## 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 GovernorENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

i 

## ACKNOWLEDGEMENTS

We are particularly grateful to the many sc hool 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 Du st Analysis Panel, who provided helpful suggestions concerning the analyses of the floor dust samples: Martha Harnly and Janet Macher (Department of Health Services), My rto 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 Boar d; Sandra McNeel, Department of Health Services; Carol Shellenberger and Rich Sheffiel d, 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 school s 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 Sco tt 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

ii • 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

iii 

## 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 t he 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 elect ronically on ARB’s website at: http://www.arb.ca.gov/r esearch/indoor/pcs/pcs.htmENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

iv 

### 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 R ESOURCES 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, DirectorENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

v 

## 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, Envi ronmental Health Laboratory Branch, DHS Raymond Richard Neutra, M.D., Dr.P.H., Chie f, Environmental & Occupational Disease Control Division, DHSENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

vi 

## TABLE OF CONTENTS

DISCLAIM ER .................................................................................................................. iii ACRONYMS .................................................................................................................viii ABBREVIATIONS A ND SYMBOL S................................................................................. x GLOSSARY OF TERMS.................................................................................................xi EXECUTIVE SU MMARY................................................................................................. 1 1. INTRODUC TION.................................................................................................. 24

1.1 Mandate and Need fo r the St udy.................................................................... 24 1.2 Definition of Po rtable Classr ooms .................................................................. 25 1.3 Purpose and Scope of the Study .................................................................... 25 1.4 Stakeholder Pa rticipat ion................................................................................ 26 2. BACKGRO UND.................................................................................................... 28

2.1 Indoor Environmental Conditions and Potential Heal th 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 Contami nants ................................................................... 31 2.3.2 Ventilation and Comfor t............................................................................ 32 2.3.3 Noise an d Lightin g.................................................................................... 32 2.3.4 Mol d.......................................................................................................... 33 2.4 Design and Construction of Portable Cl assrooms.......................................... 35 2.4.1 State Relocatabl e Classroom Program .................................................... 36 2.4.2 California Coll aborative for High Pe rformance Schools ............................ 37 2.4.3 U.S. EPA IAQ Design Tools for Schools .................................................. 38 2.4.4 State Workgroup on Re locatable Cl assrooms.......................................... 38 2.4.5 Innovative Desi gn Initiati ves..................................................................... 38 2.4.6 Portable Classroom Manufactu rers .......................................................... 39 2.4.7 LAO Blueprint for School Facility Finance ................................................ 39 2.5 School Operation and Main tenance (O&M) Pr actices .................................... 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 School s ................................................................................... 42 2.5.4 Integrated Pest Management (I PM) ......................................................... 43 2.5.5 School-based Asthma Management Program .......................................... 43 2.5.6 Statewide Organizati ons........................................................................... 44 3. STUDY METHODS AND RESU LTS .................................................................... 45

3.1 Met hods.......................................................................................................... 45 3.1.1 Phas e I ..................................................................................................... 46 3.1.2 Phas e II .................................................................................................... 46 3.2 Resul ts ........................................................................................................... 48 3.2.1 Classroom and School Characteri stics..................................................... 48 3.2.2 Building Materials and Ot her Pollutant Sources ....................................... 48 3.2.3 Environmental Problems .......................................................................... 49 3.2.4 Building Operat ion and Main tenance ....................................................... 49 3.2.5 Classroom V entilatio n............................................................................... 50 3.2.6 Air Pollutant Measurem ents ..................................................................... 53ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

vii 3.2.7 Floor Dust Contami nants.......................................................................... 59 3.2.8 Moistur e and Mo ld.................................................................................... 64 3.2.9 Pol len ....................................................................................................... 67 3.2.10 No ise ........................................................................................................ 68 3.2.11 Light ing..................................................................................................... 68 3.2.12 Specially Sele cted Classr ooms ................................................................ 69 3.3 Summary of Result s ....................................................................................... 69 4. RELATED STUDIES IN CALIFORNIA SC HOOLS............................................... 71 5. INFORMATION FROM OTHER ST ATES ............................................................ 75 6. SUMMARY OF STAKE HOLDER IN PUT.............................................................. 76

6.1 Pre-Study Works hops .................................................................................... 76 6.2 Post-Study Works hops................................................................................... 77 7. RECOMMENDATIONS AN D DISCU SSION ........................................................ 78 8. SUMMARY AND CO NCLUSION S ....................................................................... 84

8.1 Resul ts ........................................................................................................... 84 8.2 Recomm endations ......................................................................................... 86 8.3 Conclu sions.................................................................................................... 87 REFERENCE S.............................................................................................................. 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 fo r Preventive and Remedial Actions........VI-1



### LIST OF TABLES

Table 2-1. Selected Guide lines and Standards Relevant to School Environments. ..... 34 Table 3-1. Study Desi gn, Phases I and II. .................................................................... 45 Table 3-2. Phase II, Summary of Environmental Measurem ents. ............................... 47 Table 3-3. Percent of classrooms with cert ain building characteristics, Phase I. ......... 48 Table 3-4. Percent of classrooms with env ironmental problems r eported 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 C oncentrations, Phas e I and II. ................................ 54 Table 3-8. Percent of Classrooms with Moisture Indicato rs, Phase II. ......................... 65 Table 3-9. National Concentration Guidelin es for Outdoor Airborne Mold Spores and Plant Po llen* ....................................................................................................... 67 Table 3-10. Classroom Noise and Light ing Conditions Ex ceeding St andards.............. 68 Table 3-11. Summary of Contaminant Lev els in Air and Floor Dust, Phase II.............. 70ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

viii 

## 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 Heat ing, Refrigerating, and Airconditioning Engineers CAASA California Asthma Among the School-Aged Cal/EPA California Envir onmental 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 Coll aborative for High Performance Schools CIWMB California Integrat ed Waste Management Board CLPPP Childhood Lead Poison ing 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 Architec t, 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 OfficeENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

ix LAUSD Los Angeles Unified School District LEED TM 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 Environm ental Health Hazard Assessment OPSC Office of Public School Cons truction, Californi a 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 Rem ediation 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 Envi ronmental Protection Agency VOC Volatile Organic Compound, Volatile Organic Chemical WHO World Health OrganizationENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

x 

## ABBREVIATIONS AND SYMBOLS

TERM DEFINITION

o C degrees Celsius cfm cubic feet per minute CFU colony forming unit

cm 2 square centimeter CO carbon monoxide CO 2 carbon dioxide dBA decibel (referenced to 1 ampere)

o F degrees Fahrenheit kg kilogram (one thousand grams) l/min. liters per minute (flow rate)

m 2 square meter

m 3 cubic meter μg microgram (one-millionth of a gram) μg/g micrograms per gr am (concentration) μg/cm 2 micrograms per square cent imeter (surface area) μg/m 3 micrograms per cubic meter (concentration) mg milligrams (one-t housandth of a gram) mg/kg milligrams per kilogram (concentration) ml milliliter (one-m illionth of a liter) ng nanogram (one-billi onth of a gram) ng/g nanograms per gram (concentration) No. number % percent pCi/l picoCurie per liter PM2.5 Particulate matter with aerodynam ic diameter less than 2.5 microns PM10 Particulate matter with aerodynam ic diameter less than 10 microns ppb parts per billion (such as one grai n of sand in a billion grains of sand) ppm parts per million (such as one grai n of sand in a million grains of sand) § section T temperatureENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

xi 

## 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 move s into a space. Expressed in units of air changes per hour or cubic feet per minute.

Air Handling Unit HVAC (heating, ventilati on 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 f ilters. Does not include ductwork, registers, or grille s, or boilers and chillers.

Allergen A chemical or biologica l 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) enfor ceable 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 ar e 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 dis eases, and infectious diseases. Also referred to as biological agents.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

xii Comfort measures Factors that determi ne human perception of thermal comfort, including temperature, rela tive humidity, and draft

Dampers Controls that vary airflow through an air outlet, inlet, or duct. A damper may be immovable, manua lly adjustable, or part of an automated control system.

Detection Limit Limit of detection, t he 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 la ck chlorophyll, including molds, mildews, yeasts, mushrooms.

Integrated Pest An ecosystem-based st rategy 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 prov ided 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 exposur e. None of these limits are targeted toward protecting children.

Pesticides A pesticide is any subs tance 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. UnderENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

xiii 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 hydr ogen. 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 ar e designed and constructed to be moveable and transportable over public streets, also known as temporary or relocatable classrooms.

Quality Control (QC) Internal checks on t he 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 o ften as every minute, every second, or in fractions of a second.

Reference Exposure The concentration le vel 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 t he medical and toxicological literature for the populati on 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 aut omatically 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 moistu re 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

xiv Sick Building Syndrome A set of symptom s (including headache, fatigue, and eye irritation) typically affecting wo rkers in modern airtight office buildings, believed to be caused by indoor pollutants (such as formaldehyde fumes or microorganisms).

Stratified Random A study approach in wh ich the study samples are selected Sampling randomly from each of several, previously determined subgroups (strata) of the tar get 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, a ll 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 pe rmanent, site-built school buildings.

Variable Air Volume Air handling system that conditions the air to a System temperature using a varyi ng 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, maint enance, 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 ar e 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 es timates for the entire population being studied.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

1 

## EXECUTIVE SUMMARY

INTRODUCTION
The California Portable Classrooms Study was a comprehensive study of environmental health conditions in California’s public schoo l classrooms. It was conducted jointly by the Air Resources Board (ARB) and the Departm ent of Health Services (DHS) at the request of Governor Gray Davis and the St ate 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 sc hools, especially portable classrooms, might not provide healthful environments for student s or teachers. These concerns were based on the potential for mold contamination, inadequate ventilati on, poor temperature control, elevated levels of volatile chem icals, and excessive use of some pesticides. The study was funded to help understand t he 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 pr ovide 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 over view of the study, summarizes conditions identified in the study t hat 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 bas ed on the study results, findings from the scientific literature, and input provided by state agencies, sc hool districts, consultants, manufacturers, and interested stakeholders.

PURPOSE AND SCOPE OF STUDY

The purpose of the California Po rtable Classrooms Study was to:

• Conduct a comprehensive study and review of the environmental health conditions in portable classrooms.

• Identify any potentially unhealthful envir onmental conditions, and their extent.

• In consultation with stakeholders, i dentify 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 ma intenance 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 bu ilding materials and furnishings, and other mitigation actions needed to assure protection of children’s health.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

2 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, formal dehyde sampling tubes were sent to about two-thirds of the schools, for deployment in the three classroom s. In Phase II, comprehensive chemical, biological, and env ironmental measurem ents were obtained in 201 classrooms at 67 schools randomly sele cted statewide. As in Phase I, two portable classrooms and one traditional cl assroom were studied at each school.

The State contracted with Research Triangle In stitute (RTI), a not-f or-profit scientific research organization, to conduct the primary field work of the study for both Phase I and Phase II. ARB’s Research Screening Commi ttee, an external scientific peer review group that assures the quality of research funded by the AR B, 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 partici pation, while DHS conduct ed a preliminary survey of school districts, analyzed dust samples fo r allergens, and reviewed the biological sampling protocols conducted by RTI and the re lated results. Both agencies were fully involved in project oversight, review of t he results, and preparati on 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 t he Department of Education, the Department of General Services (including the Divisi on of the State Architect and the Office of Public School Construction), the Office of Environment al 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 comp letion of the final research report from RTI. Stakeholder input was obt ained through comment periods and through several public workshops conducted both prio r to the study and upon completion of the draft report.

BACKGROUND

A “portable classroom” is defined as “a classr oom building of one or more stories that is designed and constructed to be relocatabl e and transportable over public streets...” (California Education Code, §17070.15[k]). Portable classroom s 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 12 th grade (K-12) public school classrooms in the 2000-ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

3 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

4 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 lowe r first-cost than tr aditional, site-built buildings. These features allow schools great flexibility in meeting fluctuating enrollment levels. In the late 1990s, the availabili ty of portable classrooms enabled the state to achieve class size reductions aimed at impr oving 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 Sc hool 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, al ong with a revised formula for financing, based on per-pupil grants.

