absorption for

some contaminants. Carpets can

serve as a reservoir of dust and

particles. The use of entryway

doormats and proper, frequent

cleaning are recommended.

Floor dust was collected because it provides useful information on the deposition of

persistent contaminants in the past. Floor dust was collected in this study by using a

special vacuuming protocol – a measured area of the floor in the rooms’ main foot traffic

area was vacuumed with a hand-held vacuum containing a filter. Dust contaminants

were expressed as concentrations (:g/g, micrograms per gram of dust) and as loading

(:g per cm2

 of sampled floor area). Contaminant levels in floor dust and soil can be

indicators of potential exposures in the past and present. The estimated health risks

from exposures to these pollutants depend in part on the age, toxicological vulnerability,

and activity of the populations exposed.

Concentrations of some pollutants in the floor dust can be compared to the Preliminary

Remediation Guidelines (PRGs) for residential soil concentrations developed by U.S.

EPA Region 9 (EPA, 2002a) for screening carcinogenic and non-carcinogenic health

hazards at hazardous waste sites. The PRGs for carcinogens are based on a risk of

one excess cancer case in a million persons exposed for a lifetime. California state

agency risk estimates are also used when available.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

60

3.2.7.1 Metals in Floor Dust

Some of the metals measured in this study are known to have neurological or

carcinogenic effects. Fifteen of the 18 metals analyzed were detected in the floor dust

samples. Some metals, such as lead, had higher median dust concentrations in

samples from traditional classrooms; arsenic tended to have higher median dust

concentrations in the portable classroom samples.

Because the floor dust samples for the portable classrooms were combined before

laboratory analysis in order to screen samples that would merit further analyses, only

limited statistical comparison of floor dust results was conducted. Significant room-type

differences at or near the 10% level were found for a few metals: aluminum,

magnesium, and strontium concentrations in floor dust were significantly greater in

traditional classrooms, but at levels not expected to be of health concern.

When comparing dust loading (:g/cm2

, micrograms per square centimeter of floor area

sampled), all metals had higher dust loadings in portables samples than in traditional

samples. This may be due to the higher frequency of carpeted floors and elementary

school locations. However, only arsenic loadings showed a significant difference –

portables were significantly higher. This difference may be due to the presence of

arsenic-treated structural wood and playground equipment, as well as natural-occurring

soil concentrations and arsenic in fertilizers.

Lead. Concentrations of lead in floor dust in portable classrooms averaged 67 :g/g

(micrograms per gram; also equal to ppm), and 152 :g/g for traditional classrooms. The

95th percentile value was 95 :g/g for portables, and 201 :g/g for traditional classrooms.

Although these differences were not statistically significant, it is possible that the higher

levels in traditionals are in part due to the presence of old paint.

Classroom dust samples in the PCS are not directly comparable to those used for

compliance testing for the federal lead standard (U.S. EPA, 2001a), which use wetwipes rather than vacuuming. The vacuum sampling in carpeted classrooms may tend

to overestimate the lead accessible to children because it may include lead buried in the

carpet fibers. The vacuum sampling of hard floors, which is more common in traditional

classrooms, would have this problem to a lesser degree. Furthermore, the federal

standard was established to protect children under six years of age who are most

susceptible to lead toxicity, and especially infants and toddlers, who are most likely to

ingest lead from surface dust exposures. Although PCS results cannot be compared

against any state or federal standards, the amount of lead collected from the carpets

does indicate the presence of lead-containing dust.

A DHS (1998) study of lead in California’s public elementary schools found that 7% of

schools had lead levels in soil exceeding the U.S. EPA hazard standard of 400 ppm.

Lead paint and some paint deterioration were found in 37% of the schools. Recent

inspections in the Los Angeles Unified School District have found that 34% of pre-1993
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

61

schools had environmental lead deficiencies, i.e., peeling or chalking exterior paint

(Brakensiek, 2003).

One possible source of lead contamination in floor dust is lead-based paint, which is

very common in older buildings. Lead from outdoor paint can contaminate soil that is

tracked into classrooms, and it can be released and spread in older buildings during

repairs and remodeling. However, because carpets are often fairly old, it is not possible

to determine whether lead found in dust samples was recently or historically introduced

into the classroom. These results suggest that some portable and traditional

classrooms may require remediation to remove lead, especially where younger students

or women of childbearing age are present.

Peeling paint

in older

classrooms

is a source of

potential lead

exposure.

Arsenic. Sources of arsenic include naturally occurring arsenic in soil, which can be

significant in some areas, as well as certain pesticides and contaminated fertilizer and

perhaps treated wood. The California Department of Food and Agriculture (CDFA ,

2002), has proposed standards for arsenic, lead, mercury, and cadmium levels in

fertilizers.

Arsenic concentrations in floor dust in portables averaged 13 ppm, while traditional

classrooms averaged 11 ppm. The 95th percentile value was 19 ppm for portables, and

15 ppm for traditional classrooms. In comparison, median levels of arsenic in California

agricultural soils (Bradford et al., 1996) are about one-third the mean floor dust

concentrations measured in the classrooms, while 95th percentile values for arsenic in

agricultural soils are about two-thirds of the values for floor dust in this study. Nearly all

samples of floor dust had arsenic levels above 0.39 ppm, the estimated level in the

PRG for residential soil that is equivalent to a risk of one excess cancer case in a million

persons exposed.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

62

3.2.7.2 Pesticides in Floor Dust

Exposure to pesticides in sufficient quantities may affect the nervous system or the

immune system. Some pesticides are also known to cause cancer, and some are

suspected of being endocrine disruptors, i.e., they affect hormonal function. Selected

pesticides of several types were measured: organochlorine, organophosphate,

pyrethroid, carbamate, and synergist (DPR, 2003). Some of the pesticides have been

banned or restricted in use.

Floor dust samples from the two portable classrooms at each school were combined for

analysis due to cost constraints. Thus, there were two samples from each school, one

containing dust from two portables and one containing dust from a single traditional.

Pesticide residues were found in all floor dust samples, indicating the widespread use of

a variety of different products in or near classrooms. Six of the 20 pesticides measured

were detected in over 80% of the samples: esfenvalerate, chlorpyrifos, cis- and transpermethrin, o-phenylphenol, and piperonyl butoxide. Three others–diazinon, 4,4,’DDE,

and propoxur–were measured in over 50% of the samples.

At the 95th percentile, nine of the pesticides were measured at concentrations above

1.0 :g/g (microgram of pesticide per gram of floor dust), although several of these had

few measurable samples. There were no significant differences in the mean levels in

portable and traditional samples. Many of the pesticides had median loading levels less

than 0.01 ng/cm2 (nanograms per square centimeter of sampled floor surface).

Esfenvalerate, a commonly used insecticide, had the highest dust concentration and the

highest median loading level (0.34 ng/cm2

). No statistically significant differences

between the means for the portable samples and traditional classrooms were found for

either the concentration results or the loading results. Because some of the pesticides

have an environmental half-life of a few weeks, some of the pesticides were likely

applied within a few months before the sampling period at some schools in 2001-02.

As expected, some very persistent pesticides that have been banned for some time

were found in the floor dust – chlorpyrifos, DDE, and dieldrin. It is likely that dust levels

of these pesticides in schools may be slowly decreasing after the bans, because the

pesticides can persist in soils and dust for several years.

• Chlorpyrifos is an organophosphate insecticide once used regularly on school

grounds. Before June 2000, when U.S. EPA issued its ruling to ban chlorpyrifos in

non-agricultural settings including schools, chlorpyrifos was found in over 800

insecticide products; it was an ingredient in many lawn-care pesticides and in

common household insecticide products.

• DDE is a breakdown product of DDT, a widely used insecticide that was banned in

1972 (U.S. EPA, 2000a). Environmental sources of DDE include soil, atmospheric

dispersion, sediment runoff, contaminated plants and animals, and improper use and

disposal. Measurable levels of DDE (4,4’-DDE) in the floor dust were found in 48%

of portable samples and 58% of traditional classroom samples.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

63

• Dieldrin, an insecticide and a by-product of the pesticide Aldrin, was widely used

from 1950 to 1974 to control insects on cotton, corn and citrus crops (U.S. EPA,

2000b). Also, dieldrin was used to preserve wood, control termites, and control

locusts and mosquitoes. Most uses of dieldrin were banned in 1987. Environmental

sources of dieldrin include soil surrounding wooden structures treated for termites;

soil or sediment; improper use or disposal; contaminated fish and shellfish; and

contaminated dairy products and meat.

Since the discontinuation of chlorpyrifos, a class of insecticides called pyrethroids,

which includes esfenvalerate and cis- and trans- permethrins, has been widely used as

a substitute for chlorpyrifos and other organophosphate pesticides. Permethrin acts on

a broad spectrum of insects, and is less persistent than chlorpyrifos in dust and soils

with a half-life of 30 to 38 days. Esfenvalerate is equally short-lived in the environment.

Many of the pyrethroid-containing insecticides are more effective with the addition of

piperonyl butoxide (PBO) as a synergist. PBO is used in indoor fogging and termite

control, and on gardens, lawns, and indoor plants. Like the pyrethroids, PBO is not a

long-lasting contaminant of dust and soils.

Lindane, an organochlorine pesticide, was used on a wide variety of food crops,

ornamentals, livestock, homeowner, and other sites until about 1985 (U.S. EPA, 2002b).

Lindane is still used to treat head lice and scabies, and to treat seeds for six crops

(barley, corn, oats, rye, sorghum, and wheat). Measurable levels of lindane in the floor

dust were found in 6% of the portable classroom samples and none of the traditional

classroom samples. The highest lindane levels measured were at least two orders of

magnitude less than the PRG of 0.44 ppm for cancer effects.

O-phenylphenol was the only fungicide measured in the study. O-phenylphenol’s use in

commercial disinfectants such as Lysol and in some common insecticides makes it an

easily accessible and highly prevalent pesticide in school classrooms. Data were not

available on its persistence in the environment.

Dieldrin was the only pesticide measured in floor dust that exceeded or nearly exceeded

a PRG for cancer or non-cancer effects. It was found in measurable levels in 13% of

the portables and 30% of the traditional classrooms. Compared to the PRG of 0.03

:g/g for cancer effects, less than 10% of portable samples but about 25% of traditional

classroom samples had dieldrin levels above the PRG. This result suggests that, based

on the conservative assumptions in the cancer risk calculations, the cancer risk from

dieldrin is a potential health concern, especially in older classrooms.

3.2.7.3 Polycyclic Aromatic Hydrocarbons (PAHs) in Floor Dust

PAHs are ubiquitous products of combustion (e.g., wood smoke, diesel and gasoline

exhaust, tobacco smoke, cooking). They are found in measurable quantities in the air,

especially in urban areas. They are semivolatile compounds and therefore accumulate

in soil and dust. Most of the 16 PAHs studied (some of which are also known or

suspected carcinogens) also were found in over 80% of the classrooms, but the loading
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

64

levels were relatively low. The mean concentrations of most PAHs in the portables

sample were similar to those in traditional classroom sample, but the portable samples

had much higher 95th percentile values for nearly all PAHs measured. These

differences between room types may be due to the higher prevalence of carpeted floors

and nearby vehicle traffic in portables. The indoor PAH levels results were similar to

those reported for surface wipe loadings for the homes of 102 children in Minnesota

(Clayton et al., 2002), and lower than those reported for floor vacuum samples in

children’s homes in North Carolina (Chuang et al., 1999).

3.2.7.4 Allergens in Floor Dust

Varying amounts of allergen levels were measured in floor dust samples. Dog and cat

allergens (Can f1 and Fel d1) were detected most frequently: they were found in more

than half of the classroom dust samples. However, their concentrations were generally

below sensitization levels. Dust mite allergens (Der f1 and Der p1) were detected in

only 6-7% of dust samples. Levels of cat, dog, or mite allergens showed moderate

concentrations in a small subset of classrooms, but only two classrooms had any

allergen (dog) above an established sensitization level (IOM, 1993, 2000). This finding

is consistent with previous studies indicating that allergens from pets can be carried into

schools and other buildings on the clothes of pet owners, but that the concentrations of

these allergens are seldom enough to cause sensitization (IOM, 1993, 2000). However,

concentrations of these allergens as found in both traditional and portable classrooms

may be sufficient to cause allergic responses in those with pre-existing allergies to

dogs, cats or dust mites. Cockroach allergen was detected in only two samples (1%), in

part because the detection limit was higher for this type of assay.

3.2.8 Moisture and Mold

The episodic and infrequent nature of roof leaks, plumbing leaks, floods, etc., the

dependence of mold growth on temperature and humidity, and the influences of

ventilation patterns and indoor activity on particle generation and distribution determine

the likelihood of mold growth and concentration of spores in indoor air. Spot

measurements of airborne mold spores provide limited information on the presence of

mold growth in indoor environments. Therefore, we did not expect to measure elevated

levels of airborne mold spores in classrooms during a one-day building inspection

unless mold contamination was severe. In addition to sampling for culturable and nonculturable bacteria and fungi, the field technicians also inspected the classrooms for

signs of mold growth or its predecessor (water damage), by searching for water stains,

condensation, visible mold, and poor site drainage, and by measuring the moisture

content of interior building surfaces.

3.2.8.1 Moisture-related Indicators

As discussed above, Phase I questionnaire data showed that teachers frequently

observed signs of excess moisture and mold contamination. In Phase II, field

technicians measured moisture content at one location in each wall, floor, and ceiling;
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

65

preferred measurement locations were near water stains or other signs of water

damage, or under windows. Because the large majority of the moisture readings were

0% and the rest were nearly all between 10-20%, excess moisture was defined

operationally as at least 10% moisture. Observations of the field technicians sometimes

confirmed the presence of leaks or spills nearby when moisture levels were in this

range. The results of building inspections for moisture indicators in Phase II are

summarized in Table 3-8.

Water stains on the ceiling were found in 21% of the portable classrooms, indicating

current or previous roof leaks. This frequency seems high given that most portable

classrooms are relatively new, but portable classrooms often have a full-length joint

between modules that can leak at the roof level. Traditional classrooms had a higher

frequency of water stain on the ceiling (35%), which may reflect their greater age.

Water stains on the floor were observed in 13% of the portable classrooms, but very

rarely in traditional classrooms, possibly due to the lower frequency of carpeted floors in

traditional classrooms. This may also be due to poor performance of flashing and

caulking used in the modular construction of portable classrooms.

Table 3-8. Percent of Classrooms with Moisture Indicators, Phase II.

Classroom

Type

Water Stains

on Ceiling

Water Stains

on Floor

Excess Moisture

in Walls, Floor

or Ceiling*

Visible Mold

on Ceiling

Standing

Water within

50 ft.

Portable 21 13 12 3 32

Traditional 35 2 20 0 43

* Operationally defined as a moisture meter reading of at least 10%.

Excess moisture in the walls, floors, or ceilings was found in 12% of the portable and

20% of traditional classrooms. This is consistent with the higher rate of ceiling stains

and standing surface water near traditional classrooms. Visible mold was not

commonly observed, but was seen on the ceiling in 3% of portable classrooms.

Other indicators of potential moisture problems were also examined. Mold was

observed on HVAC filters infrequently (1.3% of portables and none in traditional

classrooms). Many portable classrooms (43%) had foundation skirts less than two

inches from the ground, which can lead to moisture problems with the walls and

subfloor due to wicking action and/or poor crawlspace ventilation.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

66

 Mold contamination in wall interiors requires thorough remediation.

3.2.8.2 Mold Measurements

In the Phase II study, non-culture-based air samples for mold spores and pollen grains

were collected indoors and outdoors with the Allergenco sampler in all classrooms. In

almost all cases, outdoor concentrations of mold and pollen were higher than indoor

levels in both portable and traditional classrooms. Total fungal spores averaged

1,290 counts/m3 (3.11 log10 counts/m3) outdoors and 288 counts/m3

(2.46 log10 counts/m3) indoors; the 95th percentile values were 16,200 counts/m3

(4.21log10 counts/m3) outdoors and 2,040 counts/m3 (3.31 log10 counts/m3) indoors.

Overall, the types and concentrations of mold spores and total pollen were similar for

portable and traditional classrooms.

The genus Stachybotrys is a mold that recently has gained public attention because it

may be associated with health effects other than allergies. Airborne Stachybotrys

spores were identified in 2 of 185 classrooms (1%) and 2 of 62 of the outdoor samples

(3%). The two positive indoor air samples contained very few Stachybotrys spores.

When very low airborne spore concentrations are found in rooms in which a thorough

inspection has identified no water leakage, moldy odor or visible mold growth, it is likely

that these spores have been brought indoors through open doorways or windows and

no further action is needed.

Compared to the interpretation guidelines for total outdoor mold spores (AAAAI, 2003)

shown in Table 3-9, the concentrations of total mold spores were in the Low Category,
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

67

suggesting that only extremely sensitive persons may experience symptoms. While

these guidelines were developed for the interpretation of outdoor air samples, the

responses of mold-allergic persons to indoor exposures is likely to be similar.

Table 3-9. National Concentration Guidelines for Outdoor Airborne Mold Spores

and Plant Pollen*

Concentration (pollen grains /m3 or

 mold spores /m3 )

Category

(Percentile of

total

distribution)

Persons who may

experience allergy or

asthma symptoms Weed

Pollen

Grass

Pollen

Tree

Pollen

Total Mold

Spores

Absent

(not detected) None Below

detection

Below

detection

Below

detection

Below

detection

Low

(<50%)

Extremely sensitive

persons only 0–9 0–4 0–14 0–6499

Moderate

(50–90%) Many sensitive persons 10–49 5–19 15–89 6500–12,999

High

(90-99%) Most sensitive persons 500–499 20–199 90–1499 13,000–49,999

Very high

(>99%)

Almost all sensitive

persons

(extremely sensitive

persons may

experience severe

symptoms)

>500 >200 >1500 >50,000

* Source: AAAAI (American Academy of Allergy & Asthma & Immunology), 2003. National Allergy

Bureau, Reading the Charts. Available at http://www.AAAAI.org/nab/index.cfm?p=reading_charts.

In addition, culture-based air samples of mold spores were collected indoors and

outdoors with the Mattson-Garvin sampler during lunch breaks in a subset of 14

schools. Airborne concentrations of five mold groups were reported in culturable

samples: Cladosporium species, Penicillium species, Aspergillus species, “Other”, and

“Unknown” fungi. The results from these supplemental samples agreed with the

findings from the Allergenco samples, that is, outdoor concentrations of mold spores

were higher than indoor levels for both portable and traditional classrooms, except for

the genus Aspergillus. This group was not observed in any outdoor samples, but was

found at low concentrations in most indoor samples from both portable and traditional

classrooms. This finding is probably due to the small number of outdoor samples

(n=10) and detection limit of the measurement method.

3.2.9 Pollen

Airborne pollen grains were also collected in the Phase II study, using the Allergenco

sampler indoors and outdoors at all classrooms. Total pollen concentrations were

almost always lower indoors than outdoors. For example, the mean outdoor pollen level
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68

was 21 grains/m3

 while the indoor mean was 8 grains/m3 for both portable and

traditional classrooms. The 95th percentile values were 19 grains/m3 for portable and

78 grains/m3 for traditional classrooms, versus 276 grains/m3 for outdoor air. This

indicates that most classrooms were in the “Low” categories established by AAAAI for

different types of pollen (Table 3-9). Less than five percent of the portable classrooms

were in the “Moderate” category, while traditional classrooms had somewhat higher

extreme concentrations – less than five percent were in the “High” category, depending

on the type of pollen. Differences between room types may be due to more mature and

intensive landscaping near the traditional school buildings, which were more likely part

of the original school construction. Alternatively, it may indicate cases where there was

greater infiltration of outdoor air and pollen into traditional classrooms.

Because the AAAAI sensitization classifications depend on pollen type and pollen type

was not characterized in this study, it is difficult to assess the significance of these

pollen results with respect to health impacts on students and teachers. Nonetheless,

because few indoor pollen-producing plants were observed in classrooms, it is unlikely

that children’s pollen exposures were higher in class than outside in the schoolyard or

elsewhere in the community.

3.2.10 Noise

All classrooms exceeded the new ANSI acoustic standard for classroom noise levels --

35 decibels A-weighted, or dBA. A substantial percentage of both portable and

traditional classrooms exceeded outdoor noise limits of 55 dBA set by some California

communities (see Table 3-10). Noise levels measured in both types of classrooms

were not statistically different. However, the teachers in portable classrooms were

much more likely to turn off the HVAC unit due to noise (60% vs. 23% in traditional

classrooms in Phase I, and 68% versus 42% in traditional classrooms in Phase II).

Table 3-10. Classroom Noise and Lighting Conditions Exceeding Standards

Classroom

Type

Noise Level Near

HVAC > 55 dBA

(%)

Mean Light Intensity

< 30 Foot-candles (%)

Mean Light Intensity

< 50 Foot-candles (%)

Portable 50 9 38

Traditional 38 4 27

3.2.11 Lighting

The mean light intensity measured in the traditional classrooms was significantly higher

than that measured in the portable classrooms. However, a small percentage of both

portable and traditional classrooms did not meet professional design guidelines (IESNA,

2000) of 30 foot-candles (f-c) for high-contrast materials. In addition, approximately

one-third of both portables and traditional classrooms did not meet the IESNA light
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69

guidelines of 50 f-c for low-contrast materials, indicating inadequate lighting in both

types of classrooms (see Table 3-10).

3.2.12 Specially Selected Classrooms

The specially selected classrooms at the 14 schools that were identified in Phase I were

included in Phase II. Their environmental measurements and building characteristics

were compared to the target population. The specially selected classrooms had much

more moisture–related problems reported, such as musty odors and visible mold areas,

when compared to target population. However, these classrooms had similar

formaldehyde concentrations, and lower mean percentages of time when indoor CO2

levels exceeded 1000 ppm.

Surface swab samples were also collected in the specially selected classrooms. Four

mold groups were reported: Aureobasidium species, other Yeasts, Cladosporium

species, and Other. Concentrations of surface microbes ranged from non-detectable to

4 million, depending on sampling sites (e.g., desk, windowsill or ceiling). The highest

values suggest some areas of patent mold contamination, as would be expected since

some of the swab samples were taken in areas that visibly appeared moldy during the

inspection process.

3.3 Summary of Results

This study provides the first and only comprehensive investigation of classroom indoor

environmental quality, ventilation, and HVAC system conditions for California’s K-12

schools. The findings were drawn from both questionnaires completed by teachers and

the local facility staff in Phases I and II, and on-site inspections and measurements

conducted by field research technicians in Phase II). A summary of the results from

measurements of contaminant levels in classroom air is shown in Table 3-11.

Both portable and traditional classrooms had indoor pollutant levels that exceeded

outdoor levels, and the indoor pollutant levels exceeded available environmental

standards and guidelines in some cases. Building materials, classroom age, ventilation

conditions, outdoor air, and other factors were associated with elevated pollutant levels.

There were significant differences between portable and traditional classrooms in many

of their environmental conditions and the associated factors. Further analysis of the rich

data base generated in this study will likely reveal other factors that could prove useful

for further understanding the IEQ problems in schools and the measures to be taken to

reduce their potential effects.
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70

Table 3-11. Summary of Contaminant Levels in Air and Floor Dust, Phase II.

Pollutant

Type

Summary Statistics & Comparisons

of Pollutant Levels

Modeling Results -- For Selected

Species and Selected Predictors

Indoor

Levels

Vs.

Outdoor

Levels

Exceeds

health or

comfort

guideline/

standard

Portable V.

Traditional

Mean Test

Portable

Vs.

Traditional

Test

Other Significant

Predictors

Formaldehyde

(air)

Indoors

much

higher

YES

OEHHA draft

Interim REL ,

CREL

Portables

higher

Portables

higher (most

models)

RH, temperature, room

age, school type, genl.

instruction classroom,

others related to materials

in room

Other aldehydes

(air)

Indoor

generally

higher

Possibly

acetaldehyde.

Others

detected.

About the

same

Depends on

outdoor level

(acetaldehyde)

Room age, school type;

genl. instruction

classroom, outdoor air

(acetaldehyde)

VOCs (air) Indoor

higher

Possibly

benzene and

chloroform

About the

same

About the

same, some

depend on

outdoor level

Outdoor air, depending on

room type; a few others

that vary by analyte

Particle Counts

(air)

Indoor

generally

higher

NA About the

same

About the same Frequency of vacuuming/

sweeping/dusting; outdoor

air, depending on room

type

Pesticides (dust) NA Possibly

dieldrin;

many detected

About the

same

NA** NA

Metals (dust) NA* Possibly lead,

arsenic

Lead higher

in T; Arsenic

higher in P

NA** NA

PAHs (dust) NA Many detected Some

loadings

higher in P

NA** NA

Allergens (dust) NA Cat and dog

dander in most

Traditional

slightly

higher

NA** NA

Mold and Pollen

(air)

Outdoor

generally

higher

Mold spores

and pollens at

low-moderate

thresholds

About the

same

About the same Open windows

NA Data not available.

* Outdoor soil samples were collected and analyzed for metals under funding from OEHHA. Those

results will be incorporated as an addendum to this report.

** Modeling has not yet been conducted for dust analytes, but may be pursued under separate

funding.
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4. RELATED STUDIES IN CALIFORNIA SCHOOLS

Prior to the PCS, there had been no comprehensive study of environmental conditions

in California public schools. Various investigations had been conducted over the past

decade that addressed specific components or looked at a limited subset of school

facilities. These are summarized below:

♦ A nationwide survey of school facilities was last conducted by the federal General

Accounting Office in 1995 (GAO, 1995). At that time, 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 are 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.

♦ Researchers at Lawrence Berkeley National Laboratory (LBNL) reviewed the

available literature in 1997 on general school IAQ (Daisey and Angell, 1998). The

report, contracted by OEHHA, was largely based on records of school

investigations by NIOSH. They found that the most common building-related

problem was inadequate ventilation with outside air. The second most common

problem was water damage to building elements, leading to mold contamination

and growth. The report also pointed out that measurements of indoor air

pollutants were very limited, and quantitative analyses of their impacts on health

were therefore difficult. However, respiratory and central nervous system

symptoms were the most common health complaints. A similar analysis done for

Oak Ridge National Laboratory highlighted the need for pollutant source control,

proper ventilation, and humidity control to prevent IAQ problems in schools.

♦ The California Energy Commission investigated ventilation in California schools

and other non-residential buildings. Their report found that schools consistently

had lower ventilation rates than required and that one-third of the classrooms they

tested had air exchange rates less than 50% of the level required by State

regulations and industry standards (CEC, 1995).

♦ DHS conducted a survey of lead hazards from paint, soil and water in a

representative sample of 200 elementary schools and child care facilities in

California (DHS, 1998). The study found that nearly all schools had some leadcontaining paint, and the lead content of paint is inversely related to school age

(much less post-1979). Almost 40% of facilities had some paint that is

deteriorated. Lead levels exceeding the U.S. EPA reference value for soil

contamination (400 ppm) were found in 6% of surveyed schools, and, an
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

72

estimated 18% of schools had lead in drinking water at or above the U.S. EPA

action level (15 ppb).

♦ A California non-profit, public interest group published a survey of pesticide use

information for 46 school districts (representing ~25% of state students) that

documented the widespread use of pesticides in public schools (Kaplan et al.,

1998). It found that 87% of the districts reported using one or more of 27

particularly hazardous pesticides (i.e., known or suspected to cause cancer, affect

the reproductive system, mimic the hormone system, or act as nerve toxins).

♦ DHS estimated approximately 5% of California schools have one or more

classrooms with long-term radon concentrations above the U.S. EPA’s

recommended action level of 4 pCi/l, and for some regions (e.g., Santa Barbara

County), the rate is as high as 16% (Zhou et al., 1998). An estimated 1% of

classrooms statewide exceed the U.S. EPA limit.