Health and Economic Impacts

In recent years, concerns have risen am ong teachers, parents, and the public regarding potential health risks at schools, especially a ssociated with portable classrooms. The concerns have focused on immediate health comp laints such as eye irritation, allergies, asthma, headache, and fatigue, as well as the carcinogenic, neurologic, and other risks of chronic exposures to air toxics, su ch as formaldehyde, lead, and pesticides. Chemical contaminants and biological ag ents, along with other indoor environmental problems in the classroom, have fr equently 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 withi n the confines of school buildings over a period of years. Thus, ensuring healthful cond itions inside classrooms is a critical factor in both teachers’ and students’ health and perf ormance. Both groups may suffer the detrimental effects of poor environmental conditions; however, children generally are more vulnerable than adults to env ironmental contaminants and injury.

Asthma is among the most significant health problems associated with poor indoor environmental quality (IEQ) in schools. Asth ma is a chronic disease of lung tissue involving inflamed airways and an increased s ensitivity 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 Califor nia 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 m any known asthma triggers – airborne particulate matter, chemical contami nants, and allergens such as dust mites, cockroaches, mold spores, and animal dander.

Poor environmental conditions in schools c an also affect school productivity and student performance. The available evidence suggests that IEQ pr oblems, such as low outdoor air ventilation rates and insufficient ligh t, may reduce the performance of building occupants, such as students in schools.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

5 An economic analysis of the costs of the im pacts of poor IEQ on the educational sector has not been conducted. However, it is esti mated 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 es timate only accounts for the impacts on teachers and school staff; it omits analogous effects on productivity and performance among the many more students s haring the school environment.

In addition to the benefits of improved heal th and productivity, properly maintained buildings prove to be more cost-efficient, because fewer resources are needed under prevention-oriented programs t han 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 subj ect 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 regulati ons relevant to schools as workplaces: California Code of Regulation (CCR) Title 8 § 3362 requires that workplaces be maintained in a sanitary condition, and subsec tion (g) requires that all types of water intrusion be avoided, and remedied when leaka ge occurs. Cal/OSHA also enforces the implementation of the Injury and Illne ss Prevention Program required under § 3203, which requires development of a plan and tr aining 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 r equired to be met, and those that are in regulation are often not well enforced.

♦ Ventilation Requirements for heating, ventilating, and air condit ioning (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 build ings; for classrooms, this is 15 cubic feet per minute (cfm) per per son or 0.15 cfm per square f oot, whichever is greater.

• Cal/OSHA (CCR Title 8) enforces an HVAC standard for workplaces that requires that ventilation systems be operated and ma intained to supply at least the minimum amount of outside air that was r equired at the time the system was last permitted.

• The American Society of Heating, Refr igerating, and Air Conditioning Engineers (ASHRAE) provides profe ssional guidance on minimum ventilation rates based largely on human health and comfort. Wh ile not regulatory, ASHRAE Standards, specifically Standard 62, Ventilation for Acceptable Indoor Air Quality, is anENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

6 important reference for California’s v entilation 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 guid ance on thermal comfort, which can be a complex function of season, occupant activity, cl othing, air movement, and other factors.

• ASHRAE’s acceptable temperature r ange is 68-75°F in the heating season and 73-79°F in the cooling season under typi cal humidity and airf low 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 worker s in the work environment, and outdoor air quality standards and guidelines set to protec t the general public. However, none of these are targeted toward protecting child ren, and only worker exposure levels are required to be met within school settings.

• Permissible Exposure Levels (PELs), dev eloped 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 st andards (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 ens ure that they are protecti ve 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 ha rm 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 ma y 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 OE HHA can be used to judge potential cancer risk.

♦ Noise Voluntary standards and guidelines for cl assroom noise have only recently been developed.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

7 • The American National Standards In stitute (ANSI) and the World Health Organization (WHO) recommend 35 decibels (dBA) as a limit for background classroom noise.

• The California Collaborative for Hi gh Performance Schools (CHPS) set the maximum noise level for unoccupied cla ssrooms 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 fo r 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 allowabl e lead level is 250 micrograms per square foot for interior window sills. Thes e standards are based on surface wipe samples and were developed for the protec tion of the most susceptible group, children under 6 years of age.

Design and Construction of Portable Classrooms

Portable classrooms used thr oughout California are typicall y 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 ar e 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 Californi a, including portable classrooms, must comply with the Californi a 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, wa ter-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-che ck focuses on three areas: the structural design (i.e., seismic safety), handicap a ccessibility (i.e., compliance with the Americans with Disability Ac t and related standards), and fire & life safety concernsENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

8 (e.g., sprinklers, fire ala rms). DSA also certifies inspectors, which schools are required to hire to oversee on-site sc hool construction and portable manufacture.

♦ The Office of Public School Constructi on (OPSC) administers state appropriations for public school facilities construction and modernization, leasing of relocatable classrooms, and funding fo r deferred maintenance. OPSC purchases and maintains a set of portable classroom units as part of the State Relocatable Classroom Program. This program was initially es tablished 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. Cu rrent costs for a portable classroom range from about $25,000 to $47,000; district s 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 me tal 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 fluoresc ent type with photoelectric control.

State Relocatable Classrooms have always met or exceeded construction codes in effect at the time of appr oval. Additionally, they comply with ASHRAE standards for temperature control.

OPSC also has taken, and plans to take, other steps to improv e the state portable classroom specifications for their im pact on indoor environmental quality. For example, all adhesives used for carpet or rubber baseboard in stallation 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 cont ain no detectable formaldehyde. They are also considering several options fo r quieting noisy ventilation systems.

OPSC is currently developing several re locatable classroom guides for schools that lease relocatables through the State Program. The guidebooks will provide information to custodians, maintenance st aff, 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 Ma intenance Program (DMF), which provides funding to school districts for major repairs and upgrades, such as new roofs andENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 devel opment or have been proposed. Some new programs were begun either bef ore 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 distri cts 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 stat ewide to begin new construction and modernization projects. New bond f unding will reduce the need for portable classrooms in California schools, and w here the need remains, will provide funding to replace aged portable classrooms with cla ssrooms that meet high environmental and health standards. The remaining $13 bill ion bond is scheduled to go before the voters on the March 2004 primary ballot.

♦ The Los Angeles Unified Scho ol 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 fi rst round of inspections, LAUSD officials determined that many of the basic probl ems 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 blo cked 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 chemic als and implementing an Illness and Injury Prevention Program, which also are han dled by school personnel. LAUSD has developed a detailed tracking system to assure that problems identified are addressed. LAUSD’s “Safe School Inspecti on Guidebook,” a checklist, is provided in Appendix V, and can serve as a good star ting 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 Schoo ls (CHPS) is a consortium of public agencies and energy utilities in California working to facilitate the design and construction of “high performance” school s. These schools serve as models of energy and resource efficiency, as well as provide a healthy and comfortable environment conducive to the learning proce ss. The core of CHPS is a set of BestENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

10 Practices Manuals that provides an array of opt ions for improved school planning and design. This approach allo ws school boards to declare their intentions to build high performance schools, despite a lack of explicit kno wledge of specific components. The CHPS criteria give faci lity designers latitude to incorporate practices in a manner that best fits t he district’s needs and budget. Only a very small percentage of Califor nia 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 im pact 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 progr am, and 11% of California schools reported that they use all or par t 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 sc hools in California have successfully implemented the program and demons trated 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. T he 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 re viewing and developing revisions to the State specifications for portable classr ooms 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 Occupati onal 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 (primar ily 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 Depar tment of Pesticide Regulation (DPR) to promote voluntary school IPM programs. IPM incl udes the use of non-chemical practices to reduce pest populations, using least toxic pes ticides to treat infestations above designated thresholds, and training releva nt individuals regarding IPM approaches. The Act also directed schools to comply with certain requirements to reduceENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 appl y pesticides at schools. Meeting these requirements is the responsibility of i ndividual 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 se veral 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 responsibilit y through an accountability program; and

• Transition funding to address current unmet facility needs.

Because school facilities are such a substant ial investment and it is the responsibility of the districts to ensure their maximum us eful life, the LAO felt that facilities maintenance funding would be more effici ent if there were greater local accountability. The LAO suggested that "d istricts 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 m eet their maintenance needs." The LAO recommendations would le ad 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 t he “target” study population, wh ich was defined as all public schools in California with at least one port able 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 stat ewide. For each school, the facility manager and three teachers (two from port able classrooms and one from a traditional classroom) were asked to complete deta iled questionnaires on all aspects of the classrooms. Additionally, formaldehyde samplin g tubes were sent to about two-thirds of the schools, for deployment in the three cl assrooms. In Phase II, a comprehensive suite of chemical, biological, and environ mental measurements were obtained in 201 classrooms at 67 schools statewide. Sim ilar to Phase I, two portable classrooms and one traditional classroom were studied at each school. Quality control checks were performed for field and laboratory measurem ents, and for entry of questionnaire and inspection data.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 requi re a combination of actions by the State, school districts, individual schools, manufactu rers, and others. Many of the solutions are relatively low-cost. For example, improved operation and ma intenance would go a long way to address many of the problems ident ified. Similarly, routine use of no- or low-emitting building and classroom material s 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. T he primary results include the following:

Ventilation

• In both types of classrooms, the am ount 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 (c arbon dioxide levels exceeded 2000 ppm). This is a critical finding; this latter group clearly did not m eet state ventilation requirements for continued outdoor ai r, and such deficiencies have been associated with increased eye and throat irritation, lethargy, headache, and other symptoms that can impair the lear ning process and reduce performance.

• 60% of teachers in portables indicated t hey 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 tradi tionals, including higher rates of dirty air filters (40% vs. 27%), blocked out door air dampers (11% vs. 3%), and poor condensate drainage (59% vs. 12%) which can lead to microbial contamination.

Overall, the HVAC systems delivered adeq uate 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 usua lly result from the H VAC 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 addi tion, operation and maintenance of HVAC systems needs to be improved at many schools; training of facility staff and teachers should be undertaken and regular inspecti on and maintenance programs followed to avoid larger problems that can result when ventilation systems are not properly operated and maintained.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 tradi tionals experienced temperatures below ASHRAE’s thermal comfort standards for t he heating season. Some classrooms of both types also experienced temperatur es above the ASHRAE standard range for acceptable indoor temperat ure 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) expos ed to formaldehyde levels that could potentially result in irritant effects.  Levels in virtually all classrooms exce eded OEHHA’s chronic REL (1.3 ppb) for irritant effects and OEHHA’s one-in-a-mil lion excess lifetime cancer risk level (0.13 ppb) for formaldehyde. However, levels of formaldehyde in homes and offices virtually always exceed these le vels as well, and it is generally not feasible to achieve levels below thes e 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 CALIFORN IA’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 befor e they reach relatively low levels.  Alternative low- and no-emitting materi als 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 t han those in other indoor environments.  Levels were below acute (imm ediate effects) risk levels.  Some classrooms would exceed the one-in-a -million excess lifetime cancer risk level for benzene and chloroform if t he 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 em issions 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 usua lly 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 loadi ng docks. Portables often are sited with their ventilation units and air in takes 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 CALIFORN IA’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 t hat cannot otherwis e be obtained with a routine air sample. Metals, pesticides, polycyclic aromatic hydrocarbons (PAHs, a group of semi-volatile organic compounds em itted during combustion processes, many of which are known or suspected carci nogens), 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 chip s from old paint indoors or outdoors.  Arsenic levels were slightly higher in portables; more importantly, levels in both types of classrooms appeared to exceed typi cal levels found in California soils. Arsenic is a natural soil contaminant, and the primary source would be soil trackin. The elevated levels indicate po ssible 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 rec ent 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 duri ng 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 portabl e 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 be low 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 CALIFORN IA’S PORTABLE CLASSROOMS

16 Moisture and Mold

• In the Phase I mail survey, 69% of t he teachers reported sm elling 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 fl oor. Excess moisture was measured as material moisture content above leve ls 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 mois ture in building materials often indicate hidden mold, and at a minimum indicate a mois ture problem such as a leak that needs to be remedied. Any mold present in a cl assroom or its wall vo ids, flooring or plenum should be properly remediated, since mold can trigger allergy symptoms and asthma attacks in individuals with those sensitivit ies. Proper remediation may range from scrubbing a small area with detergent and water to following procedures also used for asbestos remediation. In all cases, t he 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 CALIFORN IA’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 cla ssrooms (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. Ca lifornia 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 classr ooms do not meet IESNA prof essional design guidelines of 50 foot-candles for low contrast materi als, and a small percentage of classrooms do not meet the guideline of 30 foot-candles for high contrast materials.

• Portable classrooms had somewhat lo wer lighting levels than traditional classrooms.

Lighting was inadequate in onethird of the classrooms. Daylighting is best with proper design and location, but can lead toglare and shadows if not welldesigned.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 st udents. 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 problem s identified in this study can be addressed through meeting existing State standards and guidelines (pri marily those of Cal/OSHA), including requirements to provide continuous out door air exchange; improved operation and maintenance programs; and focused traini ng 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 fo r 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 guidelin es and standards for school environmental health.

Each specific recommendation below suppor ts one or more of these over-arching approaches. The specific recommendat ions are presented in two groups:

Group 1 : includes actions that are high priority and would yield high benefits at relatively low cost. These recomm endations 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 r equire four to five years to implement fully.

Group 1: High Priority, High Benefi t Actions, with Relatively Low Cost

Group 1 recommendations build largely on regul ations, programs and activities that are already in place but that are not fully met or utilized.

1. Meet State Regulations. Schools, districts, and the st ate should assure that all school buildings meet all re levant State regulations, particularly those related toENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

19 operation and maintenance. Many classr ooms do not meet various existing State standards, and meeting those regulations would go far to provide healthful conditions in classrooms. For exampl e, 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 Inju ry and Illness Prevention Program regulation; and maintaining s anitary conditions and correcting water intrusion, leakage, and uncontrolled accumula tion 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 classr ooms. To achieve this, many districts may need to increase their maintenance sta ffing: many district s 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 t he 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 LAUS D. In addition to assessing whether state regulations are being met, self-inspections can also be used to remedy obvious problems that are not necessarily regul ated, and as a first step to begin to incorporate “Best Practices” into operat ion 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-t hroughs and identify key problems in the near term. Conditions that can be corrected wit h little or no cost should be remedied promptly. Plans should be developed to obtain resources to address those that require additional funds to remedy; fo r 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 di scussed above. The U.S. EPA’s IAQ Tools for Schools Kit provides guidance for developing such a plan: see http://www.epa.gov/iaq/scho o ls/ . Visalia, Sau g us, Clovis, and S a n 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 prev entive operation and maintenanc e 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 fr esheners”, should not be brought into the classroom.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

20 e. Implement procurement policies and practices for classroom furnishings and supplies that assure good indoor air qual ity, 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 t he design, construction, operation, and maintenance of new California schools, es pecially 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 ti me, 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 sch ools 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.chp s .net/ ; manuals f o r 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 si tuation. Additionally, specific recommendations gleaned from this study and from st akeholders’ input, are inclu ded in Appendix VI. Key examples are: a. Specify no- and low-emi tting building materials and furnishings in construction contracts and solicitations. This s hould include using exterior grade wood products or other low-emitting materi als 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 revi ew for new buildings and major renovations should be expanded. Re view and approval of elements such as ventilation system design and building ma terials should be added to the routine structural, fire and life-safety, and accessibi lity plan-check function of the Division of the State Architect (DSA). The DSA is curr ently initiating specification revisions and implementing a more proactive approach in pl an reviews, but additional trained staff are needed for the additional work. DSA and O PSC 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 pr oper grading. Individual portable classrooms should not be placed over low drainage areas that experience flooding. The foundation skirt should be at least si x inches or more above ground level to prevent wicking of water up the wall, and adequate crawlspace vent ilation should be specified. Some of these measures may not be low cost for some schools.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 time frame. The current year-t o-year fluctuation of the existing Deferred Maintenance Program does not provide stable, consistent funding for long-term planning and preventive ma intenance. Implem entation 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 organizati ons. Those who are closest to the classroom are often not aware of curr ent “best practices” for operation and maintenance of classrooms. For example, teachers inadvertently bring pollutant sources into the room, improper ly adjust thermostats, or ta ke other actions that can have a major impact on the environmental c onditions 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-te rm 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 devel op training programs and materials in consultation with ARB, DHS, CEC, Cal /OSHA, and other relevant agencies, as well as CASBO, CASH, and other relevant ex ternal groups. These should include: a. A Training and Certific ation Program for School Facility Managers. Success in operation and maintenance is oft en a function of the strength and knowledge of facilities directors, yet there are few credentials districts can apply in their selection of key facilit y department personnel. Districts should hire trained, certified facility managers. b. Development and routine di stribution of training materials for custodial staff on proper vacuuming and cleaning pr ocedures. Effective vacuuming of carpets requires an efficient vacuum pl us a reasonable “residence time” of the vacuum on the carpet surface in order to effectively remove particles. This can effectively reduce persistent c ontaminants 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 exhaus t. Additionally, use of “safe" liquid or spray cleaning products is a key component of a healthy building.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 r equirements for schools to notify parents of pesticide use and to consider IPM. Successful application of IPM has been sufficiently widespread to support its impl ementation at all public schools, and to eliminate the use of pestici des with the greatest potential for toxic effects by school personnel. A program of preventive housek eeping 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 port ables are well past the stage at which they should have been replaced with a new portabl e 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-e fficient, 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, light ing, 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 St ate’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 st andard for K-12 schools. If needed, promote technology development to meet such a guideline or standard.

15. Develop State-level chemical expos ure 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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 des igns 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 Laborat ory, and several portable classroom manufacturers have begun to develop very different styles of relocatable classrooms which use an integrated, “whole-build ing” approach. These should be fully developed and used on a trial basis under differ ent conditions to determine if these newer designs might better m eet future classroom needs.

Implementation of some of the recommendations above will cl early incur costs to those involved, and will require fiscal planning to achi eve. However, the cost of not taking these actions appears high – potentially harmf ul impacts on children’s and teachers’ health, reduced learning, reduced educational progress, and, in some cases, higher costs to fix facility problems when they bec ome more serious. Most importantly, State building, ventilation, and workplace regul ations have been developed to assure safety and health, and must be met.

The LAUSD’s self-inspection program has s hown 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 ava ilable 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 we re identified in this study. These include a variety of problems, su ch as inadequate design, operation, and maintenance of ventilation systems; contami nants present at undesirable levels in the air and floor dust; excessive noise levels; inadequate lighting; and mold and moisture problems. A number of program s 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 mu st be done to assure that existing problems are remedied and future problems prevented. The State, school districts, school administrators, school facilit y 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 im portantly, California needs to transition from a focus on remedi ation to a focus on prevention.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

24 

## 1. INTRODUCTION

The Air Resources Board (ARB) and the Departm ent of Health Services (DHS) jointly conducted a study of environmental health conditions in Ca lifornia’s portable classrooms from 2000-03. This study, call ed the California Port able Classrooms Study, is the most comprehensive study of envir onmental conditions in kindergarten through 12 th grade (K-12) classrooms to date, and prov ides important information for State and local decision makers working to assure a safe, healthful, and productive learning environment for California children. This r eport 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 cla ssrooms. The information presented in this report is based on the study results, as we ll as information provided by state agencies, school districts, consultant s, 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 unac ceptable levels of problems such as mold contamination, inad equate ventilation, poor tem perature 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 problem s and whether they warranted st ate-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 A ppendix II). Portable classrooms are more quickly constructed and deployed to school site s. 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 c an 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 th e 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 classroom s. This requirement was imposed as a cost-saving measure, with the expectation t hat districts would move classrooms rather than build new ones as student demographi cs 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 Pr oposition 1A, this restriction was lifted,ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

25 and school districts were given greater flexib ility 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 stor ies that is designed and constructed to be relocatable and transportable over public st reets, and with respect to a single story portable classroom, is designed and construct ed 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 fee t.” Portable classrooms also are often referred to as relocatable classrooms, and occur in a variety of styles and forms. However, “modular” classrooms, which typi cally have some elements constructed offsite, may be either permanent structures or movable, and thus are not necessarily synonymous with the terms “por table” or “relocatable”.

1.3 Purpose and Scope of the Study

The objectives of the California Po rtable Classrooms Study were to:

• Conduct a comprehensive study and review of the environmental health conditions in portable classrooms.

• Identify any potentially unhealthful envir onmental conditions, and their extent.

• In consultation with stakeholders, i dentify 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 toxi c contamination including mold and other biological contaminants. Recommendations were to be developed to address the need for modified design and construction standards, em ission limits for building materials and furnishings, and other mitigation actions nee ded 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 cla ssrooms and one from a traditional classroom) were asked to complete detailed questionna ires 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 obtaine d in 201 classrooms at 67 schools randomly selected statewide. Simila r to Phase I, two portable classrooms and one traditional classroom were studied.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

26 The State contracted with Research Triangle In stitute (RTI), a not-f or-profit scientific research organization, through a competitivel y 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; formatti ng, 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 distri cts; conducted all on-site sampling and inspections; analyzed the samples collect ed; and prepared a final study report. ARB directed the field contract, air monitori ng, and data analysis; obt ained equipment used in the study; pre-tested the passive formaldehy de samplers used in Phase I; coordinated the stakeholder participation; and contributed funds for analysis of classroom carpet dust, a known reservoir for persistent cont aminants such as pesticides and metals. DHS developed and administered a preliminary survey of districts to obtain key information on the numbers and ages of portabl es in each district; directed the school and classroom sampling approach and t he assessment of ventilation systems; performed allergen analyses in the laborator y; 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 ex ternal 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 proposal s 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 re sults 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/r esearch/indoor/pcs/pcs.htm or upon request.

1.4 Stakeholder Participation

As directed in HSC § 39619.6, ARB and DH S 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 t he Department of Education (CDE), the Department of General Services (DGS; primarily the Divis ion of the State Architect [DSA] and the Office of Public School Construction [OPSC ]), the Office of Environmental Health Hazard Assessment (OEHHA), and other in terested state agencies prior to the study regarding the overall study design and detailed information to be obtained, and upon completion of the final re search report from RTI.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

27 Four public workshops were hel d 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 obtai ned 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 nor thern and southern California, were also held during the review period for the public dr aft of this document. The first workshop was webcast, and all workshops included tele phone accessibility, so that the public could participate without being physically pr esent at the workshops. Many useful comments were received, and the report was modified as appropriate. Some of the information received highlighted new produc ts that are low- or no-emitting.

Summaries of the comments received during both sets of workshops are provided in Section 6 of this report.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

28 

## 2. BACKGROUND

California public schools house more than si x million children in kindergarten through 12 th grade, close to 300,000 teachers, thous ands of administrators and support staff, plus countless parent and community visitors on a daily basis. Many of these individuals spend a considerable portion of t heir time for years within the confines of school buildings. School i ndoor environmental conditions – temperature, humidity, ventilation, lighting, noise, cleanliness, odor , and exposures to chemical contaminants and biological agents – can affect both t he 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 am ong teachers, parents, and the public regarding potential health risks at schools, especially a ssociated with portable classrooms. The concerns have focused on health complaints, similar to “sick building syndrome” or SBS (more currently called “building -related symptoms: allergies, ey e 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 respir atory symptoms, to the perc eption of poor indoor air quality, such as bothersome odors, to pat ent 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 det rimental effects of poor environmental conditions; however, children are far mo re 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. Asth ma is a chronic disease of lung tissue involving inflamed airways and an increased s ensitivity to contaminants in the air. Notably, the prevalence rate in the U.S. increased 74% from 1980 to 1995 (CDC, 2002). Disproportionately higher ra tes 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, c hemicals, 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). Cu rrently, about 10% of California’s children suffer from asthma (CHIS, 2003), with t he highest prevalence found among 12-17 year olds.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

29 Exposure to mold growth has been associated with worsening of asthma, allergies, and eye, nose or throat inflammation. Howe ver, health-based criteria for evaluating exposures to the spores, cell components, or chemical emissions from indoor mold growth are not currently available. Nume rous studies have found that indicators of excess moisture such as musty odor and visibl e 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 recent ly published, which ident ified limitations in conclusive data; however, the available evi dence suggests that IEQ problems, such as low ventilation rate and less daylight or li ght, may reduce the performance of occupants, including students in schoo ls (Heath & Mendell, 2002).