♦ Another non-profit, public interest group released a critical report about the rising

use of portable classrooms, and their concerns received substantial media

coverage (Ross and Walker 1999). The report postulates that the IEQ problems

for portables, especially elevated exposures to formaldehyde and VOCs, are more

serious than for permanent buildings, and that children are adversely affected by

being housed in them. Incidents of sick-building syndrome complaints among

teachers and students were described.

♦ A small study of portables in Los Angeles was conducted by UCLA in 1999-2000

(Shendell et al., 2003). Overall, the results found low concentrations of target

toxic and odorous VOCs. The four most prevalent VOCs measured were toluene,

m-p-xylene, a-pinene, and d-limonene, and their likely indoor sources in the

school classroom environment were commercially available personal, teaching,

and cleaning products. No daily-integrated samples of formaldehyde

concentrations exceeded 33 μg/m3

. Weekly-integrated and daily-integrated

acetaldehyde concentrations were higher in portables than in main building

classrooms. These data suggested the main sources of aldehydes were interior

finish materials and furnishings made of particleboard without lamination, though

other non-material sources likely influenced high values in specific portables, e.g.,

outdoor sources such as vehicles as a function of ventilation.

♦ LBNL recently conducted a study of four brand-new relocatable classrooms

installed at two separate locations (one coastal and one inland). Apte et al. (2003)

designed and constructed four energy-efficient relocatable classrooms for this

study to demonstrate technologies with the potential to simultaneously improve

energy efficiency and indoor environmental quality (IEQ). Two were installed at

each of two school districts, and energy use and IEQ parameters were monitored

during occupancy. Two portables (one per school) were finished with materials

selected for reduced emissions of toxic and odorous volatile organic compounds

(VOCs). Each had two HVAC systems, operated on alternate weeks, consisting
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

73

of a standard heat-pump system and an indirect-direct evaporative cooling (IDEC)

system with gas-fired hydronic heating. The IDEC system provides continuous

outdoor air ventilation at 15 cfm per person or more, providing efficient particle

filtration while using significantly less energy for cooling. School year-long

measurements included: carbon dioxide (CO2), particulate matter, VOCs,

temperature, humidity, thermal comfort, noise, meteorology, and energy use. IEQ

monitoring results indicate that important ventilation-relevant indoor CO2 and

health-relevant VOC concentration reductions were achieved while average

cooling and heating energy costs were simultaneously reduced by 50% and 30%,

respectively.

♦ The CIWMB funded a laboratory study to measure and compare emissions from

commonly used and alternative building products, including those most commonly

used for school construction, to obtain data on whether or not alternative products

with high recycled content adversely impact indoor air quality. The Public Health

Institute conducted the study, and DHS acted as the Principal Investigator. The

testing protocol, Special Environmental Requirements, Specification Section

01350 (Section 01350), was designed to simulate volatile organic compound

(VOC) emissions during the early stage of building occupancy. Over 70 products

in eleven material categories were tested for their emissions of more than 120

targeted chemicals. Predicted concentrations were calculated from laboratory

emissions data and using typical dimensions, ventilation rates and material use

scenarios.

The results of the Building Material Emissions Study indicate that recycled content

products perform about the same as standard products. Both alternative and

standard products have the potential to emit chemicals of concern. Furthermore,

the study concluded that low-emitting, sustainable building materials are available

for all categories of materials tested. Approximately 40 percent of the tested

products emitted chemicals at rates that resulted in calculated concentrations that

exceeded the concentration limits and screening criteria used in the study. The

researchers found that emission limits were exceeded equally by both standard

and alternative products under the Section 01350 concentration limits, as well as

under more stringent IAQ criteria. The majority of the products that exceeded the

IAQ concentration limits did so by exceeding the limits of only one chemical, which

suggests that product reformulation could readily improve the environmental

safety of the product. Moreover, the investigators recommended that building

product manufacturers should specifically reduce emissions of naphthalene,

formaldehyde, and acetaldehyde from their products. Since rubber-based resilient

flooring products emitted substantially greater amounts of VOCs, further

refinement and testing of these products is necessary before they can be

promoted for wide-use in most indoor environments. Industry-supported product

certification programs or product labels claiming low-or zero VOCs may not

sufficiently protect building occupants. These concerns warrant frequent product

testing through independent laboratories. A copy of the study may be found at

http://www.ciwmb.ca.gov/GreenBuilding/Specs/Section01350/METStudy.htm.
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74

♦ OEHHA recently conducted a school-based, cross-sectional epidemiological study

to examine associations between proximity to traffic and respiratory health among

children living and attending schools at varying distances from high-traffic

roadways in Alameda County, California (Kim et al., 2003). Most of these children

are nonwhite and of lower socioeconomic status. Outdoor concentrations of

nitrogen oxides (NOx), nitric oxide (NO), and black carbon (BC) measured at

neighborhood schools were used as surrogates for children’s overall exposure to

traffic pollutants. These pollutants were increased at schools nearby versus those

more distant from (or upwind of) major roads, and were associated with both

bronchitis and episodes of asthma. Another study by OEHHA examined the

number and demographic profile of public schools in California by proximity to

major roadways (Green et al., 2002). A substantial number of children in

California attend schools that are close to major roads with very high traffic

counts, and a disproportionate number of those students are economically

disadvantaged and minority.
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5. INFORMATION FROM OTHER STATES

The most comprehensive, previous statewide study of classrooms was conducted in

Texas, including an assessment of environmental conditions in 115 classrooms. The

investigators found that the use of chemical cleaning compounds and air fresheners,

especially during after-hours custodial cleaning when there was likely inadequate

ventilation, led to elevated VOC concentrations of several target compounds including

d-limonene and p-dichlorobenzene (Torres et al., 2002). The Texas study found no

statistically significant differences for mean school-day and peak carbon dioxide (CO2)

concentrations between portable and main building classrooms, or when data were

separated by teacher responses to questions regarding classroom odors. About 2/3 of

the classrooms had school-day averaged CO2 concentrations above 1000 ppm (per

ASHRAE 62), reflecting a prevalence of inadequate ventilation (Corsi et al., 2002).

In an IAQ assessment at a Texas public high school (Petronella et al., 2002),

formaldehyde concentrations were measured above federal occupational guidelines in

classrooms where the HVAC systems ran on normal daily cycles, and windows and

doors were closed. Inspections, however, found 16 of 19 classrooms had ventilation

rates below the ASHRAE 62 recommendation.

Several states have undertaken mandated or voluntary efforts to improve IEQ in public

school buildings. Maryland’s Department of Education (1987) established a program on

IAQ in public schools in 1987, and it developed a seminal set of guidance documents on

related school facility issues (such as ventilation systems, carpets, interior painting, and

science laboratories) (Maryland, 1996). The State of Washington developed their “best

management practices” for IAQ in 1994 (Washington DOH, 1995), and the Texas

Health Department recently issued “voluntary guidelines” for IAQ in schools (Texas

DOH 1998), under mandate from their legislature. The Minnesota Department of Health

has developed extensive training and guidance for schools, including a streamlined

inspection package, an IAQ Management Plan Development Package, and website

links to funding source information (Minnesota, 2003).

Others states have conducted comprehensive review or evaluation of school IEQ to

develop programs to solve noted problems, including Vermont (1999) and Delaware

(1998). Similar efforts have been successful even at the local level; the County of

Montgomery (MD) (1998) developed its own IAQ Action Team and report with guidance

and specific recommendations for achieving good IAQ in public schools. Healthy

School Networks in Massachusetts, and New York were established to press for

improvement in their state’s facilities. These are coalitions of teacher, parent, and nonprofit organizations. In New York, they successfully pressed their State Regents to

sponsor an Advisory Committee on Environmental Quality in Schools. In contrast, there

is no established healthy schools stakeholder group or advisory board in California,

similar to those in other states.
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6. SUMMARY OF STAKEHOLDER INPUT

As mentioned above, ARB and DHS consulted with other interested state agencies and

stakeholders. Interested stakeholders included portable classroom manufacturers,

environmental and health organizations, school district administrators and facility

managers, teachers, school nurses, indoor air quality consultants, and ventilation

companies.

6.1 Pre-Study Workshops

The first set of workshops were conducted in February and March, 2001, in

Sacramento, Oakland, El Monte (Los Angeles), and San Diego. ARB and DHS staff

presented information on the overall study design, as well as details regarding the

intended schedule and scope of the project. The workshops were well-attended.

Participants asked a variety of questions regarding the study, and also provided

comments or suggestions regarding the planned study design, questions to include in

the questionnaires, plans for external notice and review, and other topics. The following

is a brief listing of some of the comments received during the initial workshops:

♦ Some schools wanted their results prior to the end of the study, others did not

want them. (Results were provided by RTI directly to schools that requested

them).

♦ Portable classroom manufacturers concerned regarding premature press and

media coverage of results...wanted assurance they would be able to review the

report ahead of time (report to be released to everyone at once).

♦ Requested on-line resources for parents and teachers regarding indoor air

quality (DHS provided this online feature subsequent to the workshops).

♦ Would like to review detailed study protocols (general protocols could be

reviewed, but detailed protocols not available for review prior to study due to tight

study schedule).

♦ Be sure to consider age of the classrooms...old and new portables are very

different (age was recorded for all classrooms and used regularly in analysis of

the data).

♦ Please consider the type of installation and foundation...some portables have

had mold and other problems because of improper installation, foundation skirts

too close to the ground, etc. (Foundation skirt and installation information was

included on the technician inspection checklist).

♦ Concerns were raised over how appropriate health thresholds would be selected

and discussed in the final report. (OEHHA’s acute and chronic Reference
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77

Exposure Levels were used, along with other health and comfort standards and

guidelines that are available, such as those of IESNA, ASHRAE, and others.)

6.2 Post-Study Workshops

Four public workshops, again two each in northern and southern California, plus

webcast and phone access, were also held during the review period for the public draft

of this document. Many useful comments were received, and the report was modified

as appropriate. Comments frequently heard included the following:

♦ Not all Group I recommendations are low cost, and some are not easy to

accomplish. It may cost some schools quite a bit of money to comply with state

regulations.

♦ The recommendation for a task force to develop long-term funding sources and

mechanisms for construction and preventive maintenance should be in Group I

because it is a high priority: that effort should start now.

♦ Noise is a key factor. The State should set a standard of 45 dBA now.

♦ The issue is not just one of facility maintenance. Teachers should be trained

regarding indoor environmental quality. They are a key part of the solution to

classroom problems because they often turn off HVAC systems or adjust the

thermostat improperly, and they bring in items such as “air fresheners” that

actually contribute to indoor air pollution and degrade the indoor environment.

♦ Purchasing agents, janitors, and facility managers need to be trained too.

Perhaps “distance learning” would work for these groups.

♦ Desks and other items added to the classroom can emit formaldehyde. Schools

should purchase formaldehyde-free furnishings.

♦ Solutions and changes should be pursued through collaborative efforts, such as

with the California Teachers Association, the NEA, the ALA, and others.

♦ HVAC systems can be made quieter by offsetting the return air vent, using

baffling, and other actions. Systems need to be quiet to be usable.

These and the many other specific comments received during the workshops and

comment period were used in revising the recommendations of this report. Some

comments did not warrant changes to the report document, but rather were submitted to

provide information regarding specific substitute products that are available and other

useful information.
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7. RECOMMENDATIONS AND DISCUSSION

The results of this study demonstrate that, on a statewide basis, many schools are not

models of hygiene or healthfulness, and that there is a need for improvement in some

areas. However, the picture is not dire: the most serious problems occur only at a small

percentage of schools. The environmental problems identified in this study generally

fall into the following key areas: (a) inadequate classroom fresh air ventilation (due to

many causes); (b) unnecessary or uncontrolled sources of chemicals, particles, or other

contaminants; (c) unchecked moisture intrusion; and (d) ineffective cleaning,

maintenance, or repair practices. The most effective solutions require addressing the

underlying causes of the problems, and promoting those systems that appear to be

working well.

 Actions are needed at all levels to provide classroom environments that are healthy

and conducive to effective learning for K-12 students. Problems generally need to be

resolved and prevented at the classroom and school level, but districts and the State

must be partners in providing the tools and guidance for effective solutions.

Approaches to prevent and remedy most of the problems identified in this study are

available. While some may be subject to fiscal constraints, most often what is needed

is systematic review and attention to these issues. Many of the problems identified in

this study can be addressed through meeting existing State standards and guidelines

(primarily those of Cal/OSHA), including requirements to provide continuous outdoor air

exchange; improved operation and maintenance programs; and focused training efforts.

Many can be addressed at relatively low cost.

There are four key approaches needed to remedy the problems identified in this study,

each with several specific recommendations for implementation. The four over-arching

approaches are:

♦ Direct and assist schools to comply with State regulations, especially workplace

regulations related to operation and maintenance.

♦ Develop and promote “Best Practices” for design, construction, operation and

maintenance of school facilities.

♦ Improve support (funding and training) for school facilities and staff.

♦ Establish needed guidelines and standards for school environmental health.

Each specific recommendation below supports one or more of these over-arching

approaches. The specific recommendations are presented in two groups:

Group 1: includes actions that are high priority and would yield high benefits at

relatively low cost. These recommendations should be pursued within the next

one to two years.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

79

Group 2: these recommendations are also a priority, but will require a longerterm effort and/or additional resources in order to be fully implemented. These

actions should be initiated in the next year or so, but may require four to five

years to implement fully.

Because traditional classrooms had many of the same problems found in portable

classrooms and a portion of both types of classrooms exceeded applicable guidelines

for health and comfort, the recommendations below are directed toward preventing and

resolving problems in all classrooms, unless otherwise noted.

GROUP 1: High Priority, High Benefit Actions, with Relatively Low Cost

Group 1 recommendations build largely on regulations, programs and activities that are

already in place but that are not fully met or utilized.

1. Meet State Regulations. Schools, districts, and the state should assure that all

school buildings meet all relevant State regulations, particularly those related to

operation and maintenance. Many classrooms do not meet various existing State

standards, and meeting those regulations would go far to provide healthful

conditions in classrooms. For example, operating HVAC systems as they were

intended to be operated to assure adequate outdoor air ventilation; developing a

health and safety program and training employees to implement that program, per

requirements of the Injury and Illness Prevention Program regulation; and

maintaining sanitary conditions and correcting water intrusion, leakage, and

uncontrolled accumulation of water to reduce the potential for mold growth – all

workplace requirements enforced by Cal/OSHA – would correct several of the major

problems seen in classrooms. To achieve this, many districts may need to increase

their maintenance staffing: many districts do not meet the maintenance staffing

ratios recommended by the California Association of School Business Officials

(CASBO). Some remedies may not be low-cost, depending on the nature of the

non-compliance.

2. Conduct District and School Self-Assessments. Districts/schools should conduct

“self-assessments” of basic safety and health conditions, similar to the selfinspection program undertaken by the LAUSD. In addition to assessing whether

state regulations are being met, self-inspections can also be used to remedy obvious

problems that are not necessarily regulated, and as a first step to begin to

incorporate “Best Practices” into operation and maintenance functions (see below).

The LAUSD’s basic checklist is provided in Appendix V; districts/schools can use all

or part of it to conduct their own walk-throughs and identify key problems in the near

term. Conditions that can be corrected with little or no cost should be remedied

promptly. Plans should be developed to obtain resources to address those that

require additional funds to remedy; for example, noisy HVAC units should be

scheduled for modification or upgrade.
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80

3. Require IEQ Management Plans. The State should require districts and schools to

develop an IEQ Management Plan. Such a plan would complement and extend the

benefits of the self-assessment discussed above. The U.S. EPA’s IAQ Tools for

Schools Kit provides guidance for developing such a plan: see

http://www.epa.gov/iaq/schools/. Visalia, Saugus, San Francisco, and Clovis,

among others, have successfully and cost-effectively implemented Tools for Schools

in their schools. Districts and schools should implement key provisions of the

program and other preventive operation and maintenance measures that are high

benefit/low cost, including:

a. Appoint an IEQ manager and form an IEQ team.

b. Establish a regular inspection and maintenance schedule; ensure that HVAC

systems are thoroughly cleaned and inspected at least annually.

c. Use checklists for core inspection and preventive actions.

d. Educate the building occupants: ventilation systems should remain “on”, and

pollutant sources such as “air fresheners” should not be brought into the

classroom.

e. Implement procurement policies and practices for classroom furnishings and

supplies that assure good indoor air quality, such as desks and bookcases that

emit no formaldehyde.

4. Establish “Best Practices” Policy. The State should establish a policy to

incorporate “Best Practices” into the design, construction, operation, and

maintenance of new California schools, especially the measures developed by the

Collaborative for High Performance Schools (CHPS). Because of the large number

of new construction and renovation projects statewide at this time, there is a unique

opportunity to foster a new generation of classrooms that provide a healthful

environment conducive to learning. The CHPS Best Practices Manuals provide an

array of options and information that can be used in designing, constructing, and

renovating school buildings. CHPS-based schools have a high potential for reduced

energy consumption, and thus save energy dollars as well. The CHPS manuals and

videos are available at http://www.chps.net/; manuals for operation and maintenance

are under development. Districts and schools should use CHPS Best Practices to

the fullest extent feasible, at a minimum incorporating a few of the low-cost options

that are suitable for their situation. Additionally, specific recommendations gleaned

from this study and from stakeholders’ input, are included in Appendix VI. Key

examples are:

a. Specify no- and low-emitting building materials and furnishings in construction

contracts and solicitations. This should include using exterior grade wood

products in wall & floor materials; no-formaldehyde insulation, ceiling tiles, and

cabinetry; and other low- or no-emitting materials to avoid elevated formaldehyde

and VOC levels.

b. Specify HVAC systems that provide sufficient airflow at noise levels less than

45 dBA.

c. Design sprinklers and landscaping properly so water does not hit the building,

and drains away from the structures.
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5. Expand State Design Review. State-level design review for new buildings and

major renovations should be expanded. Review and approval of elements such as

ventilation system design and building materials should be added to the routine

structural, fire and life-safety, and accessibility plan-check function of the Division of

the State Architect (DSA). The DSA is currently initiating specification revisions and

implementing a more proactive approach in plan reviews, but additional trained staff

are needed for the additional work. DSA and OPSC should be permitted to hire the

needed staff to the extent resources allow.

6. Assure Proper Siting. Portable classrooms should be sited appropriately, away

from highways and busy roads, and with proper grading. Individual portable

classrooms should not be placed over low drainage areas that experience flooding.

The foundation skirt should be at least 6 inches or more above ground level to

prevent wicking of water up the wall, and adequate crawlspace ventilation should be

specified. Some of these measures may not be low cost for some schools.

7. Limit Noise Levels in Classrooms. Implement an interim state requirement for a

maximum decibel level of 45 dBA in new, unoccupied classrooms, and encourage

specific sound reduction measures, especially reduction of noise from HVAC

systems and lights.

GROUP 2: Priority Actions Requiring a Longer Term Effort and/or Substantial

Additional Resources

8. Assure stable, long-term funding. The State and districts need to develop stable,

long-term funding mechanisms and sources for both school construction and

preventive maintenance. Current funding programs are strained, fluctuating, and

often function on a short timeframe. The current year-to-year fluctuation of the

existing Deferred Maintenance Program does not provide stable, consistent funding

for long-term planning and preventive maintenance. Implementation of the

recommendations of The California Master Plan for Education drafted by a Joint

Legislative Committee and A New Blueprint for California School Facility Finance by

the Legislative Analyst’s Office (May 2001) would provide some substantial

progress, particularly for construction. However, preventive maintenance is not

adequately addressed in these plans, and requires further action.

9. Develop Focused Training. The State should develop and offer coordinated

training programs and materials for facility managers, custodial staff, and teachers,

in cooperation with interested organizations. Those who are closest to the

classroom are often not aware of current “best practices” for operation and

maintenance of classrooms. For example, teachers inadvertently bring pollutant

sources into the room, improperly adjust thermostats, or take other actions that can

have a major impact on the environmental conditions of the classroom. Training is

an important part of U.S. EPA’s IAQ Tools for Schools Program. Focused statewide

training programs are needed over the long-term to assure that key school staff

receive appropriate training, so that they can routinely train new staff as they come
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82

on board. DSA and OPSC should develop training programs and materials in

consultation with ARB, DHS, CEC, Cal/OSHA, and other relevant agencies, as well

as CASBO, CASH, and other relevant external groups. These should include:

a. A Training and Certification Program for School Facility Managers. Success in

operation and maintenance is often a function of the strength and knowledge of

facilities directors, yet there are few credentials districts can apply in their

selection of key facility department personnel. Districts should hire trained,

certified facility managers.

b. Development and routine distribution of training materials for custodial staff on

proper vacuuming and cleaning procedures. Effective vacuuming of carpets

requires an efficient vacuum plus a reasonable “residence time” of the vacuum

on the carpet surface in order to effectively remove particles. This can effectively

reduce persistent contaminants in carpeted classrooms. Vacuums do not need

to be true HEPA, but do need to be efficient, and have virtually no particle

leakage in the exhaust. Additionally, use of “safe" liquid or spray cleaning

products is a key component of a healthy building.

c. Development of training materials and programs for teachers that builds on

information in U.S. EPA’s IAQ Tools for Schools Kit, and includes more specific

information on California ventilation requirements and sources of indoor

pollutants.

10. Implement Integrated Pest Management. Integrated Pest Management Programs

should be implemented at all schools. The passage of the Healthy Schools Act of

2000 established requirements for schools to notify parents of pesticide use and to

consider IPM. Successful application of IPM has been sufficiently widespread to

support its implementation at all public schools, and to eliminate the use of

pesticides with the greatest potential for toxic effects by school personnel. A

program of preventive housekeeping practices and use of least-toxic pesticides

when application is necessary has many benefits. See the Department of Pesticide

Regulation website at http://www.cdpr.ca.gov/cfdocs/apps/schoolipm/main.cfm .

11. Retire older portable classrooms. Classrooms should be removed and replaced

when they become unserviceable or do not provide an adequate learning

environment for children. Some older portables are well past the stage at which they

should have been replaced with a new portable or a site-built classroom. New

portable or site-built buildings will generally not only provide an improved

environment but also will be more energy-efficient, with substantially reduced energy

costs relative to the old buildings.

12. Develop and require full building commissioning procedures. These

procedures are “best practices” for new buildings and classrooms. They should

include complete testing of HVAC, lighting, and other building systems under normal

and high-capacity operational conditions.

13. Improve school facility database. The State needs an effective system to

inventory public school facilities. These represent among the State’s greatest
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83

assets, yet there is no complete database on the condition, location, or even number

of school buildings.

14. Convene a task force on noise. A task force of experts in audiology, medicine,

education, and related fields should be convened by the State to develop a

California indoor noise guideline or standard for K-12 schools. If needed, promote

technology development to meet such a guideline or standard.

15. Develop State-level chemical exposure guidelines or standards for

classrooms. There is a lack of benchmarks for fully assessing and assuring

healthful environmental conditions specific to classrooms and to the children and

teachers who occupy them. Currently available guidelines and standards applied in

this report may not be fully protective of children.

16. Re-design portable classrooms from the ground up. Although many

improvements have been made in recent years, most portable classrooms

manufactured today are still based on designs and materials that have been

available for 20-30 years or more, and on an assumption of a need for frequent

relocation, which has not proven to be common. Southern California Edison,

Lawrence Berkeley National Laboratory, and several portable classroom

manufacturers have begun to develop very different styles of relocatable

classrooms. These should be fully developed and used on a trial basis under

different conditions to determine if these newer designs might better meet future

classroom needs.

Implementation of some of the recommendations above will clearly incur costs to those

involved, and will require fiscal planning to achieve. However, the cost of not taking

these actions appears high – potentially harmful impacts on children’s and teachers’

health, reduced learning, reduced educational progress, and, in some cases, higher

costs to fix facility problems when they become more serious. Most importantly, State

building, ventilation, and workplace regulations have been developed to assure safety

and health, and must be met.

The LAUSD’s self-inspection program has shown that much can be done at relatively

low cost, and provides a good starting point. The CHPS Best Practices Manuals and

U.S. EPA’s IAQ Tools for Schools Action Kits provide readily available guidance that

can be used by districts and schools at varying levels, based on their individual

resources and situations. The experiences of Visalia, Saugus, San Francisco, and

other districts have shown that IAQ Tools for Schools can work well in California.

Appendix VI provides more specific recommendations for schools and districts. It is a

working document that will be updated periodically and made available on ARB’s

website.
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8. SUMMARY AND CONCLUSIONS

The California Portable Classrooms Study (PCS) was conducted to address concerns

raised regarding environmental conditions in California’s portable classrooms. The

objective of the study was to examine environmental health conditions, especially those

related to indoor air quality and health risks, in K-12 portable classrooms in California.

These environmental conditions included levels of airborne chemicals; the presence of

potential pollutant sources; the performance of heating, ventilating, and air-conditioning

systems; factors such as light, noise, temperature, and relative humidity; the presence

of mold and other biological contaminants; and pollutant and allergen levels in floor

dust.

A preliminary mail survey to all school districts conducted by DHS in Fall, 2000

indicated that 85 percent of K-12 public schools had at least one portable classroom at

that time, and that about 80,000 portable classrooms were in use statewide, totaling

about one-third of all California classrooms. These portable classrooms ranged in age

from less than one year old to over 40 years old.

The study was conducted in two phases: Phase I was a mailed survey in which

questionnaires and passive formaldehyde monitors were sent to over 1000 randomly

selected public schools with at least one portable classroom in the spring of 2001.

Phase II was a field study of a wide array of environmental measurements obtained in

201 classrooms at 67 schools statewide, from October 2001 through February 2002. At

each school, two portable classrooms and one traditional classroom were studied.

8.1 Results

Both portable and traditional classrooms were found to have some environmental

conditions that require improvement. However, the picture is not dire: the most serious

problems occur only at a small percentage of schools. Remedies to address the

problems identified are available, although some will incur more than minimal costs.

The solutions require a combination of actions by the State, districts, schools,

manufacturers, facility managers, teachers, parents, and others. Adherence to state

regulations, improved operation and maintenance, and enhanced training of school

personnel, can go a long way to address many, but not all, of the problems identified.

The primary problem areas identified include the following:

1. Ventilation

♦ Inadequate at times in about 40% of the classrooms, and seriously deficient in

about 10% of classrooms.

♦ A majority of teachers in portables have turned off the ventilation system at times

due to excess noise.

♦ Portables had more instances of dirty HVAC filters, closed dampers, and airconditioner condensate drainage problems.
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85

♦ Noise is the primary issue that needs to be addressed by HVAC manufacturers,

and lower noise levels (45 decibels or less) should be specified by schools.

2. Temperature and Humidity

♦ A small percentage of portable classrooms had temperatures above or below the

ASHRAE standard for acceptable indoor temperature, and about 11%-14% of

classrooms had relative humidity levels outside the ASHRAE standard range for

comfort.

♦ Properly operating and maintaining HVAC systems should remedy these

problems in most classrooms.

3. Air Pollutants

♦ Indoor formaldehyde concentrations were elevated above OEHHA health

guideline levels. Highest levels occurred primarily in the warmer seasons, as

expected, and primarily in portable classrooms. Alternative low-emitting

materials are available and should be used in constructing new portable

classrooms.

♦ VOCs were present indoors at levels similar to other indoor environments. Levels

were below acute (immediate effects) risk levels; although some classrooms

exceeded the one in a million excess cancer risk level for a few VOCs, this is not

a major concern because outdoor sources likely contributed most to these levels.

♦ Real-time particle counts were somewhat higher in portable classrooms for PM10

and PM2.5 size ranges, likely due to proximity to vehicle traffic.

4. Floor Dust Contaminants

♦ Metals: Levels of lead measured in floor dust in some classrooms were

elevated. Arsenic levels were slightly higher in portables, and above the one in a

million cancer risk level in most classrooms.