An economic analysis has not been done spec ifically 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 y ear (1996 dollars). Fisk’s results, scaled to California educators, indicates that accr ued 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 mo re students sharing the school environment.

Improved IEQ in schools can reduce asthma-re lated medical cost (e.g., emergency room visits and hospitalization) for childr en 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 inst alled. Students with exacerbated asthma suffer chronic school absences, which can caus e delays in academic progress. At the same time, school districts suffer an econom ic 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 co mfort parameters (tem perature, relative humidity, light, noise, and odor), a study of school lighting has produced the most striking results. Researchers investigat ing lighting in an Orange County (CA) school district determined that increas ing/greater daylighti ng (natural light, such as that through windows) improved learning rates (He schong 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 CALIFORN IA’S PORTABLE CLASSROOMS

30 In addition to the benefits of improved heal th and productivity, properly maintained buildings prove to be more cost-efficient, because fewer resources are needed under prevention-oriented programs t han 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 a llowed 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 subj ect to codes and regulations (see next section), there are few spec ific 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 (Departm ent of Industrial Relations, Division of Occupational Safety & Health) enforces t he 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 Titl e 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 accumula tion of water, in order to prevent mold growth. The State Education Code also establ ishes that it is the duty of the governing (school) board to furnish, maintain, and repai r school facilities (Education Code Section 17565 et seq.).

Cal/OSHA also enforces Title 8, Secti on 3203, the Injury and Illness Prevention Program regulation, that r equires employers to develop, implement, and maintain a health and safety program that includes per iodic 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 dev eloped 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) prov ides a summary listing of the standards and guidelines discussed below.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

31 2.3.1 Environment al Contaminants

In general, PELs are usually much higher t han indoor contaminant levels found in nonindustrial settings, and Cal/OSHA rarely finds PEL violations in schools (exceptions may include chemical laborator ies and industrial arts cla ssrooms). However, these standards are likely insufficient to protect vulnerable school occupants such as pregnant teachers. School personnel include more vu lnerable sub-populati ons than the “healthy worker”, such as adults with chronic condi tions, 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 out door concentrations of traditi onal pollutants to protect public health. These standards for outdoor ai r 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 mo re stringent than the federal NAAQS. With Calif ornia Senate Bill 25 (SB 25, the Children’s Environmental Protection Act), existing California ambien t air standards are being reviewed to ensure that children and infants are protect ed (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/res earch/indoor/guidelines.htm

. OEHHA has developed and published Reference Exposure Limits (R EL) 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 pub lic 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, wh ile 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 occu r. OEHHA’s RELs may be viewed at http://www.oehha.ca.gov/air/a cute_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 toxi n 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 ar e 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

32 In the absence of a regulator y standard for indoor radon, a vo luntary 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 Portabl e 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, v entilation and air conditioning (HVAC) of schools are determined primarily by the California Energy Commission (CEC) and Cal/OSHA. Design requirements for outdoor air ventilati on rates in public and commercial buildngs, including schools, are specified in the Ca lifornia Building Standards Code (CCR Title 24, §121). Although CEC’s focus in regul ating HVAC performance is on energy efficiency, minimum design levels ar e specified to assure sufficient outdoor air for specific indoor environments. For the typica l classroom, the greater of 15 cubic feet per minute (cfm) per person or 0.15 cfm per squar e foot, is required; for special purpose classrooms such as laboratories or aut o shops, higher ventilation rates may be required. While CEC’s standards address equipment design, Cal/OSHA’s mechanical ventilation standard (CCR Title 8, §5142) addr esses HVAC operation and maintenance in workplaces. That standard require s 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 sys tem was last permitted. It also requires at least annual inspection of the HVAC syste m(s), and that maintenance records for the HVAC system(s) be kept and be avail able during a Cal/OSHA inspection.

Non-regulatory guidelines exist for HVAC systems in school settings. The American Society of Heating, Refrigerating, and Air Conditioning E ngineers’ 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 int ended as a health standard, ASHRAE Standard 62 has been historically adopted into stat e 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 appendice s, Standard 62 continues to serve as the most explicit guideline available t hat 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 AS HRAE, and serve as target values in the absence of government standards. The Amer ican National Standards Institute (ANSI, a non-government standard-setting organization) and the World Health OrganizationENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

33 (WHO) have established a standard and guideline, respectively, of 35 decibels (dBA) for background noise levels in (unoccupied) classroom s. This is a controversial noise limit, as it is not easily met in standard classr oom 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 enc ourages designers to move beyond these minimum prerequisites and achieve backgr ound noise levels of 35 dBA for all classrooms. The ANSI and WHO reco mmendation for other indoor (non-school) settings is 45 dBA, and the outdoor community standard used in many cities is 55 dBA.

For lighting, the Illumi nating Engineering Society of North America (IESNA) recommends lighting illumination levels for various kinds of visual tasks involving materials with different print sizes and of hi gh or low contrast. The California Energy Code dictates the amount of lighting power (e lectricity) 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 facilit y 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, Or tiz, 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 ri sk (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 fo r identification of mold, visible or hidden in an indoor environment, and for the remedi ation of mold. Despite the absence of PELs or numeric standards, practical gui dance has been developed for assessment and clean-up procedures of indoor mold cont amination (e.g., NYC DOH, 2000; U.S. EPA, 2001b).

Several guidance documents hav e 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 Bu ildings" in March 2001. This document presents approaches for the assessment and re mediation/cleanup of mold and moistureENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

34 Table 2-1. Selected Guidelines and St andards 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 ft 2

, 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): CO 2 below 1000 ppm, or CO 2 [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/ft 2 ) on bare floor or carpet; 250 μg/ft 2 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)ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

35 problems in schools, including measures designed to protect the health of building occupants and clean-up staff. It was des igned primarily for building managers and custodians. Also published in 2001, the Minnesota Department of Health developed “Recommended Best Practices for Mold Inve stigations 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 Qua lity Coordinators, facilities and maintenance personnel, health and safety staff, and other sc hool officials. Both documents counsel school officials to make reasonable judgment s 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: 12x 40 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 y ears, designs with a concrete wall as well as two-stories have become more common. Most importantly, num erous improvements have been made in roofing, siding, windows, heat ing and air conditioning, lighting, and insulation.

General requirements for school facilities are gi ven 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 pub lic school facility construction within the State of California, includ ing portable classrooms, must comply with the California Building Standards Code. This code is cont ained in Title 24 of the California Codes of Regulation (CCR). The Stat e 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, li ghting systems, and heating, ventilation and air conditioning (HVAC) systems. The Depar tment of General Services (DGS) oversees the design and construction of educational fac ilities. The Office of Public School Construction (OPSC) within DGS administers t he State funding of public school facilities construction and modernization, relocatabl e (portable) classrooms, and deferred maintenance.

The Division of the State Architect (DSA) wit hin DGS is responsible for reviewing design plans and construction for new school fa cilities, additions, alterations, and modernization projects, including portable classrooms. Although the building design plans and the California Buil ding Standards Code address all aspects of the school design and construction, the DSA plan che ck 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 & lifeENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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 district s 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 t he fire & life safety components, provided the classrooms will be duplicates of previous ly 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 Progr am, the OPSC has purchased and maintains a set of approximately 6000 portable classr oom 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 emergencie s. The State purchases about 200 new portables per year, on average. Funding fo r 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 in spect the unit, make necessary repairs (charged to the former lessee), and generally dep loy the unit to another district in need fairly quickly. In addition to the annual leas e, school districts are responsible for the costs of installation, including site preparation and utility hook-up.

With DSA assistance, DGS issues bid specif ications for contractors each time OPSC purchases units for the State program. Depending on funding, OPSC will issue a contract to build several hundred classroom s. The DGS specifications are for the “basic” classroom (DGS, 2000), and these oft en 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 s pecifications to assure that they meet or exceed Title 24 requirements. Current OPSC specificati ons 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 me tal 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 fluoresc ent type with photoelectric control.

State Relocatable Classrooms have always met or exceeded construction codes in effect at the time of appr oval. Additionally, they comply with ASHRAE standards for temperature control.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

37 OPSC also has taken and/or plans to take other steps to improv e the state portable classroom specifications for their impact on indoor environmental qual ity. 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 test ed 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 Constructi on (OPSC) is currently developing several relocatable classroom guides for school distri cts that lease State relocatables through the State Relocatable Classroom Program administered by the OPSC. The OPSC anticipates that these guidebo oks will be distributed in t he next several months to custodians, teachers, and maintenance staff in a ll school districts in California. These guidebooks will provide districts with informati on to assist in ensuring that classrooms are properly maintained, and wi ll 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 deliver ed to a site, as well as OPSC staff will distribute during its routine in spections of these classrooms.

OPSC also administers the Deferred Ma intenance 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 fo r 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 perform ance 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 audienc e (U.S. DOE, 2003). In addition to its publications, CHPS provides on going training to school facility staff, architects, and engineers.

CHPS developed their own gradi ng criteria using a point system, similar to the U.S. Green Building Council’s Leadership in E nergy & Environmental Design (LEEDTM) scoring (U.S. Green Building Council, 2003). This approach allows school boards toENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

38 declare their intentions to build high per formance schools, despite a lack of explicit knowledge of specify components. The CHPS scoring gives facility designers latitude to incorporate practices in t he manner that best fits the district’s app lication. CHPS has helped secure funding for a number of demons tration projects throughout the state. Several school districts, notably Los Angel es 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 informati on resources for designing new school facilities and repairing existing facilities. Its primary focus is on IAQ. It also develops the concept of designing High Performanc e Schools, using an integrated, "whole building" approach to addressing each of t he 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 recent ly to identify opportunities to implement Governor Davis’ sustainable building goals with respect to portable classrooms. This subgroup is part of the interdepartmen tal Sustainable Building Task Force ( http://www.ciwmb.ca.gov/GreenBuilding/TaskForce/ ) comprised of representatives from more than 40 state agencies with fiscal, c onstruction, energy, health, and environmental policy expertise. It was formed after Ex ecutive 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 spec ifications for relocatable classrooms with respect to sustainability goals, including enhanced IAQ, and pursuing a variety of projects focused on addressing concerns regar ding 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 des ign. SCE funded a demonstration project incor porating ideas from the 1998 workshop (SCE, 1998). A follow-up workshop was conducted in Ap ril 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 investi gating both low VOC-emitting materials and novel HVACENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

39 system design, to reduce chemical source s and increase classroom ventilation rates (Apte, 2002). Starting in mid-2003, CEC anticipates funding several projects on classroom ventilation technology for K-12 sc hools, including applications for portable classrooms (CEC, 2003).

2.4.6 Portable Classroom Manufacturers

The School Facility Manufacturers' Associ ation (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 impor ted 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; cons equently, many of these manufacturers also build products for a variet y 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 cla ssroom and commercial factory-built structure industry.

In 1999, California manufacturers of port able classrooms were sued under Proposition 65 by “As You Sow” for alleged exposures to formaldehyde above the “Safe Harbor” limits. The manufacturers disputed the clai ms of the lawsuit, but in 2002 the parties reached a settlement under the di rection of the State Attor ney General’s Office. The manufacturers agreed to minimize the us e of particleboard (a common construction material that contains formaldehyde). Particleboard does not meet the structural requirements of DSA, and ther efore is infrequently used in portable classrooms except in cabinetry. Many manufacturers also hav e 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 unpredict able, 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 "blueprin t" for more effectively financing new school construction and modernization:

• More predictable state funding by annual ap propriations 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 CALIFORN IA’S PORTABLE CLASSROOMS

40 • More local control and responsibilit y through an accountability program; and

• Transition funding to address current unmet facility needs.

Because school facilities are such a substant ial 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 wa s greater local accountability. The LAO suggested that "districts should set aside a prescribed annual cont ribution 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 ma intaining 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 ad equate funding, properly trained facility maintenance staff, and administrative support to keep school facilities in good condition. The required activities include the daily j anitorial services, routine inspection and maintenance of facilities including its s ubcomponents (e.g., HVAC systems, building envelope, landscaping, etc.), and planning for major repairs and modernization needs. Daily janitorial and routine maintenance serv ices are funded from t he general budget for school operations.

There is a relatively wide range in the se rvices supported among districts, reflecting their relative wealth and commi tment to O&M as a priority. Not surprisingly, budget cuts most often reduce facility main tenance programs first, as a way to “keep cuts out of the classroom”. Thus, during lean times, main tenance suffers disproportionately. Major repairs and modernization needs are funded separ ately from routine activities in most school districts. Districts apply to OPS C’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 Scho ol District’s (LAUSD) Facility Inspection Program is a broad self-assessment of all district classr ooms 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 custodi ans 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 safe ty 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 Pr evention Plan, which also are handled by school personnel. Problems requiring experi enced specialists from the main districtENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

41 office or from the private sector cost mo re 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 che cklists, is provided in Appendix V, and can serve as a good starting point for other di stricts 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 feder al legislation on IAQ, this voluntary program provides schools wit h 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 modul ar components for use in starting a program at a school or throughout a district. T he self-contained IAQ management plan contains materials and tools, such as occupant check lists, 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 ki ts available at no cost to schools across the U.S., and has funded numer ous training workshops.

In California, U.S. EPA has trained more t han 2000 individuals from districts throughout the state. Despite the outr each, awareness and use of the IAQ Tools for Schools program among California schools is still re latively low: based on the Phase I survey data from this study, 35% of distri ct facility staff were aware of IAQ Tools for Schools

, and 11% of districts use all or part of t he 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-intensiv e; (2) lack of understanding that poor indoor environmental quality affects both health and pr oductivity, 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 im plemented by many schools and districts throughout California. Most not ably, Saugus Union School District, which previously experienced tremendous comm unity concerns regarding hazards in classrooms, is an EPA Tools for Schools Excellence Award Winner and a model for other districts. Visalia Unified School Dist rict has become a model for the cost-effective treatment of mold problem s through its program, and San Francisco Unified School District has developed their program by utiliz ing groups such as the PTA and the United Educators of San Francisco, in light of understaffed custodial and maintenance levels. Fresno Unified School Distric t and the Fresno Teachers Asso ciation, with assistance from U.S. EPA, are working jointly to im plement the program th roughout its 95 schools.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

42 At Northgate High School in the Mt. Di ablo Unified School District, U.S. EPA is facilitating a pilot project in which the sc hool’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 ot her states. In the west, a pilot study was developed in the states of Washingt on 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 practica l and action-oriented, and the assistance of an unbiased and qualified expert is m ade available to give on-site guidance, training, and resources (Prill et al. , 2002).

California Assembly Concurrent Resolu tion No. 75 (Chan), enrolled in June 2003, recognizes the significance of school i ndoor environments to the childhood asthma problem, and “encourages California sc hool 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 regulat ed (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 Pr ogram, CLPPP and the state Department of Education. The program pr ovides training, focused documents, and a hotline aimed at school maintenance staff. The joint proj ect has conducted 81 training programs around the state for school maint enance 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, E scutia, 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 stat e 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 CALIFORN IA’S PORTABLE CLASSROOMS

43 2.5.4 Integrated Pe st 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 indivi duals regarding IPM approaches. The Act also directed schools to comply with certain requi rements to reduce exposures to pesticide at schools, such as parental notificati on 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 t he 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% report ed 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 notificati on), and 49% of school districts were fully compliant. Nonetheless, the Act does not expl icitly require that schools alter their pest management program with respect to which pesti cides are used. A survey by a public interest group identified that while dist rict 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 Asth ma Management Program

As concern about the increase of childhoo d 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 c onvenient contact point to provide information and aid in medical management for the di sease. The U.S. EPA (2002a) provides resources and information on their web site Managing Asthma in the School Environment . The American Lung Associ ation 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 CALIFORN IA’S PORTABLE CLASSROOMS

44 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, c onsultants, and vendors ( http://www.cashnet.org /). CASH’s Maintenance Network focuses on strengtheni ng maintenance efforts statewide and increasing public and legislative awareness and funding for school maintenance issues. The California Association of School Bu siness Officers (CASBO) represents the group of school officials most directly involv ed in making O&M policy decisions: Chief Financial Officers and operations managers ( http://www.casbo.org/ ). CASBO makes recommendations about staff and budget needs fo r 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 practi ces or minimum funding levels for school districts. CASBO has rec ently 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 CALIFORN IA’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, Phas e II, field technicians inspected classrooms and obtained numerous environm ental measurements from October 2001 through February 2002. In both phases, three cla ssrooms (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 c ontractor 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, wh ich 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 Calif ornia Public School Director y 2000 (CDE, 2002). A preliminary mail survey of all public K-12 school distri cts 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-rela ted 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 (ur ban, suburban, or rural). The study data were weighted to adjust for th is stratification, and for unequal response rates in certain categories, thereby providing a representative estimate fo r 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 Questionnaires Building 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 CALIFORN IA’S PORTABLE CLASSROOMS

46 3.1.1 Phase I

Two questionnaires, a Facilities Questi onnaire and a Teacher Questionnaire, were created collaboratively by ARB and DHS. The questionnaires were based on questionnaires from other studies, on gui dance documents, and on information obtained during public workshops held across the stat e. The questionnaires were used during both study phases to obtain information from facility managers and teachers about classroom characteristics and the environment al quality conditions and complaints at the sampled schools. The Facility Questionnaire provided school -level and classroom

level information on the physical conditi ons, operation, and maintenance of building facilities and grounds for 384 schools statewi de. The Teacher Questionnaire provided classroom -level information, such as the pres ence 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 cons ultation with the manufacturer, developed protocols that achieved impr oved sensitivity and precision. These samplers have been widely used in previous mail survey studi es, 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 wit h 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 exte riors, and recorded measurements of air flows, noise levels, lighting levels, and moistu re content of the interior walls, floor, and ceiling. The field technicians also collec ted 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 testi ng, 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 measurement s 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 (hi gh complaints of environmental problems orENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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

CO 2 (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 dete rmine whether classrooms with apparent or reported problems actually had serious environmental problems.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

48 3.2 Results

Results from Phase I and II are discu ssed below. When portable and traditional classrooms are compared, the re sults are given as “portable vs. traditional.” The term “all classrooms” refers to the total of a ll portable and traditional (permanent) classrooms combined. When results are compared among portable, traditional , and all classrooms, the results are weighted to provide the st atewide estimates. When the results are characterized as statistically significan t, 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 classr ooms 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 traditi onal classrooms were used this way.

The schools were mostly suburban schools (74%) and mostly elementary schools (59%). Only about 29% of the schools we re 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 tr aditional classrooms had air-conditioning.

3.2.2 Building Materials and Other Pollutant Sources

As shown in Table 3-3
, portable classrooms were r eported more frequently than traditional classrooms to have carpeted floor s, 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 72ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 (T able 3-4). Teacher complaints of air quality (stuffy air and musty odors) and noise we re 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 t hat 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 portabl e classrooms (60%) reported that they turn off the HVAC system due to high noise leve ls, an activity that had previously been reported anecdotally and in other studies. Th is behavior was reported significantly less often for traditional classrooms (23%).

Table 3-4. Percent of classrooms with environm ental 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 r eported 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 t he 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 setti ng, condensate drain pan, and coils; it is not clear if this maintenance was done by cont ractors instead. About half of the schools (57%) swept, vacuumed, and dusted the cl assrooms five days a week; most other schools did so several times a week.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 fac ility 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 tradi tional 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 teac her (45% vs. 27%). These factors may help explain why teachers in traditional classr ooms more frequently complained that the rooms were too warm.

“Natural ventilation” from open doors and wi ndows can sometimes help remove indoor pollutants from classrooms, if the wind speed, direction, temperature differences, and cross-flow patterns are suffi cient. More portables t han traditionals had windows that open (87% vs. 66%), but the fr actions of teachers reporti ng 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 mu ch higher prevalence of wall units in portables may help explain why portable classroom HVAC systems have better access for maintenance compared to traditional cla ssrooms, 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 27ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 envir onmental quality, such as:

• Closed outdoor air dampers result in insufficient outdoor air ventilation.

• Malfunctioning or blocked condensate drai ns 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 Ther mal Comfort Measurements

CO 2 Levels

. Carbon dioxide (CO 2 ) levels were measured continuously throughout the day as an indicator of building ventilation sufficiency. Indoor CO 2 levels reflect the CO 2 exhaled by building occu pants and the outdoor air CO 2 levels. Indoor levels typically are higher than outdoor levels, but substantially elevated in door levels result from insufficient outdoor air ventilation of t he classroom. Groups such as ASHRAE and Health Canada have recommended that indoor CO 2 levels not exceed 800-1200 ppm, depending on outdoor CO 2 levels; the 2005 California Energy Code for certain types of ventilation systems requires that CO 2 levels not exceed 1000 ppm (CEC, 2003).

Average CO 2 levels in portable classrooms were 1064 ppm; traditional classrooms were not significantly different (Table 3-6). Outdoor CO 2 levels were typically about 425 ppm over the day, with short-term peaks over 650 ppm. Indoor CO 2 levels were elevated over 1000 and 2000 ppm for a substantial portion of the day, indicating that nearly halfENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

52 the classroom hours have inadequate or marginal ventilation, and that about 10% of the classroom hours clearly hav e inadequate ventilation.

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

Classroom Type Mean Indoor CO 2 (ppm) Mean Outdoor CO 2 (ppm) Mean % of Class Hours @ CO 2 > 1000 ppm Mean % of Class Hours @ CO 2 > 2000 ppm Outdoor Air Flow

(mean cfm/ft 2 )

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 cla ssroom ventilation is typica lly 15 cfm of outdoor air per person, or 0.15 cfm/ft 2 , whichever is greater. Nearly all classrooms had outdoor air flow capacities greater than 0.15 cfm/ft 2 . When the air flow capac ity was expressed in cfm per chair in the classroom (a surrogat e for cfm/person), about 10-20% of the classrooms had HVAC systems with outdoor ai rflow capacities of less than 15 cfm per chair.

The airflow measurements were also expre ssed per square foot of floor area. The typical portable classroom is ~1000 ft 2 and houses between 20 and 35 persons. The standard of 15 cfm/person conver ts to a required outdoor airf low rate of 300 to 525 cfm (or 0.3 to 0.5 cfm/ft 2 ). Flow rate measurements i ndicated 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 port ables had higher flow rates per square foot of floor area (see Table 3-6).

Most HVAC systems were capable of deliv ering adequate outside air and total airflow when operated properly, but a small percent age of classrooms may have inadequate flow for maximum occupancies, due to im proper system design. The stuffy air complaints by teachers can result from inadequate outdoor airflo w capacity, but they probably result most often fr om improper operati on 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 syst em 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 CALIFORN IA’S PORTABLE CLASSROOMS

53 Thermal Comfort. HVAC systems should not only provid e healthful indoor air quality but also provide a comfortable therma l environment. Temperature levels were significantly different, with 27% portable and 17% traditional classrooms experiencing levels cooler than ASHRAE thermal comfor t 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 par t of the day; such levels are not only uncomfortable, but can lead to increased mo isture and mold problems, increased dust mite populations (allergy and asthma trigger s), and other problems. About 11% of both types of classrooms had RH levels below 30%, which can lead to dry mucous membranes and increased susceptibilit y 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, meas ured 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 estima tes 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/m 3 (OEHHA, 1992). Clearly students and teachers do not spend their entire life in cla ssrooms, but the conc entrations 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 c ancer risks from indoor exposures may be somewhat lessened for those pollutants that off-gas from building materials over time. The measured levels of pollu tants 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 samp les. 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 formald ehyde 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 Chroni c 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 CALIFORN IA’S PORTABLE CLASSROOMS

54 Indoor concentrations were routinely elevat ed 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 form aldehyde: 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 95 th percentile concentrations were notably higher in Phase I, and higher for portables co mpared 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 weat her when indoor formaldehyde levels are usually higher, and because the sample size was substantially larger, increasing the probability of including classroom s 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 i ndoor 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 le vels 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 CALIFORN IA’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 leve ls 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 ca se per million persons (ARB, 2002). These results indicate that a small but substant ial percentage of classrooms have levels that may cause short-term irritant effects, and that nearly a ll classrooms (like other indoor environments) have formaldehyde levels that may cause long-term irritation and contribute to cancer risk.