♦ Pesticides: Residues of both generally available and restricted pesticides were

found in all floor dust samples, and six pesticides were detected in over 80% of

the samples: esfenvalerate, chlorpyrifos, cis- and trans-permethrin, ophenylphenol, and piperonyl butoxide. Chlorpyrifos can last up to a year or more

in the environment; the other five are shorter-lived, lasting just a few weeks.

Children can be exposed to pesticides through inhalation, ingestion (fingers in

the mouth), and dermal contact, and children in the lower grades tend to spend a

substantial amount of time sitting on the floor; therefore the number of pesticides

found in the floor dust are of concern, although it is not yet known whether levels

are above exposure and risk levels of concern

♦ PAHs also were found in over 80% of the classrooms. However, levels in the

dust were relatively low.

♦ Allergens: Cat and dog allergens were measured in more than half of the

samples, but the concentrations were generally below sensitization levels.

Cockroach and dust mite allergens were only infrequently found.
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86

5. Moisture and Mold

♦ In the mail survey, a large percentage of teachers reported smelling musty odors

in their classroom, or current or previous floods or leaks, and 11% reported

visible mold.

♦ In the field study, 3% of classrooms were observed to have visible mold, and at

least 21% had visible water stains on the ceiling and/or floor. About 17% of all

classrooms had excess moisture measured in the walls, ceiling, or floor. Water

stains and measurements of excess moisture in building materials often indicate

hidden mold, and at a minimum indicate a moisture problem that needs to be

resolved.

6. Noise

♦ All classrooms exceeded the recently developed acoustic standards of 35

decibels background noise for unoccupied classrooms, and many exceeded

outdoor nuisance standards of 55 decibels used by some California cities.

♦ Stakeholders have indicated that 45 decibels, the level recommended by CHPS,

is achievable, but that 35 decibels appears technologically and financially

unattainable at this time. California does not have a noise guideline or standard

for classrooms.

7. Lighting

♦ About one-third of classrooms do not meet IESNA professional design

guidelines.

♦ Portable classrooms had somewhat lower lighting levels than traditional

classrooms

8.2 Recommendations

Approaches to remedy and prevent the problems identified in this study are available.

Both state-level and district/school level actions need to be taken. Many of the

problems can be addressed through meeting existing State level standards and

guidelines (primarily those of Cal/OSHA), which include providing continuous outdoor

air exchange; through improved operation and maintenance programs; and through

focused training efforts. Many also can be addressed at relatively low cost, although

some remedies will incur more substantive costs.

There are four general approaches needed to remedy the problems identified in this

study, each with several specific recommendations for implementation. The four overarching approaches are:

♦ Direct and assist schools to comply with State regulations, especially workplace

regulations related to operation and maintenance.

♦ Develop and promote “Best Practices” for design, construction, operation and

maintenance of school facilities.
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

87

♦ Improve support (funding and training) for school facilities and staff.

♦ Establish new guidelines and standards for school environmental health.

Specific recommendations are provided in support of each of these. They include

seven recommended (Group 1) actions that are high priority, would yield high benefits,

and be achieved at relatively low cost. These recommendations should be pursued

within the next one to two years. The highest priority recommendation is that all school

buildings need to be brought into compliance with existing state regulations. Districts

and schools should start with “self-assessments” of basic safety and health conditions,

similar to the program of self-inspections undertaken by the LAUSD. They also should

develop and implement Indoor Environmental Quality Management Plans such as the

IAQ plans included in U.S. EPA’s IAQ Tools for Schools. “Best Practices” should

become the policy for the State and all districts and schools for design, construction,

operation, and maintenance of school facilities, and State-level design review for new

buildings and major renovations should be expanded. Close attention needs to be paid

to properly siting portables and other school facilities. Finally, an interim state

requirement that noise levels in new, unoccupied classrooms not exceed 45 dBA should

be imposed until an appropriate task force of experts can identify an appropriate indoor

level that is acceptable for California classrooms.

Another nine specific recommendations (Group 2) are also a priority, but will require a

longer-term effort and/or additional resources in order to be fully implemented. These

actions should be initiated in the next year or so, but may require four to five years to

implement fully. Some of these recommendations include: assuring long term, stable

funding for facility construction and maintenance; developing enhanced training

materials and programs for facility managers, custodians, and teachers; and developing

State-level chemical exposure guidelines or standards for classrooms. And finally, older

portable classrooms that no longer provide acceptable learning environments should be

retired, and support given to promoting new, more advanced portable classroom

designs.

Some cost is involved with the recommendations discussed above for the State and for

districts and schools: many are relatively low-cost, but some have substantial costs and

require focused fiscal planning to address. However, the cost of not taking these

actions may be much higher − harmful impacts on children’s and teachers’ health,

reduced learning, reduced educational progress, and, in some cases, higher costs to fix

facility problems when they become more serious. The LAUSD’s self-inspection

program provides a good starting point for districts, and the CHPS Best Practices

Manuals and U.S. EPA’s IAQ Tools for Schools Kit provide valuable tools for designing,

operating, and maintaining “high performance” schools.

8.3 Conclusions

The environmental health problems identified in this study ranged across several areas,

including inadequate operation and maintenance of ventilation systems, contaminants
 ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORNIA’S PORTABLE CLASSROOMS

88

present at undesirable levels in the air and floor dust, excessive noise levels,

inadequate lighting, and mold and moisture problems. A number of programs initiated

by the State, districts, and others before or during the conduct of this study are already

beginning to address some of these concerns. However, increased effort and a more

focused approach are needed to assure that existing problems are remedied and future

problems prevented. The State, district and school administrators, school facility

managers, teachers, manufacturers of portable classrooms, manufacturers of ventilation

systems, and others who provide materials and supplies used by our schools all have

an important role in improving the environmental health conditions of our schools. Most

importantly, California needs to transition to true prevention programs that have stable

funding.
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89

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Environmental Health Conditions in California’s Portable Classrooms

I - 1

APPENDIX I

LEGISLATIVE MANDATE
Environmental Health Conditions in California’s Portable Classrooms

I - 2

HEALTH & SAFETY CODE § 39619.6

The legislative mandate for the Portable Classroom Study is contained in the Health &

Safety Code amendment contained in Section 11 of Assembly Bill 2872 (Shelley, 2000):

39619.6. (a) By June 30, 2002, the state board and the State

Department of Health Services, in consultation with the State

Department of Education, the Department of General Services, and the

Office of Environmental Health Hazard Assessment, shall conduct a

comprehensive study and review of the environmental health conditions

in portable classrooms, as defined in subdivision (k) of Section

17070.15 of the Education Code.

 (b) The state board and the department shall jointly coordinate

the study, oversee data analysis and quality assurance, coordinate

stakeholder participation, and prepare recommendations. The state

board shall develop and oversee the contract for field work, air

monitoring, and data analysis, and obtain equipment for the study.

The department shall oversee the assessment of ventilation systems

and practices and the evaluation of microbiological contaminants, and

may provide laboratory analyses as needed.

 (c) By August 31, 2000, the state board shall release a request

for proposals for the field portion of the study. Field work shall

begin not later than July 2001. The final report shall be completed

on or before June 30, 2002, and shall be provided to the appropriate

policy committees of the Legislature. The study of portable

classrooms shall include all of the following:

 (1) Review of design and construction specifications, including

those for ventilation systems.

 (2) Review of school maintenance practices, including the actual

operation or non-operation of ventilation systems.

 (3) Assessment of indoor air quality.

 (4) Assessment of potential toxic contamination, including molds

and other biological contaminants.

 (d) The final report shall summarize the results of the study and

review, and shall include recommendations to remedy and prevent

unhealthful conditions found in portable classrooms, including the

need for all of the following:

 (1) Modified design and construction standards, including

ventilation specifications.

 (2) Emission limits for building materials and classroom

furnishings.

 (3) Other mitigation actions to ensure the protection of children's health.
Environmental Health Conditions in California’s Portable Classrooms

II - I

APPENDIX II

DHS PRE-SURVEY
CA/DHS/EHLB/R-404

II-2

Survey of Portable Classrooms in California:

Estimating Numbers and Ages for 2000-01

California Department of Health Services

Indoor Air Quality Section / Environmental Health Laboratory Branch

2151 Berkeley Way, Berkeley, CA 94704

June 2003

ABSTRACT

A survey of all California school districts was conducted to acquire information about classroom

facilities. Data for over 90% of state public schools were collected, and the following estimates

of numbers and ages were determined: all classrooms totaled 268,030, and the number of

portables totaled 79,191 (29.5% of all) for the 2000-01 school year. Older portables (more than

15 y) and newer portables (5 y or less) totaled 27.9 % and 39.3% of all portables, respectively.

Districts reported plans to acquire an additional ~5% (4100) portables during the year; this

estimate is based on less complete data than for numbers and ages of portables. Elementary

schools were found to have lower numbers of students per classroom, to more frequently have

portables, and to use a higher proportion of portables, compared to middle and high schools.

The state’s largest districts’ classrooms used portables at the same proportion as the statewide

average. However, the portables used at the largest districts were more frequently older units

(44% versus 28%). The largest districts appear to have growth rates higher than the state

average, and planned portable purchases were projected at somewhat higher rates. Updated

estimates need to be made more readily available in the future. Information on classroom

facilities (e.g., numbers, ages, areas, chairs, etc.) should be included in a state inventory (similar

to the CBEDS database).

INTRODUCTION

Public kindergarten to 12th grade (K-12) education in California functions within a complex

system of local, county, state, and federal authorities, regulations, and funding. Individual

schools operate within semi-autonomous school districts, which are administrated under locally

elected school boards. Notwithstanding state or federal mandates or financial resources, all

aspects of school function, including school facility management, are under local control and

responsibility. Central bodies, such as the Department of Education, and funding agencies, such

as the State Allocation Board, can dictate what schools should or should not do, and what funds

they will or will not receive. However, it ultimately falls to the local school officials to fulfill

these mandates or suffer the consequences. Under very rare circumstances, the county or state

education agency can take over daily district operations.

The semi-autonomous organization of public K-12 education has led to gaps in the information

available on public school facilities in California. While there are centralized state databases on

the districts and schools with respect to enrollment, staffing, demographics, state funding,

compliance with some regulations, and standardized test scores, at present, there is no centralized
DHS Survey of Portable Classrooms

II-3

database for public school facilities in the state. In the absence of this kind of database, there is

no way to answer seemingly simple questions such as: How many portable classrooms are

currently being used in the state? What is their age distribution? How many new portables are

planned for purchase in a given year? And, what schools/districts use portables to a greater or

lesser degree?

In mid-2000, the Department of Health Services (DHS) and the Air Resources Board started

planning the California Portable Classrooms Study (PCS). The PCS was designed to enlist

~1000 schools in a mail survey, and ~70 schools for field study to investigate environmental

conditions in portable classrooms as well as traditional classrooms. In order to extrapolate PCS

results to statewide estimates of school conditions, information would be needed about how

many (and which) schools had portables, as well as the total numbers of classrooms in the state.

Hence, it was necessary to develop a survey instrument to query districts about portable

classrooms at their schools. Sampling a subset of school districts would not have addressed the

PCS planning goals, so a more labor-intensive “total enumeration method” was used. This prePCS (DHS) survey was conducted to acquire data to coincide with PCS Phase I (2000-01 school

year).

METHODS

DHS staff initiated a mail survey directed to all school districts listed in the California

Department of Education (CDE) list of public school districts and schools, which includes

mailing addresses and district contacts1

. CDE uses a cataloging system for schools and district

with CDS codes, for which unique numbers are given for each County, District, and School in

the state. There are 58 counties, almost 1,100 districts, and more than 10,000 schools (active and

closed), and their 2-, 5-, and 6-digit codes, respectively, are combined into the 13-digit CDS

code. A new database was created in ACCESS with records for each district and each school in

the state using their CDS codes. Schools showing no current enrollment, or no grades between K

and 12th (e.g., community colleges) were excluded from our database. Demographic information

was acquired from the CBEDS (California Basic Education Data System) demographic data

files2

.

District and school records were cross-referenced, and individual survey packets were generated

for each district. Each district packet listed the individual schools for the district onto a data

form. Survey packets included the data form with cover letter from the State Superintendent of

Public Instruction, Ms. Delaine Eastin. Survey packets were mailed to district offices in late

November 2000. Electronic files of the data form were supplied by DHS to the largest districts.

Examples of the data form and letters are shown in the Appendix.

Table 1 lists the queried items requested on the survey form for each school within the district.

The data form asked that a knowledgeable district staff person provide information “as of

November 1, 2000,” for each school in the district. Portables were defined as relocatable

classroom structures, generally factory manufactured and without foundations. The form asked

 

1 California Public School Directory, 2000. available from CDE Press. Updated directories are available on-line at

http://www.cde.ca.gov/demographics/files/schoolname.htm. 2

 Data files and additional information are available on-line at http://www.cde.ca.gov/demographics/files/index.html.
DHS Survey of Portable Classrooms

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that the age be determined using the date of manufacture, not delivery date. Many districts

contacted DHS for clarification, most often to determine whether or not to include units in noninstructional uses, e.g., teachers’ lounges, bathrooms, offices, and storage, and staff was

instructed to exclude these units.

Table 1. Survey Form Queries Sent to Each School

3⁄4 Total number of classrooms in use

3⁄4 Total number of portables in use as instructional classrooms

• The number of portables older than 15 years (1985-86 or earlier)

• The number of portables newer than 5 years (1995-96 or thereafter)

3⁄4 Number of additional portables on order or planned for installation during 2000-

01 school year.

The responses to the initial survey packet were received from about 30% of districts by the due

date (December 8, 2000). Follow-up letters and/or faxes were sent to non-responding districts in

January, February, April, and May 2001 (see example in Appendix), and each time additional

data forms were acquired. Additionally, phone calls were made to medium and large districts.

The largest districts were provided an electronic version of the database to complete. In June

2001, the response rate was up to 75%, and a decision was made to continue querying nonresponsive districts in the following school year. Forms sent in the Fall 2001 were modified to

determine the numbers of portables added in 2000-01. Hence, data acquired from school

districts in 2001-02 were adjusted to the base year (2000-01).

RESULTS

The survey database included 1049 districts and 8554 individual schools. Enrollment in 2000-01

totaled just over 6 million (Table 2). More than 90% of districts provided information for the

survey; these districts contained 92% of the state’s schools and 94% of student enrollment

(Table 3). Some responses were incomplete, omitting entries for portable of older/younger ages

and/or new portables planned for the next school year, and the rates for these items are somewhat

lower.

Table 2. California Public School Student Enrollment and Number of Teachers

1999-2000 2000-01 2001-02 2002-03

Students 5,940,976 6,038,231 6,134,839 6,236,359

Teachers 290,547 297,277 300,032 n/a

Source: CBEDS Aggregated Data Files: “Enrollment by school” (enrsch**) and “Teacher by school”:

(tchcrd**).

Table 3. Response Rates for Classroom Survey Forms

Any response

(%)

Portable

Classrooms (%)

Old vs. Young

Portables (%)

New Portables

planned (%)

Districts 90.2 - - -

Schools 92.3 91.9 89.2 65.1

Enrollment 94.0 93.7 91.3 61.5
DHS Survey of Portable Classrooms

II-5

Using the data provided for each school, number totals for each item were tabulated. Totals were

then adjusted using the enrollment response rates. That is, estimates of statewide totals were

determined by taking the data provided for schools reporting, then scaling it upward,

proportional to the enrollment of responding schools (i.e., dividing by the response rate). For

classrooms numbers and the number older/younger portables, the adjustment is small (e.g.,

1/0.94 = 1.064 or +6% adjustment). Estimates of new portables planned have greater

uncertainties, since the adjustment for missing schools is higher (+60%).

For 2000-01, DHS estimated there were 268,000 classrooms in use at the state’s public schools

(Table 4). The statewide average classroom occupancy was about 22 students per classroom.

Actual occupancies cover a wide range, from the mandated 20 or less for K-3 grades in

elementary schools to 30 or more students in some middle and high schools. About one-third of

the total classrooms – almost 80 thousand– were portables used for instruction in California

public schools. A small fraction of schools, under 13%, had no portables at all.

Table 4. Estimates of Classroom Numbers and Age for 2000-01

Number Note

All classrooms: 268,030 21.8 students per classroom

Portable classrooms:

 All 79,191 29.5 % of all classrooms

 Older (more than 15 y) 22,061 27.9 % of all portables

 Newer (5 y or less) 31,126 39.3 % of all portables

 New Portables planned (for 2001) 4,109 5.2 % of current portables

School Type. Most schools in California house a standard subset of K-12 grades as follows:

Elementary – K - 5th, Middle – 6th to 8th, and High – 9th to 12th grades. Some schools use less

standard grade ranges, and notwithstanding their CDE designation, these were categorized as

above or as follows: “Lower” – K to 8th; “Upper” – 7th to 12th; and “All” – K to 12th. CDE

designates some schools as “alternative” or “continuation,” and these were parsed according to

their grade levels as given in CBEDS. The numbers and total enrolment for each school type are

given in Table 5.

The average number of students per classroom was higher in middle and high schools than

elementary and “lower” grade schools (22-24 versus 19-21 students per classroom). Classrooms

at K-12 (“All”) schools were the most crowded on average (29 students per classroom).

Similarly, middle and high schools contained proportionally fewer portable classrooms than

elementary schools and “lower” grade schools (~22% versus 35%). Portables were used more

frequently at schools containing “All” grades (39%) and “Upper” grades (42%). While

elementary schools used almost twice the proportion of portables than middle and high schools,

the fraction of schools with at least one portable classroom was relative close (93% versus 82%).

Classroom Age. A large proportion of portable classrooms (39%) were manufactured in 1996

or later, while almost 28% were built before 1985. School districts anticipated purchasing more

than 4000 new portable classroom units for 2001-02, which represented about a 5% growth in

numbers (although how many units were planned for “retirement” was not determined).
DHS Survey of Portable Classrooms

II-6

Table 5. School, Enrollment, and Classroom Data by School Type for 2000-01

School Type (by grade levels)

Elementary

(K to 5)

Middle

(6 to 8)

High

(9 to 12)

“Lower”

(K to 8)

“Upper”

(7 to 12)

“All”

(K to 12)

All

schools

 # Schools

Schools 55.8% 14.3% 17.7% 7.3% 1.8% 3.1% 8,554

% w/portables 92.7% 83.7% 80.9% 73.0% 66.9% 71.6% 87.4%

 Enrollment

Students 48.5% 18.3% 27.4% 3.6% 0.4% 1.8% 6,007,002

% at schools

with portables 95.7% 86.7% 91.0% 87.0% 80.0% 77.0% 92.2%

Students per

classroom 21.1 24.1 22.4 19.4 16.5 29.0 21.8

 Classrooms

Total 51.6% 16.9% 25.6% 4.2% 0.4% 1.5% 268,030

Portables 60.9% 13.1% 18.7% 4.9% 0.5% 1.9% 79,191

% portables 34.8% 22.8% 21.6% 34.6% 42.4% 38.6% 29.5%

In the Portable Classroom Study (PCS), school and classroom age distributions were estimated

from data for ~500 schools, weighted for the sampling frame and response rates. The respective

age distributions are given in Table 6. The age distribution of traditional classrooms is very

similar to the schools, while portable classrooms are characteristically younger. The data

indicate that about 11% of traditional classrooms were added in expansion projects at older

schools in recent years. Compare this to the more than 40% of portable classrooms added in the

prior 10 years.

Table 6. Classroom & School Age Distribution (in Spring 2001)

Age Range Portable Traditional Schools

0 to 3 y 22.6% 5.2%

4 to 5 y 18.6% 1.8%

6 to 10 y 14.1% 5.5%

11.0%

11 to 15 y 22.1% 7.6%

16 to 20 y 8.4% 1.7% 7.3%

21 to 30 y 8.0% 18.8% 10.9%

31 to 40 y 4.9% 18.0% 22.0%

41+ y 1.3% 41.4% 48.7%

Source: California Portable Classrooms Study Phase I: Mailed Survey. Final Report

(Appendix D). Prepared by Research Triangle Institute, RTP, NC. Contract No. 00-

3017, March 2003.
DHS Survey of Portable Classrooms

II-7

The Pre-PCS study data is likely to be more accurate than the PCS data, because it used nearly

complete enumeration, while the PCS used stratified sampling and acquired data for <10% of

schools and <1% of classrooms. Nonetheless, while the Pre-PCS study used fewer age

categories, the two studies are in close agreement regarding portable classroom age distribution:

Age Range DHS survey PCS survey

0 to 5 y 39% 41%

6 to 15 y 33% 36%

16+ y 28% 23%

Using the PCS data set to interpolate mid-range values, the statewide distribution for portable

classroom age can be estimated for 2001 (Figure 1). More than half of all portable classrooms

(in 2001) were 10 years or younger, while over 11,000 portables (14%) were 20 years or older.

Statewide, almost 5,000 portables being used as classroom were 30 years or older.

Largest Districts. Data for the state’s largest districts are given in Table 7. These 20 districts

contain 29% of the state’s public school enrollment and 23% of the schools. Collectively, their

enrollment growth rate was greater than statewide average (0.9% versus 0.3%). Six districts

grew over 2% between school years. The largest districts’ classrooms were somewhat more

crowded (22.5 versus 21.8 students per classroom) and used portables at the same proportion as

the statewide average (~30%). Notably, the portables used at the largest districts were frequently

older units (44% versus 28%), and fewer of their portables were newer units (27% versus 39%).

Information on “planned to purchase” portables was incomplete; the weighted mean for the

districts providing data (n=6) was 7.7%, compared to 5.2% statewide. Subsequent to the 2000-

01 survey, Los Angeles Unified reported purchasing 245 portables in 2001-02 or a ~3% increase

per year. 

0

5

10

15

20

25

30

35

40

45

0 5 10 15 20 25 30 35 40 45 50

%

Figure 1. Statewide distribution of portable classroom ages (y) in 2000-01.
DHS Survey of Portable Classrooms

II-8

Table 7. Data for 20 Largest School Districts in California (2000-01)

Rank District County

2000-01

Enrollment

Growth

Ratea

#

Schools

Average

Studentsb

per

Classroom

# All

Classrooms

Portables

as % All 

1 Los Angeles Unified Los Angeles 720,534 1.7% 655 23.1 28,493 29.2% 2 San Diego City Unified San Diego 140,328 -0.6% 175 19.8 7,043 34.9% 3 Long Beach Unified Los Angeles 93,235 2.5% 85 21.0 4,268 28.8% 4 Fresno Unified Fresno 77,588 1.3% 94 21.7 3,433 37.7% 5 San Francisco Unified San Francisco 59,979 -2.4% 113 17.6 3,500 8.4% 6 Santa Ana Unified Orange 59,837 -1.1% 50 24.5 2,527 31.4% 7 Oakland Unified Alameda 54,264 -4.2% 92 23.3 2,262 29.1% 8 Sacramento City Unified Sacramento 53,693 0.9% 79 18.7 2,752 38.7% 9 San Juan Unified Sacramento 50,167 2.0% 83 19.9 2,433 21.2% 

10 Garden Grove Unified Orange 48,742 1.6% 65 25.0 1,926 21.0% 11 San Bernardino City Unified San Bernardino 52,031 0.5% 62 26.2 1,911 37.9% 12 Capistrano Unified Orange 40,913 -2.7% 39 21.8 1,790 37.4% 13 Elk Grove Unified Sacramento 46,090 4.5% 50 26.0 1,723 54.6% 14 Riverside Unified Riverside 38,124 4.1% 44 26.6 1,621 31.5% 15 Mt. Diablo Unified Contra Costa 36,614 0.3% 54 19.9 1,777 18.7% 16 Stockton City Unified San Joaquin 37,322 2.9% 44 22.4 1,607 34.9% 17 Saddleback Valley Unified Orange 35,199 -0.2% 37 23.1 1,569 24.9% 18 Montebello Unified Los Angeles 34,794 0.7% 28 25.2 1,350 37.0% 19 Fontana Unified San Bernardino 37,244 3.1% 34 25.4 1,440 35.3% 20 West Contra Costa Unified Contra Costa 34,499 -4.6% 59 21.1 1,650 26.1% 

LARGEST DISTRICTS 1,751,197 0.9% 1,942 22.5 75,076 30.1% ALL DISTRICTS 6,007,002 0.3% 8,554 21.8 268,030 29.5% 

a. Enrollment increase from 2000-01 to 2001-02b. District-wide average of school values
DHS Survey of Portable Classrooms

II-9

SUMMARY

When planning for the PCS commenced, no statewide inventory of portable classrooms existed.

A labor-intensive enumeration method was used to survey all California school districts

specifically about classroom facilities. Data for over 90% of state public schools were collected,

and estimates were determined of the number of all classrooms and portable classrooms as

follows: all classrooms totaled 268,030, and the number of portables totaled 79,191 (29.5% of

all) for the 2000-01 school year. Older portables (more than 15 y) and newer portables (5 y or

less) totaled 27.9 % and 39.3% of all portables, respectively. Districts reported plans to acquire

an additional ~5% (4100) portables during the year; this estimate is based on less complete data

than for numbers and ages of portables. Elementary schools were found to have fewer students

per classroom, more likely to have portables, and use a higher proportion of portables, compared

to middle and high schools. The state’s largest districts’ classrooms used portables at the same

proportion as the statewide average. However, the portables used at the largest districts were

more frequently older units (44% versus 28%). The largest districts appear to have growth rates

higher than the state average, and planned portable purchases were projected at higher rates.

Construction and modernization of school facilities represent a substantial capital investment of

state resources. Data on classroom facilities, including portable classrooms, should be collected

routinely. It is needed for surveys of environmental conditions, as well as educational programs.

These data are essential for long-range planning and to make informed policy decisions. Queries

on classroom facilities (e.g., numbers, ages, areas, energy use, etc.) should be included in a state

inventory system (similar to the CBEDS database), to ensure that this information is more

readily available in the future.
DHS Survey of Portable Classrooms

II-10

Appendix

Portables Survey Form for ARB/DHS Study

(template)

Draft Letter CDE Cover Letter to Survey Form

(from Superintendent Delaine Eastin to District Superintendents)

October 2000

Example of Follow-up Letters Sent to

District Superintendents and District Facility Directors

January 2001
DHS Survey of Portable Classrooms

Appendix

II-11

Portables Survey Form for ARB/DHS Study

Instructions: Please fill out the short form below. For each school within your district as of November 1, 2000, list

3⁄4 Total number of classrooms in use

3⁄4 Total number of portables in use (i.e., portables are defined as relocatable classroom structures, generally factory

manufactured and without foundations)

• Number older than 15 years (1985-86 or earlier) use the date of manufacture, not delivery date

• Number newer than 5 years (1995-96 or thereafter) use the date of manufacture, not delivery date

3⁄4 Number of additional portables on order or planned for installation during 2000-01 school year.

Please complete and return the questionnaire with two weeks (no later than December 8, 2000. Send the completed

form to Portable Study, c/o DHS-EHLB, 2151 Berkeley Way, Berkeley, CA 94704 (label enclosed). If you have any

questions or concerns regarding this survey, please contact DHS at 510-540-3427 or portablestudy@cal-iaq.org.

Thank you for your help.

School district: (Filled by DHS) County: (Filled by DHS)________________

Name of the respondent: ___________________________ Title: _____________________________

Phone number: ___________________________________ FAX: _____________________________

Email: _________________________________________ Date: _____________________________

As of November 1, 2000)

School CDS_CODE

Total #

classrooms

in each

school

Total #

portable

classrooms

# older than

15 yr.C

# newer than

5 yr.