Modeling results showed that several fact ors were associated with elevated indoor formaldehyde levels, in cluding the following:

• Composite wood products in building ma terials or furnishings, including plywood and particleboard, and pressed wood bookca ses and cabinets, all of which can emit large amounts of formaldehyde.

• Temperature and humidity, which affe ct the emission rate of formaldehyde.

• Classroom age, which reflects the o ff-gassing of formaldehyde sources over time. (Formaldehyde typically off-gasses from building materials over a 3-5 year period, so newer classrooms general ly have higher emission rates).

Formaldehyde sources include new cabinets, doors, bookcases, and other pressed wood materials. Thesematerials generally offgas over the first several years.

Because new materials containing formal dehyde generally off-gas over time, older classrooms (both portable and traditional) gener ally 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 s ources often are brought into classrooms. Sources can also include permanent press clothing, cosmetics, various art andENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

56 classroom supplies, and a variety of cons umer products, as well as new bookshelves and furnishings added to older classrooms. Guidance for reducing and preventing elevated formaldehyde levels in cla ssrooms 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 resp iratory tract irrita tion, while long-term exposure can affect the upper airway, red bl ood cells, kidneys, and growth (ARB, 1993). OEHHA (2000) has established a chronic RE L 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. Ac etaldehyde 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 por table 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. Tradi tional classrooms had s lightly lower indoor levels of acetaldehyde. Factors contributi ng to indoor levels included those identified for formaldehyde, except that outdoor air conc entration 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 m easurements exceeded this gu ideline. Nearly all classrooms and outdoor concentrations ex ceeded 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 m easured above their detection limits in 80% of the samples. The other tw o were detected in at least 50% of the samples. As in most indoor air quality studies, the meas ured indoor VOC concentrations were higher than those observed outdoors. Average indoor classroom concentrations ranged from a high of 6 : g/m 3 for toluene (slightly less for m,p -xylene) to less than 0.5 : g/m 3 for chloroform. For all others, the av erages were in the range of 1 to 2 : g/m 3

.

Benzene. Benzene is a carcinogen; ARB (1984) has identified it as a Toxic Air Contaminant. Short-term exposure to benz ene can cause mild irritation. Long-term exposure can reduce the numbers of bl ood cells, platelets, and immune systemENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

57 components in the blood. OEHHA has established an Acute REL of 1300 : g/m 3 for 6-hour exposures, and a Chronic REL of 60 : g/m 3 (OEHHA, 2000; 2002).

Indoor benzene concentrations in portable classrooms averaged 1.3 : g/m 3 , with a 95 th percentile value of 3 : g/m 3 . Outdoor levels of benzene averaged 1.75 : g/m 3 , while the 95 th percentile value was 3 : g/m 3 . In traditional classroom s, the mean was similar to that of portables, but the 95 th percentile value was higher at 4.6 : g/m 3 . Modeling results showed that indoor air benzene concent rations were associated with outdoor concentrations, and suggested that the presenc e of carpet and outdoor activities such as construction might contribute.

These results indicate that classroom le vels 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/m 3 , 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 i ndoor and outdoor levels, schools should be carefully sited and operated to minimize ex posure 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 vaporizat ion 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 affe ct the liver and kidneys. OEHHA (2000, 2002) has established an Acute REL of 150 : g/m 3 for a 7-hour exposure, and a Chronic REL of 300 : g/m 3

.

Indoor chloroform concentrations in portable classrooms averaged 0.30 : g/m 3 in portables and 0.48 : g/m 3 in traditional classrooms. The 90 th percentile values were lower in portables (0.42 vs. 0.91 : g/m 3 ). Outdoor levels of chloroform averaged 0.45 : g/m 3 , while the 90 th percentile value was over 1.12 : g/m 3 . Modeling results showed that indoor air chloroform concentrations were associated primarily with outdoor concentrations, and to some extent with tem perature, 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 haz ards. However, about 75% of the outdoor and indoor concentrations were above 0.19 : g/m 3 , 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 primar y source of indoor chloroform levels; thus, schools should be carefully sited and oper ated to minimize exposure to outdoor emissions of chloroform. In addition, us e of cleaning products containing bleach should be minimized, and indoor areas of heavy tap water use should be well ventilated.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

58 3.2.6.3 Particle Counts

Real time counts of particulate matter we re measured in each classroom and outdoors. It should be noted that particle counts c annot be directly associated with mass concentration standards. However, the measur ements 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 port able 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 i ndoor 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 parti cle sources. In this study, over 50% of portable and traditional classrooms were lo cated within 50 feet of parking lots and roadways. Portables usually have wall-m ounted rather than roof-mounted HVAC units, and are sometimes sited with their air handli ng units near roadways and parking lots for security reasons, which could lead to incr eased particle infiltration into those rooms. Recent research (Sioutas et al. , 2003) has shown dramatically higher levels of fine particles very near roadways. Other likel y sources of particles (and VOCs and other pollutants) include portable eq uipment such as leaf blowers and lawn mowers used for landscape maintenance. In addition, carpet s 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 chemic al 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 CALIFORN IA’S PORTABLE CLASSROOMS

59 3.2.7 Floor Dust Contaminants

Some persistent (long-lived) environmental c ontaminants can accumulate in floor dust over time. This is especially a concern fo r younger children who spend time on the floor and can be exposed to the dust contami nants by hand-to-mouth contact and skin contact, and by inhalation of resuspended floo r 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 provi des 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 t he rooms’ main foot traffic area was vacuumed with a hand-held vacuum c ontaining a filter. Dust contaminants were expressed as concentrations ( : g/g, micrograms per gram of dust) and as loading ( : g per cm 2 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 fl oor dust can be compar ed to the Preliminary Remediation Guidelines (PRGs) for resi dential 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 CALIFORN IA’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 l ead, 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 sample s that would merit further analyses, only limited statistical comparison of floor dust re sults 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/cm 2 , micrograms per square c entimeter 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 lo adings showed a significant difference – portables were significantly higher. This difference may be due to the presence of arsenic-treated structural wood and playgr ound 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 95 th 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 forcompliance 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 childr en 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 child ren 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 collect ed from the carpets does indicate the presence of lead-containing dust.

A DHS (1998) study of lead in California’s public elementary sc hools found that 7% of schools had lead levels in soil exceedi ng 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 Sc hool District have found t hat 34% of pre-1993ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

61 schools had environmental lead def iciencies, 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 cont aminate soil that is tracked into classrooms, and it can be re leased and spread in older buildings during repairs and remodeling. However, because carpet s are often fairly old, it is not possible to determine whether lead found in dust sample s was recently or historically introduced into the classroom. These results s uggest that some portable and traditional classrooms may require remediation to remo ve lead, especially where younger students or women of childbear ing 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 cert ain pesticides and contaminated fertilizer and perhaps treated wood. The California Depar tment 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 95 th percentile value was 19 ppm for portables, and 15 ppm for traditional classrooms. In comparis on, 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 95 th percentile values for arsenic in agricultural soils are about two-thir ds 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 CALIFORN IA’S PORTABLE CLASSROOMS

62 3.2.7.2 Pesticides in Floor Dust

Exposure to pesticides in sufficient quantitie s 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 m easured: organochlori ne, 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 cl assrooms at each school were combined for analysis due to cost constraints. Thus, t here were two samples from each school, one containing dust from two portables and one c ontaining dust from a single traditional. Pesticide residues were found in all floor dus t samples, indicating the widespread use of a variety of different products in or near cl assrooms. Six of the 20 pesticides measured were detected in over 80% of the sa mples: esfenvalerate, chlorpyrifos, cis - and trans

permethrin, o-phenylphenol, and piperonyl butox ide. Three others–diazinon, 4,4,’DDE, and propoxur–were measured in over 50% of the samples.

At the 95 th percentile, nine of the pesticides we re 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 signi ficant differences in the mean levels in portable and traditional samples. Many of the pesticides had median loading levels less than 0.01 ng/cm 2 (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/cm 2 ). No statistically significant differences between the means for the portable sample s and traditional classrooms were found for either the concentration results or the loadi ng 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 samp ling period at some schools in 2001-02.

As expected, some very persistent pes ticides 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 slow ly decreasing after the bans, because the pesticides can persist in soils and dust for several years.

• Chlorpyrifos is an organophosphate inse cticide 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 sour ces of DDE include soil, atmospheric dispersion, sediment runoff, contami nated 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 CALIFORN IA’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 preser ve wood, control termites, and control locusts and mosquitoes. Most uses of di eldrin were banned in 1987. Environmental sources of dieldrin include soil surrounding wooden structures tr eated for termites; soil or sediment; improper use or dispos al; contaminated fish and shellfish; and contaminated dairy products and meat.

Since the discontinuation of ch lorpyrifos, 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 per sistent than chlorpyrifos in dust and soils with a half-life of 30 to 38 days. Esfenvalerate is equally s hort-lived in the environment. Many of the pyrethroid-containing insecticid es 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, so rghum, and wheat). Measurable le vels 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 leve ls measured were at least two orders of magnitude less than the PRG of 0.44 ppm for cancer effects.

O -phenylphenol was the only fungic ide 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 pestici de in school classrooms. Data were not available on its persist ence 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 cl assrooms. 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 canc er risk calculations, the cancer risk from dieldrin is a potential health conc ern, especially in older classrooms.

3.2.7.3 Polycyclic Aromatic Hydr ocarbons (PAHs) in Floor Dust

PAHs are ubiquitous products of combustion (e.g., wood smoke, diesel and gasoline exhaust, tobacco smoke, cooking). They ar e found in measurable quantities in the air, especially in urban areas. They are semi volatile compounds and therefore accumulate in soil and dust. Most of the 16 PAHs st udied (some of which are also known or suspected carcinogens) also were found in ov er 80% of the classr ooms, but the loadingENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

64 levels were relatively low. The mean c oncentrations 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 fo r 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 meas ured in floor dust samples. Dog and cat allergens ( Can f 1 and Fel d 1) were detected most frequent ly: they were found in more than half of the classroom dust samples. Ho wever, 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 ca t, dog, or mite allergens showed moderate concentrations in a small subset of cl assrooms, but only two classrooms had any allergen (dog) above an established sensitizat ion 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 f ound 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 natur e of roof leaks, plumbing leaks, floods, etc., the dependence of mold growth on temperat ure and humidity, and the influences of ventilation patterns and indoor activity on particle generation and distribution determine the likelihood of mold growth and concentra tion of spores in indoor air. Spot measurements of airborne mold spores pr ovide limited information on the presence of mold growth in indoor environments. Theref ore, we did not expect to measure elevated levels of airborne mold spores in cl assrooms during a one-day building inspection unless mold contamination was severe. In addition to sampling for culturable and nonculturable bacteria and fungi, the field tec hnicians also inspected the classrooms for signs of mold growth or its predecessor (w ater 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 questionnair e 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 CALIFORN IA’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. Obse rvations 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 portabl e classrooms often have a full-length joint between modules that can leak at the roof level. Tradi tional 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 cons truction of portable classrooms.

Table 3-8. Percent of Classrooms wi th 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 cons istent 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 pr oblems were also examined. Mold was observed on HVAC filters infrequently (1.3 % of portables and none in traditional classrooms). Many portabl e 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 CALIFORN IA’S PORTABLE CLASSROOMS

66 Mold contamination in wall inte riors 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 outdoor s 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 cl assrooms. Total fungal spores averaged 1,290 counts/m 3 (3.11 log 10 counts/m 3 ) outdoors and 288 counts/m 3 (2.46 log 10 counts/m 3 ) indoors; the 95 th percentile values were 16,200 counts/m 3 (4.21log 10 counts/m 3 ) outdoors and 2,040 counts/m 3 (3.31 log 10 counts/m 3 ) 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 classr ooms (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, mold y odor or visible mold growth, it is likely that these spores have been brought indoor s 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 to tal mold spores were in the Low Category,ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

67 suggesting that only extremely sensitive persons may experience symptoms. While these guidelines were developed for the in terpretation of outdoor air samples, the responses of mold-allergic persons to i ndoor exposures is likely to be similar.

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

Concentration (pollen grains /m 3 or mold spores /m 3 ) 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 dur ing 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 t hese supplemental samples agreed with the findings from the Allergenco samples, that is, outdoor concentrations of mold spores were higher than indoor levels for both por table 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 classroom s. Total pollen concentrations were almost always lower indoors than outdoors. For example, the mean outdoor pollen levelENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

68 was 21 grains/m 3 while the indoor mean was 8 grains/m 3 for both portable and traditional classrooms. The 95 th percentile values were 19 grains/m 3 for portable and 78 grains/m 3 for traditional classrooms, versus 276 grains/m 3 for outdoor air. This indicates that most classrooms were in t he “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 perc ent 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 sch ool buildings, which were more likely part of the original school construction. Alternat ively, it may indicate cases where there was greater infiltration of outdoor air and pollen into traditional classrooms.

Because the AAAAI sensitization classifi cations 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 impac ts on students and teachers. Nonetheless, because few indoor pollen-produc ing 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 acous tic standard for classroom noise levels -- 35 decibels A-weighted, or dBA. A s ubstantial percentage of both portable and traditional classrooms exceeded outdoor noise li mits of 55 dBA set by some California communities (see Table 3-10). Noise leve ls 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 Li ghting 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 tr aditional classrooms was significantly higher than that measured in the por table classrooms. However, a small percentage of both portable and traditional classrooms did not m eet professional design guidelines (IESNA, 2000) of 30 foot-candles (f-c) for high-contra st materials. In addition, approximately one-third of both portables and traditional classrooms did not meet the IESNA lightENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

69 guidelines of 50 f-c for low- contrast materials, indica ting inadequate lig hting in both types of classrooms (see Table 3-10).

3.2.12 Specially Selected Classrooms

The specially selected classrooms at the 14 sc hools 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, su ch 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 CO 2 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 su rface microbes ranged fr om non-detectable to 4 million, depending on sampling sites (e.g., de sk, 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 comp rehensive 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 le vels exceeded avai lable environmental standards and guidelines in some cases. Build ing materials, classroom age, ventilation conditions, outdoor air, and other factors were associated wit h elevated pollutant levels. There were significant differences between portable and traditional classrooms in many of their environmental conditions and the asso ciated factors. Further analysis of the rich data base generated in this study will likely rev eal 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

71 

## 4. RELATED STUDIES IN CALIFORNIA SCHOOLS

Prior to the PCS, there had been no compr ehensive study of environmental conditions in California public schools. Various in vestigations 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 repor ted at least one inadequate building feature (HVAC, plumbing, roof, framing, floor, foundat ion, 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 GA O studies, center-city schools and those with higher proportions of minority and poor students report ed needing extensive repair or replacement at least 30% mo re 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 elem ents, leading to mold contamination and growth. The report also pointed out that measurements of indoor air pollutants were very limited, and quantit ative analyses of their impacts on health were therefore difficult. However, respiratory and central nervous system symptoms were the most common health co mplaints. A similar analysis done for Oak Ridge National Laborator y highlighted the need for pollutant source control, proper ventilation, and humid ity control to prevent IAQ problems in schools.

♦ The California Energy Commission inve stigated ventilation in California schools and other non-residential buildings. Thei r 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 r equired by State regulations and industry standards (CEC, 1995).

♦ DHS conducted a survey of lead haz ards from paint, soil and water in a representative sample of 200 elementar y schools and child care facilities inCalifornia (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, anENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

72 estimated 18% of schools had lead in dr inking 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 (repres enting ~25% of state students) that documented the widespread use of pesti cides 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 horm one system, or act as nerve toxins).

♦ DHS estimated approximately 5% of California schools have one or more classrooms with long-term radon conc entrations 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 ex ceed 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 r eport postulates that the IEQ problems for portables, especially elevated exposures to formaldehyde and VOCs, are more serious than for permanent buildings, and t hat children are adversely affected by being housed in them. Incident s of sick-building syndrome complaints among teachers and students were described.

♦ A small study of portables in Los A ngeles was conducted by UCLA in 1999-2000 (Shendell et al. , 2003). Overall, the results f ound 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 μ g/m 3 . 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 hi gh 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-effici ent 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 toxi c and odorous volatile organic compounds (VOCs). Each had two HVAC systems, oper ated on alternate weeks, consistingENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

73 of a standard heat-pump system and an indire ct-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 le ss energy for cooling. School year-long measurements included: carbon dioxide (CO 2 ), particulate matter, VOCs, temperature, humidity, thermal comfort, noise, meteorology, and energy use. IEQ monitoring results indicate that impor tant ventilation-relevant indoor CO 2 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 pr oducts, including those most commonly used for school construction, to obtain dat a 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, Spec ification Section 01350 (Section 01350), was designed to si mulate volatile organic compound (VOC) emissions during the early stage of building occupancy. Over 70 products in eleven material categories were te sted for their emissions of more than 120 targeted chemicals. Predicted concentrati ons were calculated from laboratory emissions data and using typical dimensions , ventilation rates and material use scenarios.

The results of the Building Material Emissi ons Study indicate that recycled content products perform about the same as st andard products. Both alternative and standard products have the potential to emit chemicals of concern. Furthermore, the study concluded that low-emitting, su stainable building materials are available for all categories of materials tested. Approximately 40 per cent 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 em ission limits were exceed ed equally by both standard and alternative products under the Secti on 01350 concentration limits, as well as under more stringent IAQ criteria. The majo rity of the products that exceeded the IAQ concentration limits did so by exceedi ng the limits of only one chemical, which suggests that product reformulation coul d readily improve the environmental safety of the product. Moreover, t he investigators recommended that building product manufacturers should specific ally reduce emissions of naphthalene, formaldehyde, and acetaldehyde from their pr oducts. Since rubber-based resilient flooring products emitted substantia lly greater amounts of VOCs, further refinement and testing of these products is necessary before they can be promoted for wide-use in most indoor env ironments. Industr y-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 labor atories. A copy of the study may be found at http://www.ciwmb.ca.gov/GreenBuildin g/Specs/Section01350/METStudy.htm

.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

74 ♦ OEHHA recently conducted a school-based, cross-sectional epidemiological study to examine associations between proximit y 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 (N O), 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) ma jor roads, and were associated with both bronchitis and episodes of asthma. A nother 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

75 

## 5. INFORMATION FROM OTHER STATES

The most comprehensive, previous state wide study of classrooms was conducted in Texas, including an assessment of environment al conditions in 115 classrooms. The investigators found that the use of chem ical cleaning compounds and air fresheners, especially during after-hours custodial cleaning when there wa s 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 fo r mean school-day and peak carbon dioxide (CO 2 ) concentrations between portable and main bui lding classrooms, or when data were separated by teacher responses to questions regarding classroom odors. About 2/3 of the classrooms had school-day averaged CO 2 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 vo luntary efforts to improve IEQ in public school buildings. Maryland’s Department of Education (1987) est ablished a program on IAQ in public schools in 1987, and it devel oped a seminal set of guidance documents on related school facility issues (such as ventila tion 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 “volunt ary guidelines” for IAQ in schools (Texas DOH 1998), under mandate from their legislatur e. The Minnesota Department of Health has developed extensive training and gui dance for schools, including a streamlined inspection package, an IAQ Management Pl an 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 fa cilities. These are coalitio ns 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

76 

## 6. SUMMARY OF STAKEHOLDER INPUT

As mentioned above, ARB and DH S consulted with other interested state agencies and stakeholders. Interested stakeholders incl uded 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 Angel es), and San Diego. ARB and DHS staff presented information on the overall study desi gn, as well as details regarding the intended schedule and scope of the project. The wor kshops 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 comm ents 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 c oncerned 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 parent s and teachers regarding indoor air quality (DHS provided this online f eature subsequent to the workshops).

♦ Would like to review detailed study protocols (general protocols could be reviewed, but detailed protocol s not available for review pr ior 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 cla ssrooms and used regularly in analysis of the data).

♦ Please consider the type of installa tion and foundation...some portables have had mold and other problems because of im proper installation, foundation skirts too close to the ground, et c. (Foundation skirt and installation information was included on the technician inspection checklist).

♦ Concerns were raised over how appropria te health thresholds would be selected and discussed in the final report. (O EHHA’s acute and chronic ReferenceENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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 souther n California, plus webcast and phone access, were also held duri ng the review period for the public draft of this document. Many useful comments were received, and the report was modified as appropriate. Comments frequent ly 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 facilit y maintenance. Teachers should be trained regarding indoor environmental quality. They are a ke y part of the solution to classroom problems because they often tu rn off HVAC systems or adjust the thermostat improperly, and they bring in items such as “air fresheners” that actually contribute to indoor air pol lution and degrade the indoor environment.

♦ Purchasing agents, janitors, and fa cility managers need to be trained too. Perhaps “distance learning” would work for these groups.

♦ Desks and other items added to the classr oom can emit formaldehyde. Schools should purchase formaldehyde-free furnishings.

♦ Solutions and changes should be pursued through collaborative efforts, such as with the California Teacher s Association, the NEA, the ALA, and others.

♦ HVAC systems can be made quieter by of fsetting the return air vent, using baffling, and other actions. Systems need to be quiet to be usable.

These and the many other specific co mments received during the workshops and comment period were used in revising the recommendations of this report. Some comments did not warrant changes to the repor t document, but rather were submitted to provide information regarding specific substitu te products that are available and other useful information.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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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 pr oblems occur only at a small percentage of schools. The env ironmental 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 pr omoting those systems that appear to be working well.

Actions are needed at all levels to prov ide 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 sc hool level, but dist ricts and the State must be partners in providing the t ools 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 fi scal constraints, most often what is needed is systematic review and attention to these i ssues. Many of the problems identified in this study can be addressed through meeti ng existing State standards and guidelines (primarily those of Cal/OSHA), including r equirements to provide continuous outdoor air exchange; improved operat ion 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 fo r 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 guidelin es and standards for school environmental health.

Each specific recommendation below suppor ts one or more of these over-arching approaches. The specific recommendat ions are presented in two groups:

Group 1 : includes actions that are high priority and would yield high benefits at relatively low cost. These recomm endations should be pursued within the next one to two years.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’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 r equire 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 bel ow are directed toward preventing and resolving problems in all cl assrooms, unless otherwise noted.

GROUP 1: High Priority, High Benefi t Actions, with Relatively Low Cost

Group 1 recommendations build largely on regul ations, programs and activities that are already in place but that are not fully met or utilized.