Add’l #

planned in

2000-01

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)

(filled by DHS) (filled by DHS)
DHS Survey of Portable Classrooms

Appendix

II-12
DHS Survey of Portable Classrooms

Appendix

II-13

State of California-Health and Human Services Agency GRAY DAVIS, Governor

DEPARTMENT OF HEALTH SERVICES

Indoor Air Quality Section, Jed M. Waldman, Ph.D., Chief

Environmental Health Laboratory Branch

2151 Berkeley Way • Berkeley, CA 94704

510-540-2469 • FAX: 510-540-3022

E-mail: Jwaldman@dhs.ca.gov

January 4, 2001

Dear Superintendent:

FOLLOW-UP – Survey of Environmental Conditions in California’s Portable Classrooms

In November 2000, your office was sent a letter from Delaine Eastin, State Superintendent of

Public Instruction, asking your help in completing a statewide survey on portable classrooms.

With her letter (enclosed) was a survey form for your district.

The survey form for your district has not been received at this time. The form was designed

to require minimal effort on the part of your staff. It is important that we receive this

information as soon as possible. Please contact my office and let us know whether:

• You already sent us the form;

• You did not receive the letter and form (or are unable to locate them);

• You would like to receive the form in electronic format (EXCEL); or

• You need assistance or guidance in completing the survey.

You can reach me or my staff at 510-540-2469 or Portablestudy@CAL-IAQ.org.

Completed forms should be sent to “Portables Study, CDHS-EHLB, 2151 Berkeley Way,

Berkeley, CA 94704”.

This survey is part of a joint study by the State Air Resources Board and Department of Health

Services, sponsored by Governor Davis and supported by the Legislature in the 2000 session

(Chapter 144). As stated in Delaine Eastin’s letter, the findings from this study will form the

primary basis for recommendations that ARB and DHS must make to the Governor and the

Legislature. These recommendations will help shape future program and funding decisions at

the State level. Further information about the study can be found on the web:

http://www.arb.ca.gov/research/indoor/pcs/pcs.htm.

Your prompt response to this request is essential for the success of the ARB/DHS Portable

Classrooms Study.

Sincerely yours,

Jed Waldman, Ph.D., Chief

Indoor Air Quality Program

Enclosure

cc: Peggy Jenkins, California Air Resources Board

Duwayne Brooks, School Facilities Planning Division, California Department of Education
Environmental Health Conditions in California’s Portable Classrooms

III - I

APPENDIX III

RTI-ARB-DHS PROJECT EXECUTIVE SUMMARY
III-2

CALIFORNIA PORTABLE CLASSROOMS STUDY

PROJECT EXECUTIVE SUMMARY

FINAL REPORT, VOLUME III

CONTRACT NO. 00-317

PREPARED BY:

RTI International

3040 Cornwallis Road

Research Triangle Park, NC 27709

California Air Resources Board

Research Division

1001 I Street

Sacramento, CA 95814

and

California Department of Health Services

Environmental Health Laboratory

Indoor Air Quality Section

2151 Berkeley Way

Berkeley, CA 94704

May 2003
III-3

PROJECT EXECUTIVE SUMMARY

California Portable Classrooms Study

Background

The California Portable Classrooms Study (PCS) was conducted to address concerns

raised regarding environmental conditions in California’s portable classrooms. The objective of

the study was to examine environmental health conditions, especially those related to indoor air

quality and health risks, in K-12 portable classrooms in California. These environmental

conditions included levels of airborne chemicals; the presence of potential pollutant sources; the

performance of heating, ventilating, and air-conditioning systems; factors such as light, noise,

temperature, and relative humidity; the presence of mold and other biological contaminants; and

pollutant and allergen levels in floor dust.

Concerns over indoor environmental quality in California’s schools have been raised by

scientists, government agencies, school administrators, and environmental health groups, as the

demand for classrooms resulted in increased reliance on portable classrooms. Population

growth, class-size reduction programs, and fiscal limitations have driven this increase. Schools

have primarily met the increased demand for classrooms by using portable classrooms because,

relative to traditional classrooms, they are more economical and can be obtained more quickly.

Additionally, until 1998 new schools were required to be designed to include 30% portable

classrooms.

A mail survey to all school districts conducted by DHS in Fall, 2000, indicated that 85

percent of K-12 public schools had at least one portable classroom at that time, and that about

80,000 portable classrooms were in use statewide, totaling about one-third of all California

classrooms. These portable classrooms ranged in age from less than one year old to over 40

years old.

Problems previously reported in portable classrooms included elevated levels of

formaldehyde and some other VOCs, microbial growth, odors, uncomfortable temperatures,

excessive noise, and excessive use of pesticides. Such problems were attributed to the use of

pollutant-emitting materials, products, or equipment in or near buildings; inadequate or deferred

maintenance; and poorly designed and noisy HVAC systems. Outdoor factors such as improper

water drainage under the units and proximity to busy roadways used by diesel-fueled vehicles

also were of concern.

Some of the contaminants and conditions found in classrooms are known to trigger

allergy symptoms and asthma attacks in sensitive individuals; irritate mucous membranes in the

eyes, nose and throat; cause respiratory infections or headaches; and contribute to the

development of cancer. Some contaminants identified in problem classrooms have been listed as

Toxic Air Contaminants by the ARB, or listed on California’s Proposition 65 list of substances

of known or suspected carcinogens and reproductive toxicants.
III-4

In light of the concerns raised, the California Air Resources Board (ARB) and

Department of Health Services (DHS) requested funding in the 2000-2001 State budget to jointly

conduct a comprehensive study of the environmental health conditions in portable classrooms.

The State Legislature approved the request, and specified milestones and requirements in

Assembly Bill 2872, Shelley (California Health and Safety Code [HSC] Section 39619.6). The

Legislature also required that ARB and DHS develop recommendations regarding ways to

“...remedy and prevent unhealthful conditions found in portable classrooms...” (AB 2872). The

study was endorsed by the Superintendent of Public Instruction, Ms. Delaine Eastin.

The PCS consists of two major phases, conducted in sequence. Phase I was a mailed

survey in which questionnaires and passive formaldehyde monitors were sent to a randomly

selected sample of all public schools with at least one portable classroom in the spring of 2001.

Phase II was a field study with a wide array of environmental measurements obtained in 201

classrooms at 67 schools statewide, from October 2001 through February 2002. Both portable

and traditional classrooms were studied in both phases.

Results from this study will be used by ARB, DHS, and other stakeholders to assess the

potential for adverse health impacts from environmental conditions and toxic pollutants that may

be present in portable classrooms, as well as conditions considered to be outside the normal

limits of comfort. They will be used to help identify sources and factors that may lead to

unacceptable conditions, and provide direction for actions that can be taken to remedy or prevent

any unhealthful conditions found.

This project summary provides a brief overview of the methods, results, conclusions, and

recommendations documented in the two separate reports for Phase I and Phase II of the

California Portable Classrooms Study.

Methods

The sampling approach for this study was designed to provide approximately equal

probabilities of selection for all public schools in California with at least one portable classroom

in spring 2001. The sample was drawn using the California Public School Directory 2000,

which was published by the California Department of Education Press. DHS staff sorted this

frame by county/district/school code and selected a 1-in-7 systematic sample from the sorted

frame. The result was a sample of 1,216 schools that was stratified by county and district. DHS

then conducted a preliminary survey of the resulting school districts and eliminated 177 schools

that did not have any portable classrooms. These schools were deleted from further

consideration for the PCS, leaving 1,039 eligible schools for inclusion in Phase I.

Two questionnaires, a Facilities Questionnaire (FQ) and a Teacher Questionnaire (TQ),

were collaboratively created by ARB and DHS. These questionnaires included questions based

in part on input from public, industry, and government agencies obtained during public

workshops held across the state. The questionnaires were used during both phases of the study

to obtain information from facility managers and teachers about the environmental quality

conditions and complaints at the sampled schools. The FQ provided school-level and

classrooms-level information on the physical conditions, operation, and maintenance of building
III-5

facilities. The TQ provided classroom-level information, including information on the presence

of potential pollutant sources.

The Phase I study was conducted in the spring of 2001 with data receipt continuing to a

limited extent through the summer of 2001. Facility managers provided school-level data (n =

384) and classroom-level data (n=1,133), via the FQ. A total of 1,181 teachers provided

additional classroom level data via the TQ. The classroom data were collected for three

classrooms—usually two portable classrooms and one traditional classroom—at each school.

Additionally, for a sub-sample of the classrooms, passive formaldehyde samplers (small glass

tubes) were mailed along with the survey materials for deployment in the classrooms. They were

placed in the classrooms for approximately 10 days to collect indoor air samples that were

analyzed to determine formaldehyde concentrations. Valid indoor air formaldehyde

concentration data were obtained for 911 classrooms (644 portable and 267 traditional) from 320

schools. Prior to mailing the samplers, ARB conducted tests to confirm the utility of the

samplers for this study. Working with the manufacturer, ARB developed approaches that

improved the sensitivity and precision of the samplers, which had been used in previous mail

surveys by DHS (Sexton et al., 1989; Liu et al., 1991). Analysis of the laboratory blanks resulted

in an estimated detection limit of 6 ppb for the Phase I study. Analysis of the duplicate samples

verified that precision was good (10% to 15% median RSD).

Phase II was a monitoring field study of environmental conditions in a smaller

probability sample selected from all schools with at least one portable classroom both in the

spring of 2001 and in the 2001-02 school year. Of 81 eligible schools in the Phase II sample,

both questionnaire and environmental monitoring data were obtained for 67 schools and 201

classrooms. Of the 67 schools, fourteen schools were specially selected into the Phase II sample

based on their Phase I results (high complaints of environmental problems or high formaldehyde

levels), to help determine whether classrooms with apparent or reported problems actually had

serious environmental problems. The Phase II study was conducted from October 2001 through

February 2002. It utilized a probability-based sample of California public schools (and random

selection of classrooms within the schools) having one or more portable classrooms. The sample

of schools selected for the Phase II survey is statistically representative of all California public

schools that had portable classrooms in both the spring and fall of 2001.

In the Phase II study, both school-level and classroom-level data were obtained.

Consistent with the Phase I approach, classroom data were collected for three classrooms per

school, usually two portable classrooms and one traditional classroom. Field technicians

inspected the HVAC system and building interiors and exteriors. Various types of data were

collected at each participating school including:

• Questionnaire and checklist data: (1) Facilities Questionnaire II, (2) Consultation with

Facilities and HVAC Managers (Part 2); (3) Teacher Questionnaire II; (4) Classroom Form;

(5) Consultation with Facilities and HVAC Managers (Part 1); and (6) an HVAC Assessment

Checklist and School Characteristics data form.

• Environmental and biological measurements: Sampling in occupied classrooms was

conducted during one school day at each school, with samplers set up in the morning prior to
III-6

arrival of students, and removed at the end of the day. HVAC testing, noise measurements,

and sampling for culturable airborne organisms were conducted during lunch breaks (see

Table PES-1). Environmental samples were stored on ice and shipped weekly by overnight

delivery.

• Field QC samples: Field QC checks were performed before and after sampling. Field blanks

and controls were each collected at a 5% rate. Field duplicates were collected for indoor air

pollen and spores, aldehydes, VOCs, and dust. Precision (measured as % RSD--relative

standard deviation) averaged 10% or less across the sample types.

Table PES-1. Summary of Environmental and Biological Samples

Sample Classroom Air Outdoor Air

Floor

Dust Comments

Airborne

Carbonyls X X 13 Aldehydes, including

formaldehyde

VOCs* X X 9 VOCs, including

benzene, toluene, xylenes,

chlorinated hydrocarbons

Pollens & 

Spores

X X 22 pollen and fungi species

possible

Culturable 

microorganisms

X X Specially selected schools

only

Particle counts X X 2 cut points: <2.5 and <10

:m

Floor Dust

Pesticides X 20 studied

Metals X 18 including Lead

PAHs X 16 studied

Allergens X 5 (cat, dog, 2 dust mite,

cockroach)

Environmental

CO2 X X continuous

Temperature

Rel. Humidity

X X continuous

Noise X X Unoccupied classroom

measurements

Light X 3 locations in room

Moisture X Walls, floor, and ceiling

*Half the schools were selected for VOC monitoring.
III-7

Results

The estimated number of K-12 public classrooms in California in the 2000-2001 school

year was about 268,000, and about one-third of those (80,000) were portable classrooms based

on the DHS preliminary survey. The target population of K-12 public schools with one or more

portable classroom was estimated to consist of 230,000 classrooms, 37% of which are estimated

to be portable classrooms.

To fulfill the objectives of the study, questionnaire responses, observations, and

measurements of indoor pollutant levels, ventilation conditions, noise and lighting levels were

characterized, and comparisons to environmental standards and guidelines, and comparisons

between portable and traditional classrooms were made. Also, associations between indoor

environmental conditions and building factors such as age, building material types and

ventilation factors were explored.

Response Rates

Phase I

There were 1,181 completed Teacher Questionnaires from the 2856 mailed, and 384

completed Facilities Questionnaires from the 952 sampled schools. Valid indoor air

formaldehyde concentration data were obtained for 911 classrooms. Response rates between 40

and 45% (for questionnaires and formaldehyde monitoring) were obtained for school-level

responses. However, for schools that responded, response rates of about 95% were obtained at

the classroom level for the teacher questionnaires and for school deployment of the

formaldehyde samplers, suggesting a strong interest by the participating schools. The overall

response rates of 40-45% are considered good for mail surveys.

Phase II

Questionnaire data and environmental monitoring data were successfully collected in 67

of 81 sample schools, resulting in an overall weighted school-level response rate of 83%. Such a

response rate for school-level participation in Phase II of this study is quite good and limits the

possibility for nonresponse bias to seriously affect the results. The Phase II response was

successful because of additional steps taken to achieve good participation: recruitment began

early in the school year, permission was obtained from superintendents before contacting

principals, and three experienced staff members made repeated recruitment calls to

superintendents and principals.

Phase I Results

School Characteristics and Maintenance Practices

The sample consisted largely of elementary schools (59% of the total), schools in

suburban areas (74%), and schools more than 30 years old (64%). About half of the schools had
III-8

55% or more of their students on Federal meal assistance (Bell, 2001), and about half spent at

least the state-wide median of $5500 per student each year (Edwards, 2001).

In the past year, facility managers received major complaints about environmental

problems in classrooms--such as air quality, water leaks, and noise--in about half of the schools

(52%). About one third (35%) of the facility managers were aware of the U.S. EPA’s program

for managing indoor air quality in schools (Tools for Schools), but only 11% of the facility

managers used the program. About two-thirds of the facility managers (67%) reported keeping

maintenance logs for the HVAC system, although all schools are required to keep such logs.

About 5% of the facility managers reported never inspecting major components of the HVAC

system, such as the outdoor air damper setting, condensate drain pan, and coils. About half of

the schools (57%) swept, vacuumed, and dusted the classrooms five days a week.

Classroom Characteristics and Results

In Phase I, significant differences in the reported building characteristics, environmental

complaints, and teacher symptoms were found between portable classrooms and traditional

classrooms. Portable classrooms were most often used at elementary schools, and typically for

general instruction rather than laboratory, art, or other special classes. They were typically 600-

1100 square feet in size (69% of the total). About 55% of the portables were 10 years old or

newer.

As indicated in Table PES-2, portable classrooms were reported more frequently than

traditionals (p < 0.10) to have carpeted floors, vinyl tackable wallboard, pressed wood

bookcases, suspended ceilings, and metal roofs. Traditional classrooms were located more often

at high schools and middle schools, were used more often for special classes, had a larger floor

area, and were older (only 19% were 10 years old or less).

Table PES-2. Percent of Classrooms with Characteristics Noted, Phase I

Characteristic Portables Traditionals All

Carpeted floors 70.7 34.3 47.8

Vinyl tackable wallboard 78.6 28.4 47.0

Pressed wood bookcases 55.3 47.8 50.6

Suspended ceilings 86.5 62.4 71.6

Metal Roofs 54.2 15.0 29.5

The HVAC systems in portable classrooms were typically packaged wall units (81%)

with thermostat control by teachers in the room (45%). Teachers reported opening the windows

or exterior doors at least occasionally in about half the portable classrooms (58% and 42%,

respectively). A high percentage (60%) of the teachers in portables turned off the HVAC system

due to noise. About half the teachers (52%) reported disruptive noises in classrooms, and about
III-9

two thirds (64%) reported disruptive noises outside the portable classrooms. The above HVAC,

window, and noise characteristics were reported less often (p < 0.05) for traditional classrooms.

In Phase I, teachers reported on various factors that contribute to indoor environmental

quality. As shown in Table PES-3, the most common pollutant source category reported for

portable classrooms was paints and marker pens (97% of all portables), followed by glues and

correction fluids, and laboratory chemicals and cleaning products. Less commonly reported

pollutant sources included office equipment, pesticide ever used by the teacher, and construction

in the classroom that year. Air fresheners, which may also indicate poor classroom air quality,

were used in about 40% of the portable classrooms and about 30% of the traditional classrooms.

Table PES-3. Selected Pollutant Source Categories Reported by Teachers (% yes)

Classroom

Type

Paints,

Marker

Pens

Glues,

Correction

Fluids

Laboratory

Chemicals,

Cleaning

Fluids

Pesticide

Usea

Construction in

Classroomb

Air

Fresheners

Portable 97c 67 44 21 16 39c

Traditional 91 66 52d 24 14 31

a. Similar proportions of facility managers reported that they had sprayed these rooms in the past year.

b. During the school year the questionnaire was administered.

c. Significantly greater (p < 0.05).

d. Significantly greater (p < 0.10).

Traditional classrooms differed significantly from portable classrooms in some of these

categories. Air fresheners, and paints and marker pens, were reported slightly less often in

traditional classrooms (p < 0.05). On the other hand, traditional classrooms had slightly more

reports of the presence of laboratory chemicals (p < 0.10).

With regard to moisture and mold indicators, over two-thirds (69%) of teachers in

portable classrooms reported that they noticed musty odors at times. Less than half (43%) of

these teachers reported current or previous leaks or floods in the room, the majority of the leaks

coming from the roof (27% of all portables). Visible mold, either currently or previously, was

reported by 11% of portable classroom teachers. For traditional classrooms, teachers reported

the presence of musty odor less often (58%, p < 0.01), but they reported previous flooding

significantly more often (47%, p < 0.05).

Teachers in portable classrooms were asked to characterize the general environment of

their classroom. Nearly one-fourth of these teachers reported the temperature to be too hot

(13%) or too cold (9%). Over one third of these teachers described the room air as too stuffy

(38%). About one-third of the teachers in portable classrooms reported the lighting to be too dim

(21%) or too bright (7%). Over one-seventh (13%) of these teachers rated the overall

environmental quality of their classroom as poor. About one-third of the teachers (30%) in
III-10

portables preferred working in portable classrooms, and another third (35%) preferred traditional

classrooms.

Compared to teachers in portable classrooms, the teachers in traditional classrooms

reported fewer of the above problems with room air quality (especially stuffiness) and with

lighting (especially dim conditions) (p < 0.01). Temperature problems, especially excessive

heat, were reported more frequently in traditional classrooms (p < 0.05). Teachers in traditionals

less frequently rated their class room environmental quality as poor (p < 0.10). A much higher

percentage of these teachers (84%) preferred working in traditional classrooms

(p < 0.05).

In portable classrooms, the frequencies of most types of odors−for example, new carpet

or furniture, fresh paint, pesticide odors, vehicle exhaust, and trash/dumpster odors−reported by

teachers ranged from about 5 to 15% of the classrooms. However, cleaning product odors were

reported more frequently (31% of portables). In comparison to portable classrooms, teachers in

traditional classrooms reported odors from new carpet and furniture significantly less often (9%).

However, odors from cleaning products and fresh paint were reported significantly more often

(41% and 15%, respectively).

Measurement Results

In Phase I, valid indoor-air formaldehyde concentration data were obtained from 911

classrooms (320 schools). The mean formaldehyde levels were 32 ppb in portables, 24 ppb in

traditional classrooms, and 27 ppb across all classrooms. Only about 3% of the classrooms had

non-detectable concentration levels, i.e., less than 6 ppb. Thus, nearly all of the classrooms had

indoor, 10-day average formaldehyde levels greater than typical outdoor levels in California

(3 ppb), the Proposition 65 notification level equivalent for air (1.3 ppb), and the California

Chronic Reference Exposure Level (REL) of 2.4 ppb for long-term exposure (ARB, 2001;

OEHHA, 2002; OEHHA, 2001). The latter level is based on protecting sensitive individuals

from nasal and eye irritation and nasal/upper airway injury resulting from long-term exposures.

The short-term health-based guidelines for formaldehyde in California are 27 ppb (Draft

8-hour Indoor REL) and 76 ppb (1-hour Acute REL) (Broadwin, 2000; OEHHA, 1999). These

guidelines are designed to protect sensitive individuals against eye irritation and effects on the

respiratory and immune systems resulting from acute, short-term exposures. The 10-day average

levels of formaldehyde are designed as screening estimates, and do not directly compare to

standards and guidelines based on shorter time periods. However, because they are longer-term

averages, they are probably conservative estimates of 1- and 8-hour levels of formaldehyde

reached in classrooms.

As can be seen in Table PES-4, the formaldehyde concentrations were significantly

higher for portable classrooms than for traditional classrooms. For example, 50% of the

portables had concentrations above 27 ppb, whereas only 29% of the traditional classrooms were

higher than 27 ppb. Also, 4% of the portables had concentrations above 76 ppb, whereas only

0.4% of the traditional classrooms were higher than 76 ppb. When adjusted for classroom age,

the difference between the two classroom types was only significant in the newer classrooms.
III-11

Table PES-4. Phase I Formaldehyde Concentrations Compared to Health Guidelines

All

Rooms

Portable

Classrooms

Traditional

Classrooms

% of Rooms > 27 ppb 36.9 50.3 29.0

% of Rooms > 76 ppb 1.8 4.0 0.4

Mean (ppb) 27 32 24

In Phase I, a number of factors appeared to be significantly (p < 0.05) associated with

high formaldehyde levels in classrooms. These include higher levels in:

• Newer classrooms

• The warmer season

• Rooms with pressed wood cabinets, new carpet and flooring

• Rooms with chemicals present

• Larger classrooms

• Southern California

• Rooms with new furnishing odor.

These results are consistent with prior studies that have found that formaldehyde is emitted at

higher rates at higher temperature and humidity; is commonly emitted at high rates from certain

pressed wood products (those made with urea-formaldehyde resins); and off-gases over time

such that newer materials have higher emissions, and emissions decrease over months to years,

depending on the characteristics of the particular material or product. (Kelly et al., 1999;

Godish, 1989; Sexton et al., 1989; National Research Council, 1981)

Phase II Results

Like the Phase I results, both school-level and classroom-level information was obtained

in Phase II. Additionally, Phase II included classroom and HVAC inspections and extensive

environmental measurements.

School Characteristics and Maintenance Practices

The following school characteristics for the total California population of schools were

identified:

• The schools are mostly suburban, elementary schools;

• Many of the schools (40.1%) have 30 or fewer total classrooms, but 4.4% are estimated to

have over 30 portable classrooms.

• Most schools (87.9%) perform regular HVAC inspection and maintenance.

• About half of the schools (58.7%) keep HVAC Maintenance Logs, which are required by

State regulations.
III-12

• Many of the schools (41.7%) are aware of EPA’s Tools for Schools program, but few

(18.7%) use this program.

These results are consistent with the Phase I findings, except that the awareness and use of the

EPA’s Tools for Schools program was slightly higher in Phase II.

Classroom Characteristics and Results

The following general characteristics relate to the total California target population of

classrooms:

• The classrooms are mostly in suburban schools (75.5% suburban, 17.8% urban, and 6.6%

rural).

• The classrooms are mostly in elementary schools (59.0% elementary, 22.9% middle, and

18.1% high school, based on the highest grade offered).

These results are comparable to those observed in Phase I of the study.

Physical and Environmental Characteristics

Similar to Phase I results, portable classrooms usually were newer than traditional

classrooms (29.1 percent versus 83.4 percent over 15 years old). Similarly, as shown in Table

PES-5, portable classrooms more often had carpet or rugs on the floor, vinyl tackable wallboard,

fiber/particle board or plywood walls, and pressed wood bookcases in the room. All of these

materials are possible sources of formaldehyde, and some other VOCs. In addition, portable

classrooms were again more likely to have a metal roof (28.5% versus 2.5%) and to have water

stains on the floor (18.1% versus 2.0%); however, portable classrooms were more likely to have

carpets, so would be more likely to have water stains on a carpeted floor.

Table PES-5. Percent of Classrooms with Characteristics Noted, Phase II

Characteristic Portables Traditionals All

Carpeted floors 82.0 62.9 69.7

Vinyl tackable wallboard 36.5 16.4 23.5

Pressed wood bookcases 73.1 49.8 58.2

Metal Roofs 28.5 2.5 12.1

The estimated distribution of the height of the foundation skirt for portable classrooms is

as follows: 42.6% are less than 2” above the ground, 22.2% are from 2” to 12” above ground,

and 35.2% are over 12”. Foundation skirts close to the ground have been reported to be more
III-13

susceptible to surface water contact and wicking of water up wall materials, resulting in mold

and moisture problems.

Phase II provided more in-depth information about HVAC characteristics and comfort

indicators:

Ventilation / HVAC

• The mean difference in outdoor air flow, total supply air, and HVAC age were not

significantly different between portable and traditional classrooms.

• Teachers were more likely to turn off the HVAC system due to high noise levels in portable

classrooms (68.3% versus 42.2%), HVAC systems were generally wall mounted in portable

classrooms (79.8% versus 9.3%) and electricity-based (94.6% versus 76.9%);

• The air filter for the HVAC unit in portable classrooms was more likely than traditionals to

have a light or medium loading of dirt.

• During the Phase II inspections, portable classroom HVAC units were less likely to have

clean condensate drain pans and lines (30.0 versus 56.7%), and were more likely to fail the

“drain test” used by the inspector to test for blockage (58.5 versus 12.4%).

• Also, the air intake was blocked on the air handling units more often for portable classrooms

than for traditional classrooms (10.8% versus 2.7%).

As can be seen in Table PES-6, both portable and traditional classrooms had school-day

average concentrations of carbon dioxide (CO2) greater than 1000 ppm, and both classroom types

had one-hour average CO2 levels above 1000 ppm for about 40% of the school day. Both

classroom types had one-hour average CO2 levels above 2000 ppm for about 10% of the school

day. These results indicate insufficient ventilation in a substantial portion of California

classrooms.

Table PES-6. CO2 Levels as an Indicator of Ventilation Sufficiency

Portable Traditional All

mean ppm across

school day 1064 1074 1070

% with one-hour

average above 1000

ppm (mean) 42.1 43.2 42.8

% with one-hour

average above 2000

ppm (mean) 9.2 10.1 9.8

Lighting

The mean light intensity in the center of the classroom was significantly lower for

portable classrooms (55.7 foot-candles [f-c]) than for traditional classrooms (65.2 f-c). A total of
III-14

8.8% of the portable classrooms and 4.4% of the traditional classrooms failed to meet the

Illuminating Engineering Society of North America’s (IESNA, 2000) light guideline of 30 f-c for

high contrast materials. Also, 38.3% of the portable classrooms and 27.2% of the traditional

classrooms failed to meet the requirement of 50 f-c of light needed for low contrast materials.

However, there was no significant difference between the opinions of teachers in portable and

traditional classrooms regarding whether or not the classroom lighting was satisfactory.

Noise

All classrooms exceeded 35 dBA, the American National Standards Institute (ANSI,

2002) acoustic standard and World Health Organization (WHO, 1999) guideline for unoccupied

classroom acoustics. In fact, 50% of the noise measurements taken indoors for the portable

classrooms and 37.5% of the traditional classrooms failed to meet the outdoor noise nuisance

standard of <55 dBA adopted by a number of cities in California (City of Sacramento, 2003; City

of Davis, 2003; City of Los Angeles, 2003). None of the HVAC noise measurements were

significantly different (at the 5% significance level) between portable and traditional classrooms,

except that indoor noise near the return register with the HVAC off was significantly greater in

the portable classrooms (p < 0.10).

Temperature and Relative Humidity (RH)

A relatively large percentage of the classrooms in California do not achieve the ASHRAE

standards for acceptable temperature and relative humidity. Portable classrooms had

temperatures below 17 EC (63 EF) for more of the time (6.3% versus 3.2%); and they had

temperatures below 20 EC (68 EF) for more of the time (27.0 % versus 17.0%). Both portables

and traditionals exceeded 23 EC (73EF) about 27% of the time, but traditionals had a higher

percent of time at very high temperatures (> 26 EC [79 EF] and > 29 EC [84 EF]). None of the

RH summary measures exhibited statistically significant differences between the means of the

two types of classrooms; average RH measurements were 46.8% and 45.9% for portable and

traditional classrooms, respectively, within the acceptable range. However, as can be seen in

Table PES-7, California classrooms do not achieve the ASHRAE standards for acceptable

relative humidity a substantial portion of the time.

Table PES-7. Average Percent of Time Outside ASHRAE Standards for Relative

Humidity

RH Level Portable Classrooms Traditional Classrooms All

<30% 11.0 11.4 11.3

>50% 44.7 45.6 45.3

>60% 16.9 12.6 14.1
III-15

Airborne Pollutant Levels

Aldehydes

Of the 13 specific aldehydes included in the analysis, only two were detected in more

than 75% of the samples − formaldehyde and acetaldehyde. Five other aldehydes were

measurable in at least 25% of the samples. For virtually all of the aldehydes, the indoor levels

were higher than the outdoor levels, indicating the presence of indoor sources. Formaldehyde,

for example, had a an overall mean level of 13.3 ppb indoors, but only 3.5 ppb outdoors, while

the indoor-air 95th percentile was 3 times higher than outdoors (see Table PES-8). Statistically

significant differences (0.10 level of significance) between mean levels of portable and

traditional classrooms (portable classroom averages were always higher) were found for

formaldehyde (15.1 versus 12.3 ppb) and acetaldehyde (7.2 versus 6.4 ppb). Significant

differences were also found in o,p-tolualdehyde (0.91 versus 0.21 ppb) and 2,5-

dimethylbenzaldehyde (0.01 versus 0.00 ppb), but these aldehydes were measurable in only a

very small percentage of classrooms.

Table PES-8. Formaldehyde Results, Phases I and II

Sample size (n) Mean (ppb) Median (ppb)

95th Percentile

(ppb)

Location Phase I Phase II Phase I Phase II Phase I Phase II Phase I Phase II

Outdoor NA 62 NA 3.48 NA 2.4 NA 8.05

All classrooms 911 199 27.0 13.3 22.0 12.0 61.7 23.9

Portable 644 135 32.4 15.1 27.1 14.5 71.5 25.8

Traditional 267 64 23.7 12.3 20.0 11.6 55.0 22.4

Table PES-8 also shows that the Phase II formaldehyde concentrations were considerably

lower than those observed in Phase I. The differences were not unexpected, and are likely

attributable to seasonal differences, the different measurement methods used in the two Phases,

and possibly other factors. For example, the Phase I measurements were obtained mostly in the

spring and summer, when formaldehyde emissions and levels tend to be higher, whereas the

Phase II measurements were obtained in the fall and winter. The Phase I measurements used PF1 passive monitoring tubes sampling over 7 to 10 days, including nights and weekends when the

schools were closed and HVAC systems may have been off. Thus, the night and weekend

periods might have raised the measured levels. However, the passive monitoring method has the

advantage of sampling over at least a week long period rather than just one day, and because it

could be conducted by mail, had the advantage of allowing for a much larger sample size, which

would be more likely to capture classrooms with very high or very low formaldehyde levels.

The Phase II measurements used an active monitoring device during the 6 to 8 hours when

classes were in session, the HVAC systems were operating, and doors and windows would be

opened. This would tend to yield lower levels than measured in Phase I. Additionally, the

HVAC inspections during Phase II required that the ventilation system be operated so that it

could be tested, so that the overall air exchange rates for the Phase II classrooms might have
III-16

been somewhat higher than normal, resulting in lower measured formaldehyde levels. Because

of all of these factors, annual average formaldehyde levels would be estimated to fall somewhere

between the Phase I and Phase II levels.

VOCs (non-carbonyl)

Seven of the nine measured VOCs had at least 80% of their measured levels above the

detection limit. The other two were detected in at least 50% of the samples. For all nine VOCs,

the traditional classrooms had higher average concentrations than did the portable classrooms,

but none of the differences in mean concentrations were significant statistically, even at a

significance level of 0.10. As in most indoor air quality studies, the measured indoor VOC

concentrations were higher than those observed outdoors. Average in-class room concentrations

ranged from a high of 6 ppb for toluene (slightly less for m,p-Xylene) to less than 0.5 ppb for

chloroform. For all others, the averages were in the range of 1 to 2 ppb.

Particulate Matter

Real time counts of particles were measured in each classroom and outdoors. Although

particle counts cannot be directly associated with mass concentration standards, the

measurements provide a relative indication of mass for comparison purposes.

Mean counts of particles per minute for particles of 2.5μm or less and for particles

of 10μm or less were not significantly different for portable and traditional classrooms.

However, the average counts for the two particle sizes of interest, <2.5 microns and <10 microns,

were higher in the portable classrooms, especially for the smaller size range. In addition, at the

95th percentile, the difference is even more remarkable for the higher portable concentrations in

both size ranges. One possible explanation is that, as mentioned before under the characteristics

of the classrooms, carpets and rugs were more often found in the portable classrooms, and could

be a source of the particles. Additionally, portable classrooms may be nearer outdoor sources

such as busy roadways and parking lots, especially in urban areas where school site space is

limited.

Pollens and Spores

In general there were few spore types that were observed frequently in either the outdoor

or indoor environments. In the outdoor environment, only six were frequently seen (on 80% or

more of the slides)—Amerospores, Ascospores, Cladosporium, Mycelial Fragments, Pollen

Count, and Total Fungal Spores. Not too surprisingly, all of these except Ascospores were

frequently found (80% or more of the slides) indoors. No significant differences between

portable and traditional classrooms were found for mean Total Pollen Counts or mean Total

Fungal Spores.
III-17

Floor Dust Contaminants

Samples were collected using a hand-held vacuum dust collector (Data Vac II), in each of

the three classrooms sampled, using a specialized protocol to attain as great a consistency as

possible in sample collection. The samples were stored on ice for shipping and frozen until

analysis. The samples were sieved at two cut points, less than 500 microns for the portion sent to

California DHS for analysis of allergens, and the remainder of the dust was sieved again at less

than 150 microns for consistency with reported chemicals in house dust. Equal aliquots of the

samples collected from the portable classrooms at each school were combined for further

chemical analysis to reduce costs. Accordingly, for each school, there was one sample analyzed

to represent the portable classrooms, and there was only one sample from the traditional

classroom. Results are reported in concentration units (:g/g) and loading units (ng/cm2).

Pesticides

Results were reported for 20 pesticides. Six pesticides were detected in over 80% of the

samples: chlorpyrifos, cis- and trans-permethrin, o-phenylphenol, piperonyl butoxide, and

esfenvalerate. Diazinon, 4,4’ DDE, and propoxur were measurable in over 50% of samples.

Dieldrin, pendamethalin, propetamphos, bifenthrin, cyhalothrin, cypermethrin, and delta/tralomethrin were detected in 10-50% of the samples. Four of the pesticides were only rarely

detected (<10% of samples): malathion, lindane, resmethrin, and cyfluthrin.

At the 95th percentile, nine of the pesticides were measured at concentrations above 1.0

:g/g, although several of these had few measurable samples. There were no significant

differences in the mean levels in portable and traditional classrooms.

Esfenvalerate, a commonly used insecticide, had the highest dust concentration and the

highest median loading level (0.34 ng/cm2), while many of the pesticides had median loading

levels less than 0.01 ng/cm2

. No statistically significant differences between the means for the

portable and traditional classrooms were found for either the concentration results or the loading

results.

Metals

Fifteen of the 18 elements were above the detection limit for all of the samples analyzed.

The only three that were not always above the detection limit were Selenium, Cobalt, and

Palladium.

Of the 15 elements, the median concentration in portable classrooms was greater than the

median concentration in samples from traditional classrooms for 8 of the 15 elements (arsenic,

chromium, copper, manganese, vanadium, cesium, iron and strontium). Conversely, the samples

from traditionals showed higher dust concentrations than the composite samples from the

portable classrooms for the other 7 elements, including lead. Some samples of both types had

lead levels that exceed the DHS and U.S. EPA acceptable floor dust levels for protection of

children’s health. 
III-18

When the floor dust metals results are considered in terms of dust loading, all the

elements show higher loadings in the samples from portable classrooms, except copper.

However, none of these differences were statistically significant at the 0.10 level of significance.

Lead, arsenic and chromium concentration results (:g/g) and loading results (ng/cm2 ) for

the median and 95th percentile are shown below in Table PES-9. The table illustrates that there

are not clear patterns across the elements, and probably reflects the close proximity of sources.

For example, since the portable classrooms are generally newer, the lower concentration of lead

may reflect the number of years of particle accumulation in the traditional classroom. Arsenic,

on the other hand, may indicate the closer proximity of portables to the school grounds, where

there may be treated wood, or they may have treated foundations.

Table PES-9. Concentration and Loading Results for Selected Elements

Concentrations (:g/g) Loadings (ng/cm2 Element )

Median 95th Percentile Median 95th Percentile

All 85.4 All 189.5 All 6.5 All 58.4

Port 67.4 Port 151.6 Port 5.8 Port 57.9

Lead

Trad 95.45 Trad 200.6 Trad 7.1 Trad 57.5

All 11.6 All 17.3 All 1.3 All 5.5

Port 12.7 Port 18.6 Port 1.6 Port 5.5

Arsenic

Trad 10.9 Trad 15.3 Trad 1.1 Trad 3.4

All 36.6 All 72.8 All 3.4 All 17.8

Port 35.8 Port 54.1 Port 3.9 Port 23.9

Chromium

Trad 37.0 Trad 74.0 Trad 3.2 Trad 12.6

Allergens

Dog and cat dander allergens (Can f1 and Fel d1) were detected in 56% and 74% of the

samples, respectively, while the two dust mite allergens and cockroach allergen were detected

less than 10% of the time. The Can f1 was measured on average about double the Fel

d1concentrations measured (0.43 versus 0.26). The traditional classrooms had higher estimated

concentrations for each species than the portables, but the differences were not statistically

significant.

Polynuclear Aeromatic Hydrocarbons (PAHs)

Most of the 16 PAHs were detected in over 80% of the samples, but the loadings were

generally very low. Only 5 of the PAHs had measured concentrations above 1.0 :g/g; these

included chrysene, fluoranthene, pyrene, indo[1,2,3-cd]pyrene, and

perylene/benzo[b]fluoranthene.

Comparing the portable classroom concentrations with the traditional classrooms, 9 of the

PAHs were measured at higher median levels in the composite portable classroom samples,

while two of the PAHs were measured at higher median levels in the traditional classrooms
III-19

(fluorene and perylene/benzo[b]fluoranthene). Similar results can be seen using the 95th

percentile of the distribution as the statistic for comparison: 15 of the 16 PAHs were higher in

the portable classrooms. (Naphthalene was measured at equal levels in both types of

classrooms.)

Factors Affecting Indoor Environmental Quality

Although time and funding did not permit an extensive modeling effort, results from

simplified ANOVA and ANACOVA models explored under this the contract resulted in the

following key findings. (The modeling efforts did not include dust results.)

• Factors Affecting Indoor-Air CO2 Concentrations. Based on modeling results, the indoor

CO2 levels were estimated to be approximately 30% lower when the teachers reported that

the indoor air quality was acceptable. Models also showed a significant effect of school type,

with high schools having the highest indoor CO2 levels (and thus indicating the greatest

likelihood of ventilation insufficiency).

• Factors Affecting Noise Associated with HVACs. Classroom age had a positive effect (older

rooms had higher noise levels), and the portable classrooms had significantly higher noise

levels than the traditional classrooms. This model only accounted for only about 11% of the

total variation in the noise level, however.

• Factors Affecting Indoor Temperatures. Two temperature measures were modeled: percent

of time that the room was below 20 ̊C (too cool) and percent of time that the room was above

23 ̊C (too warm). Portables and traditional classrooms were significantly different for the

percent of time that the room was below 20 ̊C. The percent of time that the portables had

less than 20 ̊C temperatures was larger (by about 10%) than for the traditional classrooms.

• Factors Affecting Indoor-Air Aldehyde Concentrations. Various models were fit for log

(Formaldehyde Concentration), log (Acetaldehyde Concentration), and log (o,pTolualdehyde Concentration). The preferred models for the three species were quite

different. For formaldehyde, the type of classroom was generally statistically significant,

with portables having higher levels. Acetaldehyde showed no significant differences for

portable and traditional classrooms, while tolualdehyde models included significant outdoor

air by room-type interactions. On the other hand, they both showed significant associations

with their outdoor levels, while the formaldehyde models generally did not show a

relationship with the outdoor levels. When adjustments for some other indoor variables were

made – namely the CO2 and temperature variables – there was a significant relation with

outdoor formaldehyde levels. These two models accounted for 22% and 32%, respectively,

of the total variation in the indoor levels. The model including “pressed wood bookcases” as

a predictor, which also included a significant classroom age variable (positive slope),

accounted for only about 14% of the total variation in the indoor formaldehyde levels;

however, this model implied about a 30% increase in formaldehyde levels when pressed

wood bookcases were present, and about 30% higher concentrations for portable classrooms.

The model for acetaldehyde that included “pressed wood bookcases” as a predictor

accounted for about 24% of the total variation in the indoor levels of that analyte, and
III-20

indicated a significant increase in the indoor levels when pressed wood bookcases were

present.

• Factors Affecting Indoor-Air VOC Concentrations. Models were fit for five VOCs (log-scale

concentrations) using various candidate predictors. There were significant associations with

outdoor levels in virtually all of the VOCs, except for benzene, and these associations

appeared somewhat stronger than for the aldehydes. For toluene, significantly lower levels

were estimated when new construction/repair activities were on-going (which may reflect the

fact that doors and windows might be more frequently closed when those activities were

outside of the immediate classroom). The variables in this model accounted for 69% of the

total variation in indoor toluene levels.

• Factors Affecting Indoor-Air Pollen and Spores. A number of different models were fit for

log (Pollen Count) and log (Total Fungal Spores). There was a statistically significant

association between indoor and outdoor levels – with higher outdoor levels being associated

with higher indoor levels. The tests for significance for the candidate predictors revealed that

only one predictor exhibited statistical significance – namely “windows open,” which

indicated that classrooms with “windows open today” tended to have lower pollen counts.

This may be due to days with high pollen levels coinciding with those having high wind

speeds, allergic reactions among teachers, or other factors that would result in window

closing.

• Factors Affecting Indoor-Air Particle Counts. Models were fit for log (average number of

particles/minute < 2.5 μm) and log (average number of particles/minute ≤ 10 μm). Among

several potential predictors considered, the only predictor showing significance was (for the

2.5 μm case) the presence of carpet/rugs (rooms with carpet/rugs had lower levels). For that

model, traditional classrooms exhibited lower particle counts than portable classrooms.

Conclusions

Phase I and Phase II were successful in providing extensive questionnaire and

measurement data that constitute a wealth of information about environmental conditions in

California classrooms. The stratified random sampling approach, the response rates, and

assignment of appropriate weights to the data, combined with the many types of data collected,

allow one to ascertain important conclusions regarding the conditions and characteristics of

portable classrooms in California.

The target population of schools, an estimated 6,924 schools, is comprised of mostly

suburban schools (73.8%) and mostly elementary schools (59.3%). Facility managers reported

that only about 29% of the schools were less than 30 years old, that the majority (54.4%) of the

schools have 10 or fewer portable classrooms, and that over half (52.1%) of them received some

type of environmentally related complaint within the year. Very similar results were obtained in

the Phase II study.

The estimated number of K-12 classrooms in California in the 2000-2001 school year

was about 268,000, of which about 80,000 were portable classrooms. The target population of
III-21

classrooms in Phase II is estimated to be 230,000 classrooms, 37% of which are portable

classrooms. Portable classrooms were more prevalent for elementary schools than for middle or

high schools. Most (90.4%) of the portable classrooms were devoted to general instruction, as

compared to 75.1% of the traditional classrooms. Classroom age was not known for many

classrooms; however, there is a dramatic difference in the estimated age distributions for portable

and traditional classrooms. For instance, 55.3% of the portables are 10 years old or less whereas

only 12.4% of the traditional classrooms are that new. This disparity is undoubtedly partly

responsible for many other concomitant differences—e.g., differences in structural

characteristics, HVAC characteristics, and types of environmental problems/complaints. As

compared to traditional classrooms, for instance, portables tend to have more carpet, more

tackable wallboard, more pressed wood bookcases, more exterior doors, more opening of

windows, and more air conditioning (and thermostat control). Again, results were about the

same for Phase II.

Most types of environmental complaints (roof leaks, air quality/odor, mold,

temperature, noise) were reported more often for portable classrooms; an exception was

plumbing leaks, which were more common in traditional classrooms. Pest related problems

seemed to be about the same in portable and traditional classrooms.

The methods and materials used in the study were generally successful. The

formaldehyde monitoring data in Phase I are of acceptable quality in terms of completeness,

relative precision, and sensitivity, with 97% of the measurements above the LOD. The mean

concentration for portable classrooms in Phase I was 32 ppb (median 27 ppb), compared to 24

ppb for traditional classrooms (median 20 ppb). Statistically significant associations were found

for geographic region, season, overall air quality rating by the teacher, presence of new carpet

and new flooring, presence of new furnishing odors, and nasal symptoms of the teacher.

Among all the ANOVA models in Phase I, the room type variable, adjusted for the

other variable appearing in the model, was always highly significant except for the models

involving classroom age. For these models the effect of room type, after adjustment, was nonsignificant, suggesting that at least part of the overall difference between the room types was due

to the disparity in their age distributions and differences associated with age.

Phase II provided measurement and observational information in greater detail than was

obtained from Phase I. The data base provides a robust basis for statistical inferences regarding

the population of schools with portable classrooms because response rates and data completeness

were quite good for most analytes and questionnaire items. The exceptions were relatively poor

data completeness for HOBO data regarding on/off cycles of HVAC units, CO data, and outdoor

relative humidity data.

Quality control: Analysis of field blank samples, control samples, and duplicate

samples revealed that analyte recovery and precision were reasonably good for most analytes.

Hence, the quality control samples verified that the environmental measurement and laboratory

data quality were satisfactory.
III-22

With respect to the HVAC characteristics, there were a number of significant

differences between portable and traditional classrooms. Those related to structure include:

physical location of unit (portables more wall units), type of fuel (electricity), type of unit (heat

pump), and accessibility (better for portables). For those characteristics with potential impact on

environmental quality, air filter dirt loading was lower in portables, and portables generally had

more tightly fitting filters. HVAC filters in portable classrooms showed a higher percentage of

mildew or mold, dirtier condensate drain pans, clogged drains, and standing water. Also,

teachers were more likely to turn off the HVAC system due to high noise levels in portable

classrooms. The air flow measurements in traditional and portable classrooms were not

significantly different at the 5% level; however, outdoor air flow (cfm/ft2) was significantly

higher for portable classrooms at the 10% level.

The mean light intensity measured in the traditional classrooms was significantly higher

than that measured in the portable classrooms. However, a small percentage of both portable and

traditional classrooms did not meet IESNA light guidelines for high-contrast materials, and

approximately one-third of both portables and traditionals did not meet the IESNA light

guidelines for low-contrast materials, indicating inadequate lighting in both types of classrooms.

All classrooms exceeded the new ANSI acoustic standard for classroom noise levels (35

dBA), and a substantial percentage of both portable and traditional classrooms exceeded outdoor

noise limits (45 and 55 dBA) set by some California communities. Noise levels measured in

both types of classrooms were not statistically different. However, the teachers in portable

classrooms were more likely to turn off the HVAC unit due to noise. This noise effect in

portable classrooms was supported in the statistical modeling.

Temperature levels were significantly different, with some portable classrooms

experiencing levels much cooler than ASHRAE comfort standards and some traditional

classrooms experiencing levels notably warmer than ASHRAE comfort standards. Portables also

had relative humidity measurements above 60% more of the time than traditional classrooms;

such levels are not only uncomfortable, but can lead to increased moisture and mold problems,

increased dust mite populations (allergy and asthma triggers), and other problems.

Assessment of contaminant levels in classroom air and floor dust revealed the general

findings shown in Table PES-10.

Indoor formaldehyde air concentrations in Phase II were lower than those in Phase I;

this was largely due to the many differences in procedures and timing of the two data collections.

However, indoor levels are routinely higher than outdoor levels, and average formaldehyde

levels are likely to fall between the Phase I and Phase II measurements. Thus, most classrooms

exceed health guidelines for chronic effects, and a substantial percentage exceed guidelines

designed to address acute effects. Other aldehydes and VOCs have not yet been examined

relative to health-based guidelines, but indoor levels generally exceeded outdoor levels (similar

to results in other studies), indicating the presence of indoor sources that may need to be

addressed.
III-23

Table PES-10. Overall Results of Contaminant and CO2 Levels in Air and Floor Dust

Summary Statistics and Comparisons

of Pollutant Levels

Modeling Results -- For Selected

Species and Selected Predictors

Pollutant

Type

Indoor

Levels

Vs.

Outdoor

Levels

Exceeds

health- or

comfortbased

guideline/

standard

Portable

Classroom

Mean Vs.

Traditional

Classroom

Mean Test

Portable

Classroom

Vs.

Traditional

Classroom

Test

Indoor Levels

Related to

Outdoor

Levels

Other Significant

Predictors

CO2 (air) Indoor

higher

Yes

indicates

inadequate

ventilation

in many

classrooms

About the

same

Depends on

outdoor level

(some models)

Yes (when

applicable),

depends on

room type

Classroom age, and

school type and teacher

rating of indoor air

quality (when

classroom age included)

Particle Counts

(air)

Outdoor

higher

NA About the

same

About the

same (most

models)

NA Presence of carpets/rugs

Microbiologicals

(air)

Outdoor

generally

higher

NA About the

same

About the

same

Yes Open windows

Formaldehyde (air) Indoors

much

higher

Yes,

OEHHA

draft

Indoor

REL,

apparent

cancer risk

Portables

higher

Portables

higher (most

models)

Generally not Classroom age, school

type, general instruction

classroom, others

related to materials in

room, indoor CO2

levels, indoor RH

o,p-Tolualdehyde

(low %

measureable)

Indoor

higher

Not yet

reviewed

Portables

higher

Depends on

outdoor level

Yes General instruction

classroom, materials in

room, school type

Other aldehydes

(air)

Indoor

generally

higher

Not yet

reviewed

About the

same

About the

same

(acetaldehyde)

Yes

(acetaldehyde)

General instruction

classroom, indoor RH

(acetaldehyde)

VOCs (air) Indoor

higher

Not yet

reviewed

About the

same

About the

same, some

depend on

outdoor level

Yes, some

depend on room

type

Only a few, varies by

analyte

Pesticides (dust) NA Many

detected

About the

same

NA** NA NA

Metals (dust) * Acceptable

lead floor

dust levels

exceeded

Arsenic

higher in P;

Lead higher

in T.

NA** NA NA

PAHs (dust) NA Many

detected

Portables

somewhat

higher

NA** NA NA

Allergens (dust) NA Cat and

dog dander

in most

Traditionals

slightly

higher

NA** NA NA

* Outdoor soil samples were collected and analyzed for metals under funding from the California Office of Environmental

Health Hazard Assessment. Those results will be incorporated as an addendum to this report.

** Modeling has not yet been conducted for dust analytes, but may be pursued under separate funding.
III-24

Airborne pollens and spores (primarily fungi) were found at higher levels outdoors than

indoors, as expected. Typically indoor levels of fungi are elevated primarily in cases of extreme

mold or biological contamination. However, classroom wall, floor, and ceiling moisture

measurements indicated excess moisture in building materials in about 17% of the classrooms,

indicating potential mold problems in those locations. Traditional classrooms had excess wall,

floor, and ceiling moisture more often than portables, but portables were reported to experience

roof leaks more often, and over two-thirds of the teachers in portables reported musty odors at

times. 

Pesticide residues were found in all floor dust samples, indicating the widespread use of

a variety of different products in or near classrooms. Six pesticides were detected in over 80% of

the rooms, with esfenvalerate (a common insecticide) showing the highest concentration and

loading levels. Some of the pesticides are persistent chemicals, lasting for years, while other

have an environmental lifetime lasting just weeks; thus, some of the pesticides were likely

applied just a week or two prior to the sampling period at some schools in 2001-2002.

Similarly, 15 of the 18 metals analyzed for were detected in the floor dust samples.

Some, such as arsenic, were detected at higher levels in portables, while others, like lead, were

higher in traditional classrooms. Some lead dust levels exceed acceptable levels for floor and

window sill dust established by DHS and U.S. EPA to protect children’s health. Some of the

metals are known to have neurological or carcinogenic effects. Most of the 16 PAHs studied

(some of which are also known or suspected carcinogens) also were found in over 80% of the

classrooms, but the loading levels were low. Most were found at higher levels in the portable

classrooms.

Some contaminants in dust, such as pesticides, can be ingested or absorbed through the

skin, as well as inhaled, making them undesirable in the floor dust of classrooms, especially

those used for younger children who spend more time on the floor.

Dog and cat allergens were found commonly in floor dust. Dust mite allergens and

cockroach allergens were found much less often.

The Phase II study was successful in generating a massive amount of information about

California schools and classrooms. Although the data summaries and analyses described in this

report are quite extensive, they clearly represent only a small fraction of the analyses that could

be undertaken to address environmental quality issues and related concerns.

Conclusions: From the above discussions of significant results, it is clear that there are

differences in environmental factors between portable and traditional classrooms. Most

importantly, some of both types of classrooms exceeded many of the environmental standards

and guidelines available for judging the state of the environmental conditions in classrooms.

Further analyses of this very rich data base will likely reveal other factors that could prove useful

for further identifying sources and measures to be taken to reduce their potential effects.
III-25

REFERENCES

ANSI/ASA (American National Standards Institute, Acoustics Society of America), 2002.

Standard S12.60-2002.

ARB (2001). Annual Statewide Toxics Summary, 1989-2000, Means and Maximums of

Monthly Means of 24-Hour Measurements.

http://www.arb.ca.gov/aqd/toxics/statepages/hchostate.html.

ASHRAE (American Society of Heating, Refrigerating and Air-Conditioning Engineers),

Standard 55-1981. See http://www.ashrae.org.

Bell, J., 2001. Poverty Data, October 2000. California Department of Education, CalWORKS

California Work Opportunity and Responsibility to Kids, Free and Reduced Price

Meals/CalWORKS – School Level Files. Personal communication, April 27.

http://www.cde.ca.gov/demographics/files/afdc.htm.

Broadwin R. (2000). Development of and Uses of Health-based Exposure Levels for Indoor Air

Contaminants. California Office of Environmental Health Hazard Assessment, Air Toxics and

Epidemiology Section, Oakland, CA. Presented at 10th Annual Conference of the International

Society of Exposure Analysis, October 24-27, Asilomar, CA. Abstract #5A-15p.

City of Davis, 2003. Municipal Code, Sec. 24.02.020, daytime residential noise standard.

City of Sacramento, 2003. Ordinance 8.68.060, daytime exterior noise standard.

City of Los Angeles, 2003. Ordinance Ch. XI, Art.1, Sec. 111.03, daytime exterior noise

standard.

Edwards, S., 2001. California Department of Education, Ed-Data, Cost per ADA, 1999-2000, as

of May 7, 2001. Personal communication, August 7. http://www.ed-data.k12.ca.us/.

Godish, 1989. Indoor Air Pollution Control. CRC Press, Boca Raton.

IESNA (Illuminating Engineering Society of North America), 2000. IESNA Lighting

Handbook. 9th Edition. New York, NY. Educational Facility Lighting 12-1. As cited in

California High Performance Schools (CHPS). CHPS Best Practices Manual, Electrical

Lighting: Volume IIA, p. 150. Eley Associates, 2001. http://www.chps.net.

Kelly, T.J., Smith, D.L., and J. Satola, 1999. “Emission Rates of Formaldehyde from Materials

and Consumer Products Found in California Homes.” Environ. Sci. Technol. 33(1):81-89.

Liu, K-S., Huang, F-Y., Hayward, S.B., Wesolowski, J.J. and Sexton, K., 1991. “Irritant Effects

of Formaldehyde Exposure in Mobile Homes,” Environ. Health Perspec. 94:91-94.
III-26

National Research Council, 1981. Indoor Pollutants. National Academy Press, Washington,

DC. http://www.nap.edu/catalog/1711.html.

OEHHA (2002). Proposition 65 Status Report: No Significant Risk Levels for Carcinogens and

Maximum Allowable Dose Levels for Chemicals Causing Reproductive Toxicity, March.

http://www.oehha.ca.gov/prop65/pdf/Mar2002StatusReport.pdf.

OEHHA (2001). All Chronic Reference Exposure Levels Adopted by OEHHA as of December

2001: Chronic Toxicity Summary, Formaldehyde. Office of Environmental Health Hazard

Assessment, Air Toxicology and Epidemiology Section, Oakland, CA.

http://www.oehha.ca.gov/air/chronic_rels/pdf/50000.pdf.

Sexton, K., Petreas, M.X. and Liu, K-S., 1989. “Formaldehyde Exposures Inside Mobile

Homes,” Env. Sci. & Tech. 23(8): 985-988.

WHO (World Health Organization), 1999. Guidelines for Community Noise. Berglund, B.,

Lindvall, T., and Schwela, D. (ed.). http://www.who.int/peh/noise/guidelines2.html.
Environmental Health Conditions in California’s Portable Classrooms

IV - I

APPENDIX IV

RECOMMENDATIONS TO SCHOOLS

FOR REDUCING FORMALDEHYDE
Environmental Health Conditions in California’s Portable Classrooms

IV-2

REMEDIES FOR REDUCING FORMALDEHYDE IN SCHOOLS

Recommendations of the

California Air Resources Board

and Department of Health Services

March 2002

When a classroom has been measured with elevated formaldehyde levels (more than

27 parts per billion--ppb), we recommend that the school implement the basic measures

listed below. Classrooms with formaldehyde levels below 27 ppb would benefit from

these measures as well, because formaldehyde is a carcinogen, and it is desirable to

achieve the lowest formaldehyde levels reasonably feasible. However, achieving very

low indoor levels (below 5 -10 ppb) generally is not possible. Outdoor levels average

about 3 ppb, but can range up to 20 ppb in some areas, such as near traffic.

1. Reduce the total amount of formaldehyde sources in the classroom.

Removing sources is often the most effective way to assure that formaldehyde

concentrations are reduced in classroom air. The primary indoor sources are typically

pressed wood building materials and furnishings; consumer products and combustion

sources can also contribute to indoor levels.

• Newer, removable sources such as new, freestanding bookshelves and desks

made with pressed wood products (e.g., particleboard) should be aired out in a

different, well-ventilated location for as long as conveniently possible, preferably at

least two to three weeks. This process will not remove all of the formaldehyde, but it

can accelerate the initial off-gassing of formaldehyde, and keep the highest

emissions out of the classroom.

• Avoid using noxious consumer products in the classroom. Cleaning products,

carpet shampoos, surface cleaners, glass cleaners, markers, and cosmetics such as

fingernail polish can emit formaldehyde as well as other undesirable chemicals. If

some of these products must be used, make sure the ventilation is turned on and

run at proper levels.

• Assure that all combustion appliances are exhausted directly to the outdoors.

Combustion appliances such as gas heaters and ovens produce formaldehyde.

They should be checked annually by a professional to assure proper functioning.

2. Provide sufficient ventilation to the classroom.

• Check the outdoor air flow rate and controls. An inspection should be conducted

to assure that the heating and air conditioning (HVAC) unit is drawing 15 to 20 cubic

feet per minute per person of outdoor air into the room. Keep motor vehicles and

combustion engines away from the air intakes.
IV-3

• To be effective, the HVAC system must be used (turned on). Verify that the

HVAC fan is continuously operating whenever the classroom is being used. If HVAC

noise is a problem, consider installing a rubber gasket between the air handler and

building shell. Consult with the manufacturer for assistance with noise attenuation.

• Keep doors and windows open as much as possible. Additional ventilation can

be provided by operating oscillating fans inside the classroom (or in a window) while

doors and windows are open. Fleecy materials such as carpet, upholstery, and wall

surfaces will adsorb formaldehyde that is in the air and re-emit it as environmental

conditions change. Additional ventilation and air circulation will help accelerate the

removal of formaldehyde from these surfaces and from the room.

• Assure that the classroom is maintained at 30% to 50% relative humidity and a

comfortable temperature. Formaldehyde emissions generally increase with higher

temperatures and higher humidity.

3. Testing the Air

The following information may be helpful to schools that wish to obtain a follow-up

measurement in classrooms after taking steps to reduce formaldehyde levels:

• Be sure to hire a qualified consultant or obtain the services of a trained industrial

hygienist from the district or a local government agency to conduct the testing.

Private consultants may charge about $1000 - $1500 to test several classrooms for

one day. Advice on hiring an indoor air quality consultant and lists to help locate

consultants can be found on-line at http://www.cal-iaq.org/FIRMS/.

• Use an accepted test method. An active DNPH (dinitrophenylhydrazine) sampler

is the preferred method, although other methods may be adequate.

• Obtain measurements during school hours with the ventilation system in

normal operating mode. This will provide a good estimate of the levels the

occupants are actually exposed to in their classrooms. Ideally, a 6-8 hour test is

desired, to cover the hours the rooms are occupied.

If Levels Are Still Higher Than Desired

If test results show that formaldehyde concentrations remain elevated after the

measures above have been taken, then some additional action may be necessary.

Sealing all exposed surfaces of particleboard furnishings with multiple layers of water

resistant sealants--such as polyurethane, vinyl laminate, lacquers, alkyd paints or other

water-resistant coatings--can reduce formaldehyde emissions. The effectiveness of

these sealants varies greatly by product, thickness of the layer applied, and the

thoroughness of application. It is advisable to seal all surfaces, including the back and

edges of the board, and use multiple layers of coatings. Sealants themselves may

release other chemicals for a period of time, so application and initial off-gassing during
IV-4

drying must be conducted under high ventilation conditions and/or at an alternate

location.

For newer classrooms that show especially high formaldehyde levels even after the

measures above have been taken, schools may also want to consider measures such

as extensive airing out of the building or sealing of surfaces over the summer.

Future Purchases

When new classrooms or furnishings are ordered or constructed, materials can be

specified that emit low or no formaldehyde and other volatile chemicals. Schools may

also want to request that any furnishings that might emit chemicals be aired out prior to

installation. Airing of carpet for several days at an alternate location, such as at a

warehouse, can greatly reduce the chemical levels in the classrooms after installation of

the carpet. Specification language for low formaldehyde elements was developed by

the Collaborative for High Performance Schools (CHPS) and can be found at the

website below.

For More Information

For more information on formaldehyde, visit:

http://www.arb.ca.gov/toxics/compwood/background.htm

http://www.arb.ca.gov/research/indoor/formald.htm and

http://www.arb.ca.gov/research/resnotes/notes/97-9.htm.

For information on designing, constructing, and maintaining healthier school buildings,

visit:

CHPS: http://www.chps.net/.

Advisory on Relocatable and Renovated Classrooms

http://www.cal-iaq.org/ADVISORY.pdf

IAQ Tools for Schools, U.S. Environmental Protection Agency

http://www.epa.gov/iaq/schools/index.html
Environmental Health Conditions in California’s Portable Classrooms

V - I

APPENDIX V

LAUSD CHECKLIST
Safe School Inspection Guidebook

LOS ANGELES UNIFIED SCHOOL DISTRICT

OFFICE OF ENVIRONMENTAL HEALTH AND SAFETY

Preliminary Revision: August 27, 2004
Safe School Inspection Guidebook

Preliminary Revision 08/27/04

SAFE SCHOOL INSPECTION GUIDEBOOK

TABLE OF CONTENTS

SECTION PAGE

INTRODUCTION .......................................................................................................................................... 1

ASBESTOS MANAGEMENT.......................................................................................................................... 2

CAMPUS SECURITY.................................................................................................................................... 4

CHEMICAL SAFETY.................................................................................................................................... 5

EMERGENCY PREPAREDNESS ..................................................................................................................... 9

FACILITIES AND EQUIPMENT MAINTENANCE........................................................................................... 10

FIRE/LIFE SAFETY.................................................................................................................................... 16

INDOOR ENVIRONMENT ........................................................................................................................... 20

INJURY AND ILLNESS PREVENTION .......................................................................................................... 22

LEAD MANAGEMENT............................................................................................................................... 27

MISCELLANEOUS ..................................................................................................................................... 28

OFF-SITE RISKS........................................................................................................................................ 29

TRAFFIC AND PEDESTRIAN SAFETY ......................................................................................................... 33

VIOLENCE PREVENTION........................................................................................................................... 34

INDEX ...................................................................................................................................................... 36
Safe School Inspection Guidebook

Preliminary Revision 08/27/04

INTRODUCTION

OEHS SAFE SCHOOL INSPECTION PROGRAM

The education of our children requires a learning environment which is safe and health-protective. 

Maintaining a safe learning environment requires the commitment and active participation of school 

administrators, plant managers, central support staff, and an informed school community. The Safe 

School Inspection Program was established to provide comprehensive routine assessment of safety 

conditions in all Los Angeles Unified School District schools.

SAFE SCHOOL INSPECTION PROCESS

The Safe School Inspection process begins with a meeting between the OEHS safety officer and the site 

administrator. The meeting is followed by a brief walk-through of the school with the site administrator 

or plant manager. The safety officer then conducts a detailed inspection in accordance with the regulatory 

standards referenced in this Guidebook. The inspection concludes with a meeting between the safety 

officer and the site administrator to review the inspection findings and discuss any other safety concerns.

OBJECTIVE OF THE GUIDEBOOK

This Guidebook covers 14 safety areas and defines the mandatory health and safety standards applicable 

to schools. Although the Guidebook was designed primarily for OEHS use, it is also a useful tool for 

school administrators, plant managers, and other members of the school community. For copies of the 

Safe School Inspection Guidebook, please refer to the OEHS web site: www.lausd-oehs.org.
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 2

ASBESTOS MANAGEMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Asbestos Management Plan Availability Ensure that an Asbestos Management Plan (AMP) is available to employees, 

parents and others pursuant to 40 CFR.

HSC § 25915; 

40 CFR § 763.93

Current Confer with Asbestos Technical Unit (ATU) to ensure that the Asbestos 

Management Plan is current and identifies the location of all Asbestos 

Containing Material (ACM).

HSC § 25915; 

40 CFR § 763.93

3-Year Survey Ensure a 3 Year Asbestos Survey is conducted by the Asbestos Technical Unit 

(ATU) and results are included in the school Asbestos Management Plan

(AMP). For assistance, contact ATU at (213) 763-1450.

HSC § 25915; 

40 CFR § 763.85

6-Month Surveillance Ensure a 6 Month Visual Surveillance is conducted by the Asbestos Technical 

Unit (ATU) and results are included in the school Asbestos Management Plan

(AMP). For assistance, contact ATU at (213) 763-1450. 

HSC § 25915; 

40 CFR § 763.85

Maintenance of Asbestos 

Containing Material (ACM)

Condition Maintain all floors and other surfaces constructed of Asbestos Containing 

Material (ACM) in good condition to prevent deterioration.

8 CCR § 5208

Floor Buffing Do not burnish or dry buff floors that may contain asbestos unless there is a

sufficient finish to ensure the pad does not contact Asbestos Containing 

Material.

8 CCR § 5208

Sanding Do not sand flooring materials or other surfaces that may contain asbestos. 

Use wet methods and low-abrasion pads at speeds lower than 300 rpm to 

remove floor finish.

8 CCR § 5208

Non-Qualified Personnel Prohibit the handling of Asbestos Containing Material by non-qualified 

personnel.

HSC § 25915; 

40 CFR § 763.93

Restricted Access Restrict access to areas identified with damaged and friable Asbestos 

Containing Material (ACM) or areas undergoing abatement activities.

8 CCR § 5208
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 3

ASBESTOS MANAGEMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Training Provide 2-hour Asbestos Awareness training to custodial and maintenance

staff. Training should be provided within 60 days of employment.

8 CCR § 5208;

40 CFR § 763.92

Warning Signs Post warning signs on the entrance to boiler rooms, fan rooms and other

maintenance areas that contain Asbestos Containing Material (ACM). 

Warning signs must be clear, conspicuous and state:

“Asbestos Containing Material (ACM) has been identiried in this room. See 

Asbestos Management Plan Book for specific type, location, and work 

practices to be followed.”

HSC § 25915; 

40 CFR § 763.95

Warning Labels Attach warning labels on or immediately adjacent to known or suspected 

Asbestos Containing Material (ACM) in boiler rooms, fan rooms and other 

maintenance areas. Warning labels must be clear, conspicuous and state:

"DANGER: ASBESTOS. Cancer and lung disease hazard. Do not disturb 

without proper training and equipment."

HSC § 25915; 

40 CFR § 763.95
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 4

CAMPUS SECURITY

Type Subtype Corrective Action for Identified Deficiency Reference

Visitation Policy Visitor’s Pass Ensure visitors entering school grounds sign-in and receive a visitor’s pass. OEHS Model Safe School 

Plan Volume 1 – Prevention 

Programs; Bulletin N-2; 

California State 

Constitution, Article I, 

Section 28

Posting Ensure school visitation policy is posted and distributed annually to parents 

and staff.

OEHS Model Safe School 

Plan Volume 1 – Prevention 

Programs; Bulletin N-2

Locked Campus Lock all fences and gates at the beginning of classes each morning and keep 

them locked until the end of the school day, pursuant to Bulletin 33.

OEHS Model Safe School 

Plan Volume 1 – Prevention 

Programs; Bulletin 33

Parking Do not permit parking of vehicles on District property without approval of 

Site Administrator. 

Restricted Areas Prevent access to crawl spaces, roof access, or other passageways not

intended for use by students or unauthorized staff.

8CCR 1541

Supervision Ensure the school has a campus supervision plan clearly delineating the times 

and areas of the campus that require specific supervision such as during 

scheduled activities and bus loading areas. 

Bulletin Z-10, Bulletin Z-36, 

Bulletin DP-1, Bulletin L-4, 

Bulletin L-5, Bulletin 61, 

Bulletin Z-19, Memorandum 

L-2, Memorandum Z-6

Vandalism Reporting Ensure all acts of vandalism are reported to School Police, OEHS and 

Maintenance, including graffiti, property damage, etc.

Facilities Inspection Checklist
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 5

CHEMICAL SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Hazard Commu nication Program Implement a Hazard Communication Program pursuant to Cal/OSHA

requirements. To obtain a copy of the District’s Hazard Communication 

Program, contact OEHS at (213) 241-3199.

8 CCR § 5194;

29 CFR § 1910.1200

Inventory Maintain School Chemical Inventory pursuant to Hazard Communication 

Program.

8CCR 5191

MSDS Maintain current Material Safety Data Sheets (MSDSs) for each hazardous 

substance used on site. 

8 CCR § 5194;

29 CFR § 1910.1200

Labels Label each hazardous substance container indicating identity of the contents 

and appropriate hazard warnings..

8 CCR § 5194;

29 CFR § 1910.1200

Training Provide employees with annual Hazard Communication training on hazardous 

chemicals used in their respective work areas. Employees should be retrained 

when new hazards are introduced into the work place.

8 CCR § 5194;

29 CFR § 1910.1200

Chemical Hygiene Plan Develop a written Chemical Hygiene & Safety Plan and ensure it is readily 

available to all employees. The plan should identify a "coordinator" and be 

revised at least annually.

8 CCR § 5191;

29 CFR 1910.1450;

Chemical Hygiene & Safety 

Plan

Training Provide and document annual Chemical Hygiene training to science staff. 8 CCR § 5191;

29 CFR 1910.1450;

Chemical Hygiene & Safety 

Plan

Chemical Handling & Storage 

– General Requirements

Use of Prohibited Chemicals Do not use chemicals unless approved for District use by OEHS. Refer to 

OEHS website at www.lausd-oehs.org (see OEHS Product Review). Contact 

OEHS at (213) 241-3199 for assistance or to arrange for chemical pickup and 

disposal services.

8 CCR § 5194; 8 CCR § 

5228; 29 CFR 1910.1450;

Student Access Ensure that all hazardous chemicals are locked, secured and kept out of reach 

of students.
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 6

CHEMICAL SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Chemical Handling & Storage 

– General Requirements 

(cont.)

Incompatible Storage Store chemical materials by compatibility type as described in Material Safety 

Data Sheets (MSDSs).

8 CCR § 5533 and 19 CCR 

§ 3.15;

29 CFR § 1910.106

Food Storage Avoid storage, handling or consumption of food and beverages in chemical 

storage areas or areas used for laboratory operations.

8CCR 5191 Appendix A

Maximum Quantities Do not store on site more than 60 gallons of Class I or Class II, and/or 120 

gallons of Class III liquids on site. 

8 CCR § 5533;29 CFR § 

1910.106

Restraints Ensure all chemical storage shelves and cabinets are equipped with lips or 

other devices to prevent stored materials from falling. If necessary, place a 

trouble call to the Maintenance and Operations trouble-call desk at (213) 745-

1600.

Chemical Hygiene & Safety 

Plan

Spill Kit Ensure that all chemical storage areas are provided with a spill kit containing 

absorbent, neutralizing chemicals and other spill-control materials.

8 CCR § 5191

Flammable and Combustibl e 

Materials

Grounding & Bonding Ensure that all containers dispensing flammable materials are bonded and 

grounded.

LA Fire Code § 57.30.64;

29 CFR § 1910.106

Storage Cabinets Ensure the storage of flammable and combustible liquids in approved cabinets 

with self-closing doors.

8 CCR § 5417 and 19 CCR § 

3.15; 8CCR 5533

29 CFR § 1910.106(d)(3)(I);

Chemical Hygiene & Safety 

Plan Bulletin

Safety Containers Utilize approved safety containers for flammable materials and ensure proper 

labeling. 

8 CCR §§ 5531, 5532, 

5533, 5534, 5535, 5538, 

5541

Flammable Storage Labeling Ensure flammable storage bunkers, rooms and cabinets are labeled

“Flammable - Keep Fire Away”. 

Flammable Storage Room -

Location

Do not locate flammable material storage rooms in buildings occupied by 

students.

8 CCR § 5533;

29 CFR § 1910.106
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

7

CHEMICAL SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Flammable and Combustible 

Materials (cont.)

Flammable Storage Room -

Aisle Spacing

Ensure aisles are at least 3 feet apart in flammable storage rooms to provide for 

emergency egress.

8 CCR § 5533;

29 CFR § 1910.106

Ventilation Ensure exhaust ventilation system in flammable material storage rooms

provide 6 air exchanges per hour, and that the control switch is located outside 

the room.

8 CCR § 5533;

29 CFR § 1910.106

Gas Cylinders Condition Ensure compressed gas cylinders are free of corrosion, dents, cuts, gouges, 

bulges and leaks. 

8 CCR § 4649;29 CFR § 

1910.101

Hydrostatic Test Ensure up-to-date hydrostatic test for all compressed gas cylinders. 8 CCR § 4649;

29 CFR § 1910.101

Incompatible Storage Separate compressed flammable gases and oxidizing gases by either a 1-hour 

fire wall or distance of 25 feet.

8 CCR § 5533;

29 CFR § 1910.106

Signage Post "NO SMOKING" sign, identify hazard classes, and list all gases stored in 

the compressed gas storage areas. If necessary, place a trouble call to the 

Maintenance and Operations trouble-call desk at (213) 745-1600.

8 CCR § 4649;

29 CFR §§ 1910.101, 

1910.102, 1910.103, 

1910.104

Storage Ensure compressed gas cylinders are stored upright in a well ventilated area, 

by hazard class, secured, capped and kept at least 20 feet from flammable 

liquids, oxidizers, and other sources of ignition.

8 CCR § 4649;

29 CFR §§ 1910.101, 

1910.102, 1910.103, 

1910.104

Laboratory Safety Chemical Inventory Post current Lab Chemical Inventory in chemical storage areas. 8CCR 5191

Eyewash Provide approved eyewash stations in all laboratories using chemicals. Chemical Hygiene & Safety 

Plan 

Floor Plan Post floor plan drawings of science laboratory indicating locations of waste 

disposal containers and safety equipment in a conspicuous area.

8 CCR § 5191;

29 CFR 1910.1450;

Chemical Hygiene & Safety 

Plan

Labels Label laboratory cabinets and storage areas as required in the Chemical 

Hygiene & Safety Plan.

Chemical Hygiene & Safety 

Plan 
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

8

CHEMICAL SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Laboratory Safety (cont.) Locked Cabinets Lock all laboratory chemical storage cabinets when not in use. Chemical Hygiene & Safety 

Plan 

Storage - Method Store laboratory chemicals by compatibility type as described in Appendix D 

(Tables 1 and 2) of the Chemical Hygiene & Safety Plan.

Chemical Hygiene & Safety 

Plan 

Storage- Volatiles Store all volatile laboratory chemicals in an explosion-proof cabinet. Chemical Hygiene & Safety 

Plan 

Storage Temperature Keep all laboratory chemical storage areas cool (between 55 and 80 degrees F) 

and dry (relative humidity between 30 and 60 percent).

Chemical Hygiene & Safety 

Plan 

Hazardous Waste 

Management

Aisles Maintain unobstructed aisle space in hazardous waste storage areas. 22 CCR 66264.35

Characterization Ensure the proper characterization of all waste (hazardous and non-hazardous). 22 CCR § 66262.11;

40 CFR § 262.11

Closed Containers Keep hazardous waste containers closed except when adding waste. 22 CCR § 66262.34;

40 CFR § 262.34

Container Condition Ensure all hazardous waste containers are in good condition, free of leaks and 

provided with secondary containment.

Labels Label hazardous waste containers with the words: "HAZARDOUS WASTE", 

the physical state of the waste, hazard class, accumulation date and the address 

of the generator.

22 CCR § 66262.34;

40 CFR § 262.34

Inspections Conduct daily inspections of tanks in waste accumulation areas and weekly 

inspections of containers in waste storage areas.

22 CCR § 66262.34;

40 CFR § 262.34

Disposal Dispose hazardous waste generated at schools at least every 180 days. 22 CCR § 66262.34;

40 CFR § 262.34

Storage Supplies and 

Equipment

Supply hazardous waste storage areas with spill kits, fire extinguis hers, 

communication systems and decontamination equipment.

22 CCR § 66262.34;

40 CFR § 262.34

Lab Wastes Properly dispose of all outdated, retrograde, or otherwise expired lab

chemicals. To request pickup and disposal services, contact OEHS at (213) 

241-3199 or www.lausd-oehs.org.

22 CCR § 66262.11;

40 CFR 262.11
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 9

EMERGENCY PREPAREDNESS

Type Subtype Corrective Action for Identified Deficiency Reference

Safe School Plan Prepare and annually update Safe School Plan, Volume 2 – Emergency

Procedures. 

CEC § 35294;

OEHS Model Safe School 

Plan, Volume 2 –

Emergency Procedures

Drills Conduct and document periodic Fire/Life Safety drills (at least monthly for 

primary schools or once each semester for secondary schools).

Bulletin N-25

Seismic Bracing Overhead Storage Remove all materials and objects stored on top of cabinets or upper shelves 

unless such objects are fastened to the shelf or otherwise restrained from 

falling.

Furniture Provide seismic bracing for furniture, equipment and appliances. Memorandum N8

HVAC/Water Heaters Provide seismic bracing for HVAC units and water heater tanks. If necessary, 

place a trouble call to the Maintenance and Operations trouble-call desk at 

(213) 745-1600.

Supplies and Equipment General Ensure emergency supplies include flashlights, batteries, battery powered

radio(s), first aid kits for every 400 persons, drinking water ratio 1.5 gallons 

per person, wrenches, pumps, pitchers, cups, bleach, search and rescue kit for 

every 500 persons, canned foods and personal hygiene products. For

assistance in obtaining supplies, contact OEHS at (213) 241-3199.

OEHS Model Safe School 

Plan, Volume 2 –

Emergency Procedures

Reference Guide REF-801

Reference Guide REF-802

Maintenance Ensure emergency supplies are inspected and/or refreshed on a regular basis. 

Label water drums with expiration date. Change out untreated tap water every 

6 months and disinfected water every 3 years.

OEHS Model Safe School 

Plan, Volume 2 –

Emergency Procedures

Reference Guide REF-801

Reference Guide REF-802

Storage Container Provide and maintain dedicated emergency supply storage containers. For 

assistance in obtaining containers, contact OEHS at (213) 241-3199.

OEHS Model Safe School 

Plan, Volume 2 –

Emergency Procedures

Reference Guide REF-802

Training Train all employees on emergency procedures within the first three months of 

the school year, and maintain documentation of date of training, agenda,

training materials and sign-in sheet.

CEC § 35294

Collective Bargaining 

Agreement UTLA & 

LAUSD Articles XXIV and 

XXVIII
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

10

FACILITIES AND EQUIPMENTMAINTENANCE

Type Subtype Corrective Action for Identified Deficiency Reference

Condition of Equipment and 

Facilities

General Ensure campus grounds and equipment are maintained in good repair. If 

necessary, place a trouble call to the Maintenance and Operations trouble-call

desk at (213) 745-1600.

OEHS IIPP Template, 

Attachment E

Annual Campus/

Facilities Inspection

Form

Asphalt Ensure asphalt and other paved areas are in good condition (e.g., free of

significant cracks, holes, standing water).

Annual Campuses/ 

Facilities Inspection 

Checklist

Broken Windows Ensure broken or cracked windows are reported and that broken windows are 

repaired within 72 hours. If necessary, place a trouble call to the Maintenance 

and Operations trouble-call desk at (213) 745-1600.

OEHS IIPP Template, 

Attachment E

Annual Campus/

Facilities Inspection

Checklist

Carpeting Ensure carpeting is clean and in good condition. OEHS IIPP Template, 

Attachment E

Annual Campus/

Facilities Inspection

Checklist

Fences and Gates Ensure fences and gates are maintained in good repair. If necessary, place a 

trouble call to the Maintenance and Operations trouble-call desk at (213) 745-

1600.

OEHS IIPP Template, 

Attachment E

Annual Campuses/ 

Facilities Inspection 

Checklist

Ground Striping Ensure ground striping and parking lines are clearly visible. OEHS IIPP Template, 

Attachment E

Annual Campuses/ 

Facilities Inspection 

Checklist
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

11

FACILITIES AND EQUIPMENTMAINTENANCE

Type Subtype Corrective Action for Identified Deficiency Reference

Condition of Equipment and 

Facilities (cont.)

Housekeeping Ensure all areas in the school are clean, well maintained and free of clutter. OEHS IIPP Template, 

Attachment E

Annual Campus/

Facilities Inspection

Checklist

Landscaping Ensure tree canopies are adequately raised, plants adequately trimmed and 

landscape is free of tripping hazards and other obvious hazards.

OEHS IIPP Template, 

Attachment E

Annual Campus/

Facilities Inspection

Checklist

Roof and Gu tters Ensure roofs and gutters are intact and well maintained. OEHS IIPP Template, 

Attachment E

Annual Campus/

Facilities Inspection

Checklist

Weeds Maintain school grounds free of weeds. OEHS IIPP Template, 

Attachment E

Annual Campus/

Facilities Inspection

Checklist

Carts Brakes Hand-held brakes on motorized carts should be periodically checked to ensure 

they are in working condition.

Key Activation Motorized carts should require key activation, and the key should be removed 

when cart is not in use. 

Wheel Chocks Place wheel chocks in front and behind one wheel of motorized carts when 

stationary. If necessary, place a trouble call to the Maintenance and

Operations trouble-call desk at (213) 745-1600.
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

12

FACILITIES AND EQUIPMENTMAINTENANCE

Type Subtype Corrective Action for Identified Deficiency Reference

Electrical Equipment Clearance Maintain at least 3 ft clearance around all electrical equipment (e.g., electrical 

panels, switchgear, transformers). 

8 CCR § 2340;

29 CFR § 1910.303

Electrical Panels Ensure the identification of all circuit breakers within electrical panels indicate 

the circuits they are protecting. 

29 CFR § 1910.303

Ground Fault Interrupter Ensure power tools/equipment are used on circuits protected by ground fault 

interrupter (GFI).

29 CFR § 1910.304

Guarding Ensure electrical equipment components operating at 50 volts or above are 

guarded to prevent access, unless confined to rooms only accessible to

qualified persons. 

8 CCR § 2340;

29 CFR § 1910.303

Outlet Covers Provide approved covers for all electrical outlets, switch plates, pull boxes, and 

junction boxes. 

8 CCR § 2340;

29 CFR § 1910.305

Extension Cords and Cable See “Injury and Illness Prevention, Extension Cords and Cables”.

Hot Water Ensure hot water is provided in food preparation areas, health office and 

showers. If necessary, place a trouble call to the Maintenance and Operations 

trouble-call desk at (213) 745-1600.

OEHS IIPP Template, 

Attachment E

Annual Campus/Facilities 

InspectionForm

Kitchen Waste Management Best Management Practices Implement Best Management Practices (BMPs) for industrial waste disposal as 

defined by the Food Services Branch.

LAMC Article 4 Section 

64.30

Best Management Practices -

Posting

Conspicuously post Best Management Practices (BMPs) in the cafeteria

kitchen and/or food preparation area.

LAMC Article 4 Section 

64.30

Best Management Practices -

Training

Train food service workers on Best Management Practices (BMPs) and 

maintain training records.

LAMC Article 4 Section 

64.30

Dumpsters Keep dumpster lids closed when not in use.
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

13

FACILITIES AND EQUIPMENTMAINTENANCE

Type Subtype Corrective Action for Identified Deficiency Reference

Kitchen Waste Management 

(cont.)

Fats, Oils & Grease Ensure fats, oils, and grease are frozen prior to disposal. LAUSD BMPs

Food Disposal Do not discharge food waste into sink garbage disposals. All food waste

should be disposed of in refuse bins. 

LAMC Article 4 Section 

64.30

Permits Air Quality Ensure facility equipment subject to South Coast Air Quality Management 

District (SCAQMD) permit requirements is lawfully permitted and that the 

permit is current.

(SCAQMD) Rules and 

Regulations

OSHA Post valid operating permit near air compressor, air pressure tank, elevator, 

boiler, or other equipment subject to permitting.

8CCR 461

8CCR 344.2

8CCR 344.1

Salvage Items Remove unusable equipment and other salvage items pursuant to the Reference 

Guide REF-1071, Pick-up and Transfer of Materials for Salvage.

Reference Guide REF-1071

Securing Equipment Ensure equipment designed to be located in a fixed position is secured to 

prevent its "walking" or moving. 

Playground and Sport 

Equipment

Discontinue Use Discontinue use of playground equipment not meeting current specifications. 22 CCR § 65710;

CPSC Guidelines

Inspections Ensure playground equipment is inspected daily by site staff and at least 

annually by a certified inspector.

Specifications Ensure playground equipment and matting comply with American Society for 

Testing and Materials (ASTM) standards and Consumer Products Safety

Commission (CPSC) guidelines.

22 CCR § 65710;

CPSC Guidelines

Training Train students on proper use of sports equipment. Bulletin M -66

42, 44
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

14

FACILITIES AND EQUIPMENTMAINTENANCE

Type Subtype Corrective Action for Identified Deficiency Reference

Powered Equipment Condition Periodically inspect equipment to ensure that electrical cords, hoses and

fittings, and safety devices are in good condition.

Storage Ensure lawnmowers and other powered equipment is stored in a secure area, 

not located in buildings occupied by students. 

Training Ensure proper training of personnel that use steam cleaners, pressure washers, 

wet abrasive washers or other cleaning equipment.

Prohibited Use Do not use gasoline powered equipment in buildings or other enclosed areas.

Trouble Calls Maintain “Trouble Call Log” and ensure trouble calls are made in a timely 

manner.

OEHS IIPP Template, 

Attachment E

Annual Campus/

Facilities Inspection Form

Restrooms Adequate Facilities –

Kindergarten

Provide and maintain open a sufficient number of restroom facilities to meet 

student needs (kindergarten buildings: 1 toilet for up to 20 students; 2 toilets 

for 21 to 50 students; and 1 additional toilet for every 50 additional students.)

Education Code 35292.5; 

SB 892; District Bulletin 

735

Adequate Facilities –

Elementary (pre-1994)

Provide and maintain open a sufficient number of restroom facilities to meet 

student needs (elementary schools constructed prior to 1994: 1 urinal for every 

30 male students; 1 toilet for every 100 male students; and 1 toilet for every 35 

female students).

UBC Section 805

Adequate Facilities –

Elementary (post-1994)

Provide and maintain open a sufficient number of restroom facilities to meet 

student needs (elementary schools constructed after 1994: 1 urinal for every 75 

male students; 1 toilet for every 30 male students; and 1 toilet for every 25 

female students).

5 CCR 

Adequate Facilities –

Secondary (pre-1994)

Provide and maintain open a sufficient number of restroom facilities to meet 

student needs (secondary schools constructed prior to 1994: 1 urinal for every 

30 male students; 1 toilet for every 100 male students; and 1 toilet for every 45 

female students).

UBC Section 805

Adequate Facilities –

Secondary (post-1994)

Provide and maintain open a sufficient number of restroom facilities to meet 

student needs (secondary schools constructed after 1994: 1 urinal for every 35 

male students; 1 toilet for every 40 male students; and 1 toilet for every 30 

female students).

5 CCR Section 
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

15

FACILITIES AND EQUIPMENTMAINTENANCE

Type Subtype Corrective Action for Identified Deficiency Reference

Restrooms (cont.) Adequate Facilities - Female 

Employees

Provide adequate restroom facilities for employees (1 toilet for up to 34 female 

employees; 2 toilets for 35 to 54 female employees; 3 toilets for over 55 

female employees; and 1 additional toilet for every 40 additional female 

employees.

Visually inspect restroom facilities to confirm adequate number of facilities.

UBC Appendix C

Adequate Facilities - Male 

Employees

Provide adequate restroom facilities for employees (1 urinal for every 50 male 

employees; 1 toilet for up to 34 male employees; 2 toilets for 35 to 54 male 

employees; 3 toilets for over 55 male employees; and 1 additional toilet for 

every 40 additional male employees.

UBC Appendix C

Fixture Operation Maintain toilets, fixtures and drains in proper working conditions. If necessary, 

place a trouble call to the Maintenance and Operations trouble-call desk at 

(213) 745-1600.

Gender Designation Provide gender-segregated restrooms in all facilities which have more than 

five employees.

8CCR 3364

Supplies Ensure restrooms are adequately stocked with toilet paper, soap and paper 

towels.

Service Log Maintain a daily restroom service log for review by District Staff. Bulletin 735

Ventilation Maintain restroom exhaust fans in proper working condition. If necessary, 

place a trouble call to the Maintenance and Operations trouble-call desk at 

(213) 745-1600.

Recycling Consider waste recycling for paper and cardboard, toner cartridges and

beverage containers. For assistance, contact OEHS Duty Officer at (213) 241-

3199 or refer to OEHS website at www.lausd-oehs.org.

Memoranda 997

Wastewater Management Sewers Ensure that debris is periodically cleared from sewer and storm drain inlets. Annual Campuses/ 

Facilities Inspection 

Checklist

Storm Drain Do not discharge hazardous substances, cleaning agents or waste water into 

storm drains.
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

16

FIRE/LIFE SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Access and Egress Emergency Exit Grills Provide at least one security grill with “emergency breakaway” capacity for 

classrooms equipped with security grills. The window with the breakaway grill 

must be constructed of glass, and clearly identified as an emergency exit. In 

classrooms with only one exit door, the breakaway grill must be located

furthest from the exit door. If necessary, place trouble call to the Maintenance 

and Operations trouble-call desk at (213) 745-1600.

CBC Section 305.2.4, 

UBC Section 305.2.4, 

District Policy

Exit Pathways Ensure classrooms with an occupancy of 50 or more have at least two means 

of egress.

8 CCR § 3225;

LA Fire Code § 57.33.11; 

Section 305.2.4; 29 CFR § 

1910.36

Obstructions Maintain building exit pathways free of obstructions to ensure safe egress. 8 CCR § 3227;

LA Fire Code § 57.33.11

29 CFR § 1910.37

Panic Hardware Ensure panic hardware is provided and maintained on main exit doors or are 

posted with signage indicating "This Door to Remain Unlocked During 

Business Hours". If necessary, place a trouble call to the Maintenance and 

Operations trouble-call desk at (213) 745-1600.

LA Fire Code § 57.33

Signs – Elevator Post signage adjacent to elevator call devices indicating procedure to follow in 

case of emergency.

Signs-General Provide visible exit signs or directional signs for all exit doors and escape 

pathways. If necessary, place a trouble call to the Maintenance and Operations 

trouble-call desk at (213) 745-1600.

8 CCR § 3216

LA Fire Code § 57.33.15

29 CFR § 1910.36

Signs – Obstructed Remove all objects that may conceal or obscure exit signs. UBC Section 305.2.4

Signs – “No Exit” Place "NO EXIT" signs on non-exit doors or indicate actual use. If necessary, 

place a trouble call to the Maintenance and Operations trouble-call desk at 

(213) 745-1600.

8 CCR § 3216

LAMC § 57.33.15

29 CFR § 1910.36
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

17

FIRE/LIFE SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Elevated Work Surfaces Access Provide a permanent means of access and egress to elevated storage and work 

surfaces.

8 CCR §§ 3209, 3210, 

3211, and 3212

Guarding Provide standard guard rails for elevated surfaces in excess of 30 inches above 

any adjacent floor or ground surface (exception: auditorium side of stage). If 

necessary, place a trouble call to the Maintenance and Operations trouble-call

desk at (213) 745-1600.

8 CCR §§ 3209, 3210, 

3211, and 3212

Ladder Condition Ensure portable ladders are routinely inspected and maintained in good repair. 8 CCR §§ 3278, 3279

29 CFR §§ 1910.25, 

1910.26

Ladders - Metal Ensure metal ladders are labeled indicating "CAUTION: DO NOT USE

AROUND ELECTRICAL EQUIPMENT".

8 CCR §§ 3278, 3279

29 CFR §§ 1910.25, 

1910.26

Lifts Conduct and document weekly testing of all special access lifts (wheelchair 

lifts, auditorium stage lifts and swimming pool immersion lifts).

29 CFR§ 1910.68

Load Capacity Post signs indicating load capacity for elevated surfaces. 8 CCR §§ 3209, 3210, 

3211, and 3212

Toe Boards Install standard 4-inch toe boards for elevated surfaces to prevent objects from 

falling. If necessary, place a trouble call to the Maintenance and Operations 

trouble-call desk at (213) 745-1600.

8 CCR §§ 3209, 3210, 

3211, and 3212

Fire Prevention Clearance - Fire Equipment Maintain a minimum 3-foot clearance around fire extinguishers, fire hoses, 

pull stations and sprinkler control valves.

8CCR 6151

LAMC 57.140.09

Clearance - Fire Sprinklers Maintain a minimum 18-inch clearance between overhead sprinklers and

materials below.

8 CCR § 6170;

Annual Campus/

Facilities Inspection Form

Clearance - Heaters Maintain a minimum 3-foot clearance around heater/furnace. UFC 1107

Curtains Remove non-flame retardant curtains or post current certification that curtains 

are flame-resistant (certification tag must be attached to curtain).

LAMC 57.110.12
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

18

FIRE/LIFE SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Fire Prevention (cont.) Emergency Vehicle Access Ensure school has at least one entrance gate with an opening of at least 20 ft to

accommodate emergency vehicles. Ensure fire lanes are provided and

maintained free of obstruction.

LA Fire Code § 57.111.07

Fire Alarms – Obstruction Ensure compliance with fire alarm testing procedure in Bulletin No. 61 and

ensure that fire alarm mechanisms are free of obstruction.

LA Fire Code § 57.01.22; 

29 CFR § 1910.165

Fire Alarms – Testing Conduct and document weekly inspections of fire alarms to ensure they are in 

good working order.

8CCR 6184 (Alarms)

LAMC 57.138.041 & .09

Fire Doors Do not impair function of self-closing fire doors. LAMC57.20.41

Fire Extinguishers - General Fully charge and mount portable fire extinguishers and ensure signs are posted 

to indicate location. If necessary, place a trouble call to the Maintenance and 

Operations trouble-call desk at (213) 745-1600.

8 CCR § 6151;

29 CFR § 1910.157

Fire ExtinguishersHydrostatic TestingPerform hydrostatic testing at the required interval of 5 or 12 years, depending 

on the fire extinguishing media.

8 CCR § 6151;

29 CFR § 1910.157

Fire Extinguishers- Inspection Conduct and document monthly visual inspection and perform annual

maintenance inspection of portable fire extinguishers.

8 CCR § 6151;

29 CFR § 1910.157

Fire Sprinkler Requirement Ensure the maximum distance from any point in the building to an exterior exit 

or an enclosed exit stairway does not exceed 150 feet in buildings without 

sprinklers or 200 feet in buildings with sprinklers. If necessary, place a trouble 

call to the Maintenance and Operations trouble-call desk at (213) 745-1600.

8 CCR § 3222

Paper Decorations Remove all combustible materials (e.g., paper decorations, hanging mobiles) 

from exit doors, electrical panels, light fixtures, fire sprinklers and heaters.

LAMC 57.22.01

Training Provide fire extinguisher training to new employees, and at least annually 

thereafter.

8 CCR § 6151;

29 CFR § 1910.157
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04

19

FIRE/LIFE SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Occupancy Limit Post signs above assembly room doors indicating maximum occupant load and 

usage as referenced in the Certificate of Occupancy.

LA Fire Code § 57.33.04

Walkways Guarding Provide temporary guarding or other controls for floor openings, excavations 

and damaged walking surfaces to prevent falls. If necessary, place a trouble 

call to the Maintenance and Operations trouble-call desk at (213) 745-1600.

8 CCR § 3232; 3272;

29 CFR § 1910.22

Non-Slip Provide and maintain non-slip materials on ramps, or aisle and walkway 

surfaces prone to moisture. If necessary, place a trouble call to the

Maintenance and Operations trouble-call desk at (213) 745-1600.

8 CCR § 3232; 3272;

29 CFR § 1910.22

Trip Hazards Maintain aisles and walkways free of obstruction or tripping hazards. 8 CCR § 3215;

29 CFR § 1910.36;

8 CCR § 3232; 3272;

29 CFR § 1910.22
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 20

INDOOR ENVIRONMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Indoor Air Quality Blocked Vents Remove all items blocking air vents to ensure adequate HVAC system

ventilation.

Complaint Log Maintain log of nuisance odors potentially affecting indoor air quality. Report 

to OEHS at (213) 241-3199, and if an outdoor emission source is suspected, 

contact South Coast Air Quality Management District (SCAQMD) at (800)

288-7664.

Safety Alert No. 03-02

Exhaust Ventilation Ensure adequate exhaust ventilation for all activities emitting air contaminants. 

If necessary, place a trouble call to the Maintenance and Operations troublecall desk at (213) 745-1600.

HVAC Maintenance Perform periodic preventative maintenance on HVAC systems. If necessary, 

place a trouble call to the Maintenance and Operations trouble-call desk at 

(213) 745-1600.

Mold Infestation Mitigate mold and mildew infestation..

Odors Ensure that rooms are properly maintained to minimize chemical smells and 

objectionable odors.

Vehicle Idling Ensure vehicles are not idling in the vicinity of classrooms.

Water Damage Correct all unresolved water damage. If necessary, place a trouble call to the 

Maintenance and Operations trouble-call desk at (213) 745-1600.

Lighting Ensure all areas within the school have adequate lighting. 
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 21

INDOOR ENVIRONMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Noise Classroom Noise Contact OEHS Industrial Hygiene Section at (213) 241-3199 to arrange for 

evaluation of interior noise source (this is in response to a request, complaint, 

or elevated noise levels identified during inspection).

OEHS Position on 

Classroom Acoustical 

Quality

Construction Noise Contact OEHS Industrial Hygiene Section at (213) 241-3199 to arrange for 

evaluation of construction noise source (this is in response to a request,

complaint, or elevated noise levels identified during inspection).

OEHS Position on 

Classroom Acoustical 

Quality

LA Municipal Code 

Chapter 11

Transportation Noise Contact OEHS Industrial Hygiene Section at (213) 241-3199 to arrange for 

evaluation of transportation noise source (this is in response to a request,

complaint, or elevated noise levels identified during inspection).

OEHS Position on 

Classroom Acoustical 

Quality

California DOT Chapter 30

Industrial Noise Contact OEHS Industrial Hygiene Section at (213) 241-3199 to arrange for 

evaluation of industrial noise source (this is in response to a request,

complaint, or elevated noise levels identified during inspection).

OEHS Position on 

Classroom Acoustical 

Quality

LA Municipal Code 

Chapter 11

Other Noise Source Contact OEHS Industrial Hygiene Section at (213) 241-3199 to arrange for 

evaluation of outdoor noise source (this is in response to a request, complaint, 

or elevated noise levels identified during inspection).

OEHS Position on 

Classroom Acoustical 

Quality

LA Municipal Code 

Chapter 11
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 22

INJURY AND ILLNESS PREVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Injury and Illness Prevention

Program (IIPP)

Program Prepare and implement an Injury and Illness Prevention Program (IIPP) using 

the OEHS IIPP Template, and update at least annually. The IIPP Template 

may be downloaded at www.lausd-oehs.org. 

8 CCR § 3203

Death/Serious Injury 

Reporting

Notify Cal/OSHA within 8 hours if any employee is seriously injured on the 

job. 

8 CCR § 342;

29 CFR § 1904.8; Safety 

Alert No. 02-09

Elevated Injury Rate Workers’ Compensation Claims Rate for this site is significantly higher than 

the District-wide average. Review accident trends and provide and document 

training to staff as necessary. 

Incident Report Ensure an investigation is conducted and an Incident Report is prepared for 

each accident (Incident Report is Attachment G in the Injury and Illness 

Prevention Program).

OEHS IIPP Template, 

Attachment G

Inspections Conduct and document semi-annual safety inspections pursuant to Injury and 

Illness Prevention Program (IIPP).

8 CCR § 3203; OEHS IIPP 

Template, Attachment E

OSHA Log 300 Maintain OSHA Log 300 of employee injuries and illnesses as required by 

Cal/OSHA regulation. Contact OEHS at (213) 241-3199 to request a copy. 

8 CCR § 14305

OSHA Log 300 Summary 

Posting

Post previous calendar year's OSHA 300 summary from February 1 through 

March 1 in a location frequented by employees.

8 CCR § 14305

29 CFR § 1904

OSHA Poster Post Cal/OSHA Safety & Health Protection Job poster in a conspicuous

location.

8 CCR 340

Records Maintain safety inspection records for three years as required by the Injury and 

Illness Prevention Program (IIPP). 

8 CCR § 3203; OEHS IIPP 

Template, Section E

Responsible Individual Assign authority and responsibility for implementation of Injury and Illness 

Prevention Program (IIPP).

8 CCR § 3203; OEHS IIPP 

Template
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 23

INJURY AND ILLNESS PREVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Injury and Illness Prevention

Program (IIPP) (cont.)

Safety Committee Establish School Safety Committee that: meets at least quarterly and records 

meeting minutes; reviews results of workplace inspections and incident reports 

to identify safety issues and determine incident causes; reviews alleged 

hazardous conditions and safety suggestions brought to the attention of any 

committee member; and submits recommendations to management to resolve 

safety issues.

8 CCR § 3203

OEHS IIPP Template

OEHS Model Safe School 

Plan

Summary Page Post a copy of the Injury and Illness Prevention Program (IIPP) Summary in a 

conspicuous area.

8 CCR § 3203; OEHS IIPP 

Template, Attachment B

Training Provide and maintain records of annual Injury and Illness Prevention Program 

(IIPP) training to all employees.

8 CCR § 3203

Ambient Noise Sources See “Indoor Environment, Noise”.

Bloodborne Pathogens Exposure Control Plan Ensure implementation of Bloodborne Pathogen Exposure Control Plan (ECP) 

to minimize exposure to bloodborne pathogens pursuant to Title 8 CCR. (See 

School Nurse for ECP requirements.)

8 CCR § 5193;

29 CFR § 1910.1030

Cleanup Kit Provide bloodborne pathogen cleanup kits for the disposal of body fluids and 

medical waste. Kits will include, at minimum, personal protective equipment 

(gloves, goggles, clothing protection) and biohazard bags.

8 CCR § 5193;

29 CFR § 1910.1030

Decontamination Clean and sanitize areas that may have been exposed to bloodborne pathogens. 8 CCR § 5193

29 CFR § 1910.1030

Exposure Evaluation Ensure a post-exposure evaluation is conducted following all potential

employee exposures to bloodborne pathogens.

8 CCR § 5193;

29 CFR § 1910.1030

Labeling Affix warning labels to all containers used to store, transport, or ship potential 

BBP materials. Ensure biological waste is placed in red biohazard bags.

8 CCR § 5193;

29 CFR § 1910.1030
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 24

INJURY AND ILLNESS PREVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Bloodborne Pathogens (cont.) Personal Protective 

Equipment

Provide personal protective equipment to employees at risk of exposure to 

bloodborne pathogens. 

8 CCR § 5193;

29 CFR § 1910.1030

Recordkeeping Maintain records of employee Bloodborne Pathogen training, including name 

of employee, training date, outline of presented material, name and title of 

person conducting training, job titles, and ID numbers. For employees in a 

“primary exposure category”, training records should include a copy of either 

the hepatitis B vaccination status or Declination Form.

8 CCR § 5193;

29 CFR § 1910.1030

Sharps - Use Ensure sharps are only used by trained personnel. 8 CCR § 5193;

29 CFR § 1910.1030

Sharps - Disposal Ensure that contaminated sharps are disposed in approved containers. 8 CCR § 5193;29 CFR § 

1910.1030

Training Provide all employees with annual bloodborne pathogen awareness training. 8 CCR § 5193;

29 CFR § 1910.1030

Equipment Guarding Fans Ensure all fans whose blades are less than 7-feet above the floor or working 

level are equipped with blade guards. 

29 CFR 1910.212

General Ensure proper guarding is provided and maintained on all equipment to 

prevent injury to operators.

29 CFR 1910.212

Electrical Equipment See “Facilities and Equipment Maintenance, Electrical Equipment”.
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 25

INJURY AND ILLNESS PREVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Extension Cords and Cables Damaged Destroy and discard electrical cords that are frayed, spliced, taped, or

otherwise deteriorated.

8 CCR § 2300;

29 CFR § 1910.305

UL Approved Ensure extension cords and cables are UL approved and suitable for the

conditions of use.

8 CCR § 2300;

29 CFR § 1910.305

Use - General Ensure flexible extension cords and cables are not used in place of permanent 

wiring. 

8 CCR § 2300;

29 CFR § 1910.305

Use – In Series Ensure extension cords, outlet multipliers and surge protectors are not used in 

series.

8 CCR § 2300;

29 CFR § 1910.305

Use – Near Water Ensure that flexible cords and cables are not used near sinks, faucets or other 

water sources. 

8 CCR § 2300;

29 CFR § 1910.305

Use – On Metal Do not hang extension cords and cables on metal hangers or supports. 8 CCR § 2300;

29 CFR § 1910.305

Use – Through Opening Ensure extension cords and cables are not run through holes in walls, ceilings, 

floors or similar openings.

8 CCR § 2300

29 CFR § 1910.305

Face/Eye Protection Provide face/eye protection for persons at risk of injury from airborne objects, 

particulate matter or hazardous substances.

8CCR 3382
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 26

INJURY AND ILLNESS PREVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Hearing Conservation Program Ensure all personnel who are exposed to a time weighted average (TWA) noise 

level greater than 85 db(A) are included in a Hearing Conservation Program. 

For assistance with noise monitoring, training, audiometric testing or other 

hearing program requirements, contact OEHS at (213) 241-3199.

8 CCR §§ 5097;

29 CFR § 1910.95

Complaint Procedures Ensure employees are informed of the need to report excessive noise levels in 

their workplace to their supervisor so that an appropriate evaluation can be 

made.

8 CCR § 5096;

29 CFR § 1910.95

Heat Stress Implement actions to prevent heat related illnesses in athletes pursuant to 

District Guidelines for Preventing Heat Stress.

Bulletin 963

Household Appliances Remove from classroom, household appliances (e.g. toaster/oven, microwave 

oven, refrigerator, coffee machine, heater) or other unauthorized electrical 

appliances pursuant to Bulletin C-26.

Bulletin C-26

Medication Storage Ensure medication cabinet is secured at all times.

Respiratory Protection Program Maintain a written Respiratory Protection Program dealing with the use of 

respiratory protective equipment by employees or students. 

8 CCR § 5144;

29 CFR §§ 1910.134

Equipment Provide respiratory protection equipment when engineering/operational

controls are not feasible for limiting an identified exposure to airborne

contaminants.

8 CCR § 5144

Sports Medical Clearance Ensure appropriate medical clearance for students prior to participating in 

interscholastic athletics.

Bulletin Z-9

Smog Alerts Ensure staff and students are notified of “Smog Alerts” and other air pollution 

episodes pursuant to Reference Guide REF-886.

Reference Guide REF-886
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 27

LEAD MANAGEMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Drinking Fountains Flush drinking fountains, kitchen faucets and other water fixtures used to 

dispense drinking water each morning for a minimum period of 30 seconds to 

minimize potential exposure to lead and other water pollutants. 

Reference Guide REF-858

Peeling Paint or Debris Repair Repair areas of peeling paint or otherwise deteriorated paint surfaces and clean

up paint debris. If necessary, place a trouble call to the Maintenance and 

Operations trouble-call desk at (213) 745-1600.

Area Closure Restrict access to areas where visible paint debris is accessible to students and 

staff. 

Room Closure Restrict access to rooms with peeling paint or paint debris in areas directly 

accessible to students in kindergarten through third grade. 

Other Source of Lead 

Contamination

Restrict access to rooms or other areas with potential lead contamination. 
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 28

MISCELLANEOUS

Type Subtype Corrective Action for Identified Deficiency Reference

Animal Care Authorization Obtain authorization from site administrator prior to bringing animals into the 

classroom.

Bulletin 83

Humane Treatment House and care for all caged animals in a humane and safe manner. Bulletin 83

LAUSD Required Poster Ensure LAUSD Integrated Regulatory Requirements Poster is posted in a

conspicuous area and accessible to employees.

Smoking Prohibit smokoing on District prohibit pursuant to Bulletin 66. Bulletin 66
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 29

OFF-SITE RISKS

Type Subtype Corrective Action for Identified Deficiency Reference

Abandoned Vehicle Off-site survey identified abandoned vehicle that may pose a significant risk to 

school occupants. OEHS will confer with appropriate regulatory agencies to 

assess and/or mitigate potential risk.

Air Emission Source An industrial air emission source(s) has been identified in proximity of the 

school which may pose a significant health or safety risk to school occupants. 

Report all air pollution complaints to OEHS at (213) 241-3199 and South 

Coast Air Quality Management District (SCAQMD) at (800) 288-7664. 

Maintain log of air pollution complaints pursuant to Safety Alert 03-02. 

OEHS will confer with appropriate regulatory agencies to assess and/or

mitigate potential risk.

Safety Alert No. 03-02

Airport or Other Major 

Transportation Corridor

Off-site survey identified airport or other major transportation corridor that 

may pose a significant health or safety risk to school occupants. OEHS will 

confer with appropriate regulatory agencies to assess and/or mitigate potential 

risk. 

“High Risk” Facility Off-site survey identified one or more industrial facilities that may pose a

significant health or safety risk to school occupants. OEHS will confer with 

appropriate regulatory agencies to assess and/or mitigate potential risk. 

Board Resolution on “High 

Risk Facilities”

Noise Off-site survey identified potential noise source that may interrupt the learning 

environment. OEHS will notify appropriate regulatory agencies to assess 

and/or mitigate potential risk.

Pipelines Off-site survey identified one or more high pressure or petroleum pipelines 

that may pose a significant health or safety risk to school occupants. OEHS 

will confer with appropriate regulatory agencies to assess and/or mitigate 

potential risk. 

Power Lines Off-site survey identified one or more high power transmission line that may 

pose a significant health or safety risk to school occupants. OEHS will confer 

with appropriate regulatory agencies to assess and/or mitigate potential risk. 

Railway Line Off-site survey identified a railway line that may pose a significant health or 

safety risk to school occupants. OEHS will confer with appropriate regulatory 

agencies to assess and/or mitigate potential risk. 
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 30

OFF-SITE RISKS

Type Subtype Corrective Action for Identified Deficiency Reference

Sidewalk/Curb Off-site survey identified deteriorated sidewalk/curb in public walkway that 

may pose a trip and fall hazard to school occupants. OEHS will confer with 

appropriate regulatory agencies to assess and/or mitigate potential risk.

Traffic Hazard Off-site survey identified traffic conditions that may pose a significant risk to 

school occupants. OEHS will confer with appropriate regulatory agencies to 

assess and/or mitigate potential risk. 

Trash/Debris Off-site survey identified trash/debris or other material including dead animals 

that may pose a significant health or safety risk to school occupants. OEHS 

will confer with appropriate regulatory agencies to assess and/or mitigate 

potential risk.

Unlawful Activity Off-site survey identified unlawful activity adjacent to school (drug or liquor 

sales, gang activity, street vending, loitering, etc.) OEHS will notify 

appropriate authority. 

Bulletin BUL-577
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 31

PEST MANAGEMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Integrated Pest Management Program Maintain a copy of the District's Integrated Pest Management (IPM) program

in the main office. Contact Pest Managment at (213) 745-1435to obtain a 

copy.

AB2260

Approved Pesticides List Post a current copy of the District’s Approved Pesticide Products List in the 

main office.

CEC § 17612

Awareness Ensure all staff is familiar with the Integrated Pest Management (IPM) Policy 

and Program.

California Education Code 

(CEC) § 17610

Notification Provide written annual notification to staff and parents of pesticide products 

expected to be used during the school year. The notification should offer to 

staff and parents a procedure by which they may receive 72 hour advance 

notification of pesticide use, and should include a copy of District’s Approved 

Pesticide Products List.

CEC § 17612

Pesticide Application Ensure pesticides used on campus are on the District’s Approved Pesticide 

Products List and applied only by a District Pest Management Technician. 

CEC § 17612

Recordkeeping Maintain records for the past 4 years of pesticides used at the site. Integrated Pest 

Management Program

CEC 17611

Standing Water Remove all sources of stagnant or standing water on campus to prevent 

mosquito breeding. 

Safety Alert 04-07

Warning Signs Ensure warning signs are posted at least 24 hours prior to pesticide application 

and remain posted for 72 hours after application.

CEC § 17612

Bird Nesting Mitigate bird nesting problem. Place trouble call to District Pest Management 

at (213) 745-1435

LAUSD Integrated Pest 

Management Handbook

Dead Bird Handle dead bird on campus in accordance with Safety Alert West Nile Virus 

Precautions.

Safety Alert 04-07
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 32

PEST MANAGEMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Fly Fans Provide air curtains, fly fans and/or self-closing screen doors for all cafeteria 

doors opening to the outside. If necessary, place a trouble call to the

Maintenance and Operations trouble-call desk at (213) 745-1600.

CURFFL 114030

Insects Mitigate insect infestation (e.g. ants, spiders, cockroaches, termites). Place 

trouble call to District Pest Management at (213) 745-1435

LAUSD Integrated Pest 

Management Handbook

Rodents Mitigate rodent infestation. Place trouble call to District Pest Management at 

(213) 745-1435

LAUSD Integrated Pest 

Management Handbook
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 33

TRAFFIC AND PEDESTRIAN SAFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Pedestrian Routes Ensure “Safe Pedestrian Routes” to school have been designated, distributed to 

parents and posted in the main office.

Safety Evaluation Contact OEHS Traffic Safety Section at (213) 241-3199 to request evaluation 

of traffic safety issues, signage, and training or for assistance on safe routes to 

school. 

Student Drop-off and Pick-up 

Points

Enforcement Request assistance from School Police and/or local law enforcement for traffic 

enforcement as necessary to ensure student safety during drop-off and pickup 

times.

Supervision Ensure student drop-off and pick-up points are designated and supervised as 

required by OEHS Safe School Plan, Volume 1 – Prevention Programs.

Safe School Plan, Volume 1 

– Prevention Programs

Training and Education Provide students, parents and employees with: AAA traffic safety and 

pedestrian brochures; bicycle and bus safety rules; information on pedestrian 

routes to and from school; student drop-off/pickup procedures; and seat

belt/car safety information.

Memorandum CT-1
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 34

VIOLENCE PREVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Safe School Plan – Volume 1 Develop and annually update Safe School Plan. Refer to OEHS Model Safe 

School Plan, Volume 1 - Prevention Programs at www.lausd-oehs.org.

Model Safe School Plan, 

Volume 1 - Prevention 

Programs

Attendance Plan Establish attendance plan in compliance with District policy. Bulletin 13

Bulletin Z-54

Crisis Intervention Team Ensure that the school has established a Crisis Intervention Team and the site 

administrator has identified team members.

Model Safe School Plan, 

Volume 1 - Prevention 

Programs; Bulletin 962

Handbook Maintain a copy of the most recent Crisis Intervention Handbook, so that it is 

available to the site administrator and members of the Crisis Intervention 

Team. 

Model Safe School Plan, 

Volume 1 - Prevention 

Programs

Intervention Notebook Maintain an intervention notebook to document the specifics of each critical 

incident and Crisis Intervention Team actions taken in response. 

Model Safe School Plan, 

Volume 1 - Prevention 

Programs 

Training Ensure that school Crisis Intervention Team meet regularly for training and 

review of the crisis intervention plan. Training documentation should include 

name of trainer, trainer affiliation, and location of training and date of training. 

Model Safe School Plan, 

Volume 1 - Prevention 

Programs; Bulletin 962

Discipline Code Ensure that the school discipline code is distributed annually to all students, 

parents and employees.

OEHS Model Safe School 

Plan Volume 1 –

Prevention Programs; 

Collective Bargaining 

Agreement, UTLA & 

LAUSD, Articles XXIV 

and XXVIII
Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook

Preliminary Revision 08/27/04 35

VIOLENCE PREVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Human Relations Leadership

Team (HRLT)

Team Establish a Human Relations Leadership Team (HRLT) and assign a

coordinator. 

Model Safe School Plan, 

Volume 1 - Prevention 

Program

Calendar Ensure the Human Relations Leadership Team (HRLT) maintains a calendar

of events to implement strategies for the Multicultural and Human Relations 

Education Program (MHREP).

Model Safe School Plan, 

Volume 1 - Prevention 

Programs

MHREP Summary Ensure the Human Relations Leadership Team (HRLT) submits a year-end 

summary of the Multicultural and Human Relations Education Program

(MHREP) to the site administrator and school governance council.

Office of Intergroup 

Relations, "Educating for 

Diversity: A Framework 

for Multicultural and 

Human Relations 

Education, School 

Assessment Checklist," 

pages 76-79, 4-92.
Safe School Inspection Guidebook 36

Revised 07/01/04

INDEX

3-Year Survey ......................................................................2

6-Month Surveillance...........................................................2

Abandoned Vehicle............................................................29

Access................................................................................17

Access and Egress..............................................................16

Accident Report .................................................................22

Adequate Facilities - Female Employees..........................15

Adequate Facilities - Male Employees .............................15

Adequate Facilities – Elementary (post-1994)...................14

Adequate Facilities – Elementary (pre-1994)....................14

Adequate Facilities – Kindergarten....................................14

Adequate Facilities – Secondary (post-1994)....................14

Adequate Facilities – Secondary (pre -1994)......................14

Air Emission Source ..........................................................29

Air Quality .........................................................................13

Airport or Other Major Transportation Corridor...............29

Aisles....................................................................................8

Ambient Noise Sources......................................................23

Animal Care.......................................................................28

Approved Pesticides List...................................................31

Area Closure ......................................................................27

Asbestos Management .....................................................2–3

Asbestos Management Plan .................................................2

Asphalt ...............................................................................10

Attendance Plan .................................................................34

Authorization .....................................................................28

Availability...........................................................................2

Awareness..........................................................................31

Best Management Practices...............................................12

Best Management Practices - Posting................................12

Best Management Practices - Training..............................12

Bird Nesting.......................................................................31

Blocked Vents....................................................................20

Bloodborne Pathogens.................................................23, 24

Brakes.................................................................................11

Broken Windows................................................................10

Calendar.............................................................................35

Campus Security ..................................................................4

Carpeting............................................................................10

Carts...................................................................................11

Characterization ...................................................................8

Chemical Handling & Storage – General Requirements.....5

Chemical Hygiene................................................................5

Chemical Inventory..............................................................7

Chemical Safety...............................................................5–8

Classroom Noise................................................................21

Cleanup Kit........................................................................23

Clearance............................................................................12

Clearance - Fire Equipment ...............................................17

Clearance - Fire Sprinklers ................................................17

Clearance - Heater..............................................................17

Closed Containers................................................................8

Complaint Log ...................................................................20

Condition....................................................................2, 7, 14

Condition of Equipment and Facilities ..............................10

Construction Noise.............................................................21

Container Storage.................................................................8

Crisis Intervention..............................................................34

Current.................................................................................2

Curtains..............................................................................17

Damaged ............................................................................25

Dead Bird...........................................................................31

Death/Serious Injury Report ..............................................22

Decontamination................................................................23

Discipline Code..................................................................34

Discontinue Use.................................................................13

Disposal................................................................................8

Drills.....................................................................................9

Drinking Fountains............................................................27

Dumpsterss.........................................................................12

Electrical Equipment....................................................12, 24

Electrical Panels .................................................................12

Elevated Work Surface ......................................................17

Emergency Exit Grills........................................................16

Emergency Preparedness.....................................................9

Emergency Vehicle Access................................................18

Equipment..........................................................................26

Equipment Guarding..........................................................24

Exhaust Ventilation............................................................20

Exit Pathways.....................................................................16

Exposure Control Plan .......................................................23

Exposure Evaluation ..........................................................23

Extension Cords and Cable................................................12

Extension Cords and Cables ..............................................25

Eyewash...............................................................................7

Face/Eye Protection ...........................................................25

Facilities and Equipment Maintenance........................10–15

Fans....................................................................................24

Fats, Oils & Grease............................................................13

Fences and Gates................................................................10

Fire Alarm – Obstruction...................................................18

Fire Alarm – Testing..........................................................18

Fire Doors ..........................................................................18

Fire Extinguishers General.................................................18

Fire Extinguishers- Hydrostatic Testing ............................18

Fire Extinguishers- Inspection ...........................................18

Fire Prevention...................................................................17

Fire Sprinkler Requirement................................................18

Fire/Life Safety ............................................................16–19

Fixture Operation...............................................................15

Flammable and Combustible Materials ...............................6

Flammable Storage Labeling ...............................................6

Flammable Storage Room - Aisle Spacing..........................7

Flammable Storage Room -Location...................................6

Floor Buffing........................................................................2

Floor Plan.............................................................................7

Fly Fans..............................................................................32

Food Disposal....................................................................13

Food Storage ........................................................................6

Furniture...............................................................................9

Gas Cylinders.......................................................................7

Gender Designation............................................................15

General.....................................................................9, 10, 24

Ground Fault Interrupter....................................................12

Ground Striping..................................................................10

Grounding & Bonding .........................................................6

Guarding.................................................................12, 17, 19

Handbook...........................................................................34

Hazard Communication .......................................................5

Hazardous Waste Management............................................8

Hearing Conservation ........................................................26

Hearing Conservation -Complaint Procedures ..................26

Heat Stress..........................................................................26

High Risk Facility..............................................................29

Hot Water...........................................................................12

Household Appliances .......................................................26
Safe School Inspection Guidebook 37

Revised 07/01/04

Housekeeping.....................................................................11

Human Relations Leadership .............................................35

Humane Treatment.............................................................28

HVAC Maintenance...........................................................20

HVAC/Water Heaters..........................................................9

Hydrostatic Test...................................................................7

Incompatible Storage .......................................................6, 7

Index.............................................................................36–38

Indoor Air Quality..............................................................20

Indoor Environment.....................................................20–21

Industrial Noise..................................................................21

Injury and Illness Prevention .......................................22–26

Injury and Illness Prevention Program (IIPP)...................22

Injury Rates........................................................................22

Insects.................................................................................32

Inspection...........................................................................22

Inspections...........................................................................8

Inspections.........................................................................13

Integrated Pest Management..............................................31

Intervention Notebook.......................................................34

Inventory ..............................................................................5

Key Activation...................................................................11

Kitchen Waste Management..............................................12

Lab Wastes...........................................................................8

Labeling .............................................................................23

Labels ...................................................................................8

Labels ...............................................................................5, 7

Laboratory Safety.................................................................7

Ladder Condition ...............................................................17

Ladders - Metal..................................................................17

Landscaping .......................................................................11

LAUSD Required Poster....................................................28

Law Enforcement...............................................................33

Lead Management..............................................................27

Lifts....................................................................................17

Lighting..............................................................................20

Load Capacity ....................................................................17

Locked Cabinets...................................................................8

Locked Campus....................................................................4

Maintenance.........................................................................9

Maintenance of Asbestos Containing Material (ACM).......2

Maximum Quantities............................................................6

Medication Storage ............................................................26

MHREP Summary .............................................................35

Miscellaneous.....................................................................28

Mold Infestation.................................................................20

MSDS...................................................................................5

Noise..................................................................................21

Noise..................................................................................29

Non-Qualified Personnel......................................................2

Non-Slip.............................................................................19

Notification ........................................................................31

Obstructions.......................................................................16

Occupancy Limit................................................................19

Odors..................................................................................20

Off-Site Risks...............................................................29–30

OSHA.................................................................................13

OSHA Log 300..................................................................22

OSHA Log 300 - Posting...................................................22

OSHA Poster......................................................................22

Other Noise Source............................................................21

Other Source of Lead Contamination ................................27

Outlet Covers .....................................................................12

Overhead Storage.................................................................9

Panic Hardware ..................................................................16

Paper Decorations..............................................................18

Pedestrian Routes...............................................................33

Peeling Paint or Debris ......................................................27

Permits ...............................................................................13

Personal Protective Equipment..........................................24

Pest Management.........................................................31–32

Pesticide Application .........................................................31

Pipeline...............................................................................29

Plan.......................................................................................5

Playground and Sport Equipment ......................................13

Posting..................................................................................4

Power Line.........................................................................29

Powered Equipment...........................................................14

Program..............................................................5, 22, 26, 31

Prohibited Use....................................................................14

Railway Line......................................................................29

Recordkeeping .............................................................24, 31

Records...............................................................................22

Recycling ...........................................................................15

Repair.................................................................................27

Respiratory Protection........................................................26

Responsible Individual.......................................................22

Restraints..............................................................................6

Restricted Access.............................................................2, 4

Restrooms.....................................................................14, 15

Rodents...............................................................................32

Roof and Gutters................................................................11

Room Closure ....................................................................27

Safe School – Volume 1.....................................................34

Safe School Plan ..................................................................9

Safety Committee...............................................................23

Safety Containers.................................................................6

Safety Evaluation...............................................................33

Salvage Items .....................................................................13

Sanding.................................................................................2

Securing Equipment...........................................................13

Seismic Bracing ...................................................................9

Service Log ........................................................................15

Sewers................................................................................15

Sharps - Disposal...............................................................24

Sharps - Use.......................................................................24

Sidewalk/Curb....................................................................30

Signage.................................................................................7

Signs – “No Exit”...............................................................16

Signs – Elevator.................................................................16

Signs – Obstru cted .............................................................16

Signs-General.....................................................................16

Smog Alerts........................................................................26

Smoking .............................................................................28

Specifications.....................................................................13

Spill Kit................................................................................6

Sports Medical Clearance ..................................................26

Standing Water...................................................................31

Storage...............................................................................14

Storage.................................................................................7

Storage - Method..................................................................8

Storage Cabinets ..................................................................6

Storage Container.................................................................9

Storage Supplies and Equipment .........................................8
Safe School Inspection Guidebook 38

Revised 07/01/04

Storage Temperature............................................................8

Storage- Volatiles.................................................................8

Storm Drain........................................................................15

Student Access.....................................................................5

Student Drop-off and Pick-up Points.................................33

Summary Page ...................................................................23

Supervision...........................................................................4

Supervision.........................................................................33

Supplies..............................................................................15

Supplies and Equipment.......................................................9

Team.............................................................................34, 35

Toe Boards.........................................................................17

Traffic and Pedestrian Safety.............................................33

Traffic Hazard ....................................................................30

Training..........................................3, 5, 9, 13, 14, 18, 23, 34

Training - General..............................................................24

Training and Education......................................................33

Transportation Noise..........................................................21

Trash/Debris.......................................................................30

Trip Hazards.......................................................................19

Trouble Calls......................................................................14

UL Approved .....................................................................25

Unlawful Activity ..............................................................30

Use - General.....................................................................25

Use – In Series ...................................................................25

Use – Near Water...............................................................25

Use – On Metal..................................................................25

Use – Through Opening.....................................................25

Use of Prohibited Chemicals................................................5

Vandalism Reporting ...........................................................4

Vehicle Idling.....................................................................20

Vehicle Parking....................................................................4

Ventilation......................................................................7, 15

Violence Prevention.....................................................34–35

Visitation Policy...................................................................4

Visitor’s Pass........................................................................4

Walkways...........................................................................19

Warning Labels ....................................................................3

Warning Signs................................................................3, 31

Wastewater Management...................................................15

Water Damage....................................................................20

Weeds.................................................................................11

Wheel Chocks....................................................................11
Environmental Health Conditions in California’s Portable Classrooms

VI - I

APPENDIX VI

WORKING DRAFT SUGGESTIONS

FOR PREVENTIVE AND REMEDIAL ACTIONS
Environmental Health Conditions in California’s Portable Classrooms

VI - 2

WORKING DRAFT SUGGESTIONS

FOR PREVENTIVE AND REMEDIAL ACTIONS

The list below provides additional, more detailed suggestions for preventing and remedying IEQ

problems in schools. It is based on information from various sources, including school district

staff who participated in public workshops during this project, consultants, state agency staff,

and others. This list is a draft working document. Further comments are welcomed and can be

sent to ARB at tphillip@arb.ca.gov or capcs@arb.ca.gov. A School Advisory Fact Sheet

compiled by ARB for California schools, school districts, consultants, and others, dated April,

2004, is available at http://www.arb.ca.gov/research/health/school/pcsfact.pdf. That fact sheet

and the information below may be updated from time to time by ARB on the ARB website.

October 2003 Guidance

GENERAL

1. For new school design or retrofits, also see CHPS Best Practices Manual sections on siting,

materials selection, and ventilation (www.chps.net) and EPA’s Design Tools for Schools

(http://www.epa.gov/iaq/schooldesign/).

2. Apply for financial assistance through local utility programs and the California Energy

Commission (see AB 549 program for energy efficiency in existing buildings,

http://www.energy.ca.gov/ab549/index.html).

3. Set up communication and tracking system for reporting IEQ problems immediately and

ensuring their resolution. The Los Angeles USD database program for tracking

environmental health complaints is available at no cost.

4. Educate teachers, maintenance staff, custodial staff, and administrative staff on the causes

and prevention of poor IEQ. EPA’s IAQ Tools for Schools, a free package, can help

accomplish this (http://www.epa.gov/iaq/schools/).

5. Identify asthmatics and other individuals who are more sensitive to indoor air pollution, and

work with the local American Lung Association to reduce pollutant and allergen exposures at

school and at home (http://www.lungusa.org/events/astopen.html.)

6. Design or modify building to allow easy access and clearance for maintenance and

inspection, including HVAC systems, crawlspaces, and plumbing systems.

VENTILATION AND AIR CLEANING

1. Meet Cal OSHA regulations, Sec. 5142, which require provision of constant ventilation at a

rate specified in the building design, as well as annual inspection, maintenance, and record

keeping (http://www.dir.ca.gov/title8/5142.html).

2. Ensure constant supply of outdoor air and pre-occupancy flushing, per CEC Title 24

regulations and Cal/OSHA regulations.

3. Conduct annual cleaning and inspection of HVAC: dampers, drains, flow imbalance, coils,

filters, ductwork, etc. (see EPA Tools for Schools).

4. Assure thermal comfort (T & RH, drafts) through annual inspections and testing.

5. Improve user-friendliness of control systems; educate teachers on use of timers and post

simple instructions.

6. Consider separate, low-noise exhaust ventilation systems for providing constant ventilation

when the central system is inefficient or too noisy. Include air intakes in locations away from

outdoor pollutant sources. Design the systems and measure indoor-outdoor pressure
Environmental Health Conditions in California’s Portable Classrooms

VI - 3

differences to avoid excessive depressurization, which can cause problems due to

increased transport of radon, soil gas, pesticides, odors, and moisture into the room from

the soil, crawl spaces, and adjoining spaces.

7. During high humidity conditions (warm and wet or muggy, and high occupant load), reduce

residual indoor moisture by running HVAC or dehumidifier after classes for an hour or two,

as needed. This may also be needed during school vacations (especially in climate zones

with high humidity), and during the first year in new classrooms built with a significant

amount of wood materials.

8. Avoid the use of ozone-generating air cleaners in enclosed areas

(http://www.arb.ca.gov/research/indoor/acdsumm.pdf).

NOISE

1. Specify low-noise, low-vibration HVAC systems (new and retrofit), e.g., systems with baffles,

vibration dampers, insulation, etc.

2. Specify windows, doors, and other building components with low-noise transmission

characteristics, wherever possible.

3. Test and demonstrate low-noise, low-vibration HVAC systems; track long-term performance.

MOISTURE

1. After leaks, spills, and flooding, dry the rooms thoroughly within 24 hours. Use heating and

floor fans if necessary. For more information on IAQ and repairing flood damage safely and

effectively, see http://www.epa.gov/iaq/pubs/flood.html.

2. Repair leaks immediately, to avoid major damage later. Moisture meters can be used to find

damp areas of building. Infrared cameras may be available on loan from utilities to identify

less accessible leak locations.

3. Inspect EPDM and metal roofs annually for tears, leaks, interior condensation, and

degradation.

4. Inspect buildings, especially roofs, gutters, and crawlspaces, before each wet season, and

after every heavy rain.

5. Specify at least 6 inch flashing and mastic sealant around roof HVAC units, a common

source of water leakage. Inspect routinely.

6. Test condensate drain pan routinely: pour 1 cup of water in pan, check for flow at end of

drain line and for any standing water left in pan.

7. Specify and verify proper siting, drainage, and pad with concrete or asphalt surface or a

plastic vapor barrier. Add drainage features to site if necessary.

8. Specify and verify effective crawlspace ventilation area and location:

-- Sufficient ventilation area per building code.

-- Non-louvered vents

-- Proper location – avoid corners, stagnant areas, and close spacing between vents.

9. Do not drain the roof and HVAC to the surface near the building; route to sub-surface drains,

or if necessary, at least several feet away from building in area with permeable soil and a

slope away from building.

10. Inspect roof gutters for proper drainage.

11. Specify portable skirt height at least 6 inches above ground, preferably higher, to avoid

wicking and improve ventilation; avoid wood or other absorbent material for skirting.

12. Do not allow sprinklers to hit buildings or drain next to or under building.

13. Specify adequate flashing for roofs, walls, windows, and doors, and specify adequate roof

overhangs.

14. Avoid carpet in areas with the potential for high moisture such as areas with sinks,

entrances, coatrooms, etc.
Environmental Health Conditions in California’s Portable Classrooms

VI - 4

15. Specify and verify low moisture content in building materials such as wood, concrete, and

wallboard. Protect these materials from moisture and dust before and during installation.

16. Avoid cold spots in building shell (insulation gaps, thermal bridges) through better QC at

factory, and by commissioning (infrared camera).

17. Avoid flat roofs. Add slope to roofs during retrofits, if possible.

18. Use moisture resistant materials in subfloor (e.g., if wood product, should be exterior grade.)

VOCs, INCLUDING FORMALDEHYDE AND OTHER ALDEHYDES

1. Specify low- or non-emitting building materials and furnishings, including items after original

installation, such as cabinetry. Have manufacturers confirm emission rates.

2. Follow ARB-DHS recommendations for reducing indoor formaldehyde levels (see Appendix

IV).

3. Control emissions from remodeling and construction through isolation and negative pressure

(exhaust ventilation).

4. Select low-emitting carpets and glues; air out the carpet before installation; flush out the

room during and after installation and before occupancy; ensure constant ventilation before

and during occupied periods.

5. Caulks and sealants: apply during school vacations, flush out after installation.

6. Ensure that teachers do not use or store products or materials that can be significant

sources of indoor pollutants, such as room deodorizers, cleaning products, pressed wood,

candles, pesticides, hair spray, aromatherapy oils, etc.

7. Program the HVAC controls for daily pre-occupancy flush, per CEC ventilation standard.

PARTICULATE MATTER AND FLOOR DUST

1. Place ground cover on open soil.

2. Include walk-off mats inside and outside of each classroom.

3. Upgrade HVAC filters & frequent replacement; seal leaks/bypasses around filters.

4. Perform daily vacuuming, sweeping, and dusting.

5. Dust with damp mops and cloths.

6. Vacuum with efficient vacuum cleaners that capture more of the dust (see Consumer

Reports).

7. Consider hard flooring with washable area and runner rugs.

8. Provide covered storage containers for teaching supplies.

LIGHTING

1. Encourage daylighting.

2. Replace old ballasts with new high-efficiency, low-noise ballasts.

3. Add solar shades and/or awnings to reduce glare and heat load.

4. Assure illumination level and quality are sufficient. Refer to IESNA standards for

classrooms.

BIOLOGICAL POLLUTANTS

1. Do not keep animal pets in classrooms for extended periods, especially furry mammals,

reptiles, and turtles.

2. Plant trees and bushes that produce little or no allergens (see American Lung Association

and local allergists; see example at the Tulare School District,

http://www.visaliatimesdelta.com/news/stories/20030630/localnews/568385.html; and ARB

Research Division, Biogenic Research, http://www.arb.ca.gov/research/ecosys/ecosys.htm).