1. Meet State Regulations. Schools, districts, and the st ate should assure that all school buildings meet all re levant State regulations, particularly those related to operation and maintenance. Many classr ooms do not meet various existing State standards, and meeting those regulations would go far to provide healthful conditions in classrooms. For exampl e, operating HVAC systems as they were intended to be operated to assure adequate outdoor air ventilation; developing a health and safety program and training empl oyees to implement that program, per requirements of the Injury and Illne ss Prevention Program regulation; and maintaining sanitary conditions and correcting water intrusion, leakage, and uncontrolled accumulation of water to reduc e 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 distri cts do not meet the maintenance staffing ratios recommended by the California A ssociation 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 LAUS D. In addition to assessing whether state regulations are being met, self-inspections can also be used to remedy obvious problems that are not necessarily regul ated, and as a first step to begin to incorporate “Best Practices” into operat ion 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-t hroughs and identify key problems in the near term. Conditions that can be corrected wit h little or no cost should be remedied promptly. Plans should be developed to obtain resources to address those that require additional funds to remedy; fo r example, noisy HVAC units should be scheduled for modification or upgrade.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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 di scussed above. The U.S. EPA’s IAQ Tools for Schools Kit provides guidance for developing such a plan: see http://www.epa.gov/iaq/scho o ls/ . Visalia, Sau g us, San Francisco, and Clovis, among others, have successfully and cost-effectively implemented Tools for Schools in their schools. Districts and schools s hould implement key provisions of the program and other preventiv e operation and maintenance m easures 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: v entilation systems should remain “on”, and pollutant sources such as “air fr esheners” 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 t he design, construction, operation, and maintenance of new California schools, es pecially 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 sch ools 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.chp s .net/ ; manuals f o r 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 si tuation. Additionally, specific recommendations gleaned from this study and from stakeholders’ input, are incl uded in Appendix VI. Key examples are: a. Specify no- and low-emi tting building materials and furnishings in construction contracts and solicitations. This should include using exterior grade wood products in wall & floor materials; no-fo rmaldehyde insulation, ceiling tiles, and cabinetry; and other low- or no-emitting ma terials to avoid elevated formaldehyde and VOC levels. b. Specify HVAC systems that provide suffi cient 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

81 5. Expand State Design Review . State-level design revi ew for new buildings and major renovations should be expanded. Re view and approval of elements such as ventilation system design and building ma terials should be added to the routine structural, fire and life-safety, and accessibi lity plan-check function of the Division of the State Architect (DSA). The DSA is curr ently initiating specification revisions and implementing a more proactive approach in pl an reviews, but additional trained staff are needed for the additional work. DSA and O PSC 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 pr oper 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 vent ilation 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, espec ially 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 time frame. The current year-t o-year fluctuation of the existing Deferred Maintenance Program does not provide stable, consistent funding for long-term planning and preventive ma intenance. Implem entation 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 organizati ons. Those who are closest to the classroom are often not aware of curr ent “best practices” for operation and maintenance of classrooms. For example, teachers inadvertently bring pollutant sources into the room, improper ly adjust thermostats, or ta ke other actions that can have a major impact on the environmental c onditions 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-te rm to assure that key school staff receive appropriate training, so that they can routinely train new staff as they comeENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

82 on board. DSA and OPSC should devel op training programs and materials in consultation with ARB, DHS, CEC, Cal /OSHA, and other relevant agencies, as well as CASBO, CASH, and other relevant ex ternal groups. These should include: a. A Training and Certific ation Program for School Facility Managers. Success in operation and maintenance is often a f unction of the strength and knowledge of facilities directors, yet there are few credentials districts can apply in their selection of key facility department per sonnel. Districts should hire trained, certified facility managers. b. Development and routine di stribution 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 effectivel y remove particles. This can effectively reduce persistent contaminants in car peted 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. T he passage of the Healthy Schools Act of 2000 established requirements fo r 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 housek eeping practices and use of least-toxic pesticides when application is necessary has many benef its. 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 port ables are well past the stage at which they should have been replaced with a new portabl e 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-e fficient, 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, light ing, 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. T hese represent among t he State’s greatestENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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 st andard for K-12 schools. If needed, promote technology development to meet such a guideline or standard.

15. Develop State-level chemical expos ure 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 des igns 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 Laborat ory, 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 thes e newer designs might better meet future classroom needs.

Implementation of some of the recommendations above will cl early incur costs to those involved, and will require fiscal planning to achi eve. However, the cost of not taking these actions appears high – potentially harmf ul impacts on children’s and teachers’ health, reduced learning, reduced educational progress, and, in some cases, higher costs to fix facility problems when they bec ome more serious. Most importantly, State building, ventilation, and workplace regul ations have been developed to assure safety and health, and must be met.

The LAUSD’s self-inspection program has s hown 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 ava ilable 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 Schoolscan work well in California.

Appendix VI provides more specific recomm endations for schools and districts. It is a working document that will be updated perio dically and made available on ARB’s website.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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## 8. SUMMARY AND CONCLUSIONS

The California Portable Classrooms Study (PCS) was conducted to address concerns raised regarding environmental c onditions in California’s portable classrooms. The objective of the study was to examine envir onmental health conditions, especially those related to indoor air quality and health risks, in K-12 portable cla ssrooms in California. These environmental conditions included levels of airborne chemicals; the presence of potential pollutant sources; the performance of heating, v entilating, and air-conditioning systems; factors such as light, noise, temper ature, 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 sc hools had at least one portable classroom at that time, and that about 80,000 portable cla ssrooms were in use statewide, totaling about one-third of all Californi a classrooms. These portable classrooms ranged in age from less than one year ol d 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, fr om October 2001 thr ough 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 availa ble, although some will incur more than minimal costs. The solutions require a combination of ac tions by the State, districts, schools, manufacturers, facility managers, teachers, parents, and others. Adherence to state regulations, improved operation and ma intenance, and enhanced training of school personnel, can go a long way to address many, but not all, of t he problems identified.

The primary problem areas i dentified 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 hav e turned off the ventila tion system at times due to excess noise.

♦ Portables had more instances of dirty HVAC filters, closed dampers, and airconditioner condensat e drainage problems.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

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 classroom s had temperatures above or below the ASHRAE standard for acceptable indoor temperature, and about 11%-14% of classrooms had relative humidity leve ls outside the ASHRA E 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 occurr ed primarily in the warmer seasons, as expected, and primarily in portable cl assrooms. Alternative low-emitting materials are available and should be used in constructing new portable classrooms.

♦ VOCs were present indoors at levels si milar 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 lik ely 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 pes ticides were detected in over 80% of the samples: esfenvalerate, chlorpyrifos, cis- and trans -permethrin, o

phenylphenol, and piperonyl butoxid e. Chlorpyrifos can last up to a year or more in the environment; the other five are s horter-lived, lasting just a few weeks. Children can be exposed to pesticides th rough inhalation, ingestion (fingers in the mouth), and dermal contact, and childr en 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, al though 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.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

86 5. Moisture and Mold

♦ In the mail survey, a large percentage of teachers reported smelling musty odors in their classroom, or current or prev ious 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 recent ly 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 dec ibels, 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 lo wer lighting levels than traditional classrooms

8.2 Recommendations

Approaches to remedy and prevent the problem s 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 provid ing continuous outdoor air exchange; through improved operati on 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 re medy the problems identified in this study, each with several specific recommendati ons 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 CALIFORN IA’S PORTABLE CLASSROOMS

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

♦ Establish new guideli nes and standards for school environmental health.

Specific recommendations are provided in s upport of each of these. They include seven recommended (Group 1) acti ons 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 year s. The highest priority reco mmendation 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 dist ricts and schools for design, construction, operation, and maintenance of school facilitie s, 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, unocc upied classrooms not exceed 45 dBA should be imposed until an appropriate task force of ex perts 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 f our to five years to implement fully. Some of these recommendat ions include: assuring long term, stable funding for facility construction and ma intenance; 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 l earning environments should be retired, and support given to promoti ng 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 educatio nal 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 poi nt 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, contaminantsENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

88 present at undesirable levels in the ai r and floor dust, excessive noise levels, inadequate lighting, and mold and moisture probl ems. A number of programs initiated by the State, districts, and others before or during the con duct of this study are already beginning to address some of these concer ns. 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, manufacture rs of portable classrooms, manufacturers of ventilation systems, and others who provide materials and supplies used by our schools all have an important role in improvi ng the environmental health conditions of our schools. Most importantly, California needs to transition to true prevention progra ms that have stable funding.ENVIRONMENTAL HEALTH CONDITIONS IN CALIFORN IA’S PORTABLE CLASSROOMS

89 

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I - 1 

## APPENDIX I

LEGISLATIVE MANDATEEnvironmental Health Conditions in California’s Portable Classrooms

I - 2 

## HEALTH & SAFETY CODE § 39619.6

The legislative mandate for the Portable Classr oom 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 Depar tment 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 depar tment shall jointly coordinate the study, oversee data analysis and quality assurance, coordinate stakeholder participation, and prepar e 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 sha ll be provided to the appropriate policy committees of the Legislat ure. 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 maintenanc e practices, including the actual operation or non-operation of ventilation systems. (3) Assessment of indoor air quality. (4) Assessment of potential toxi c contamination, including molds and other biological contaminants. (d) The final report shall summa rize the results of the study and review, and shall include recommendations to remedy and prevent unhealthful conditions found in port able classrooms, including the need for all of the following: (1) Modified design and c onstruction 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-SURVEYCA/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 / Envir onmental 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) tota led 27.9 % and 39.3% of all portables, respectively. Districts reported plans to acquire an additi onal ~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 stude nts 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 por tables 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 pr ojected at somewhat higher rates. Updated estimates need to be made more readily ava ilable 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 12 th grade (K-12) education in Calif ornia functions within a complex system of local, county, state, and federal au thorities, regulations, and funding. Individual schools operate within semi-autonomous school di stricts, which are administrated under locally elected school boards. Notwithstanding state or federal mandates or financial resources, all aspects of school function, incl uding school facility manageme nt, are under local control and responsibility. Central bodies, su ch as the Department of Edu cation, 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 th e local school officials to fulfill these mandates or suffer the consequences. Unde r very rare circumstances, the county or state education agency can take ove r daily district operations.

The semi-autonomous organization of public K-12 e ducation 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, staffi ng, demographics, state funding, compliance with some regulations, and standardized test scores, at present, there is no centralizedDHS 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 th eir age distribution? Ho w many new portables are planned for purchase in a given year? And, what schools/district s 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 tradi tional classrooms. In or der to extrapolate PCS results to statewide estimates of school cond itions, 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 di stricts 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 “t otal 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 list ed in the California Department of Education (CDE) list of public school districts and schools, which includes mailing addresses and district contacts 1 . CDE uses a cataloging system for schools and district with CDS codes, for which unique numbers are given for each County, D istrict, and S chool in the state. There are 58 counties, almost 1,100 di stricts, 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 crea ted in ACCESS with records for each district and each school in the state using their CDS codes. Schools showi ng no current enrollment, or no grades between K and 12 th (e.g., community colleges) were excluded from our database. Demographic information was acquired from the CBEDS (California Basi c Education Data System) demographic data files 2

.

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 w ith cover letter from the State Superintendent of Public Instruction, Ms. Delaine Ea stin. Survey packets were maile d 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 su rvey form for each school within the district. The data form asked that a knowledgeable di strict staff person provide information “ as of November 1, 2000, ” for each school in the district. Po rtables were defined as relocatable classroom structures, generally factory manufact ured and without foundations. The form asked

1 California Public School Directory, 2000. available from CDE Press. Update d 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

II-4 that the age be determin ed using the date of manufacture, not delivery date. Many districts contacted DHS for clarification, most often to de termine whether or not to include units in noninstructional uses, e.g., teachers’ lounges, bath rooms, 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 ini tial 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 ex ample in Appendix), and each time additional data forms were acquired. Additionally, phone calls were made to medium and large districts. The largest districts were provide d an electronic version of the database to complete. In June 2001, the response rate was up to 75%, and a d ecision was made to continue querying nonresponsive districts in the follo wing 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 adjust ed to the base year (2000-01).

RESULTS

The survey database included 1049 districts a nd 8554 individual schools. Enrollment in 2000-01 totaled just over 6 million (Table 2). More than 90% of distri cts 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 Stude nt 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” (enrsc h**) 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 61.5DHS Survey of Portable Classrooms

II-5 Using the data provided for each school, number tota ls 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 fo r schools reporting, then scaling it upward, proportional to the enrollment of responding schools (i.e., divi ding 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 classr ooms 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 sc hools, 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 standa rd subset of K-12 grades as follows: Elementary – K - 5 th , Middle – 6 th to 8 th , and High – 9 th to 12 th grades. Some schools use less standard grade ranges, and notwithstanding th eir CDE designation, thes e were categorized as above or as follows: “Lower” – K to 8 th ; “Upper” – 7 th to 12 th ; and “All” – K to 12 th . CDE designates some schools as “alternative” or “co ntinuation,” and these were parsed according to their grade levels as given in CBEDS. The numb ers 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 ve rsus 19-21 students per classroom). Classrooms at K-12 (“All”) schools were the most crow ded 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” grad es (39%) and “Upper” grades (42%). While elementary schools used almost twice the pr oportion of portables than middle and high schools, the fraction of schools with at l east one portable classroom was relative close (93% versus 82%).

Classroom Age . A large proportion of portable cla ssrooms (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 planne d 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 a nd classroom age distribut ions were estimated from data for ~500 schools, weighted for the sa mpling frame and response rates. The respective age distributions are given in Table 6. The ag e distribution of traditional classrooms is very similar to the schools, while portable classr ooms are characteristically younger. The data indicate that about 11% of traditional classrooms were adde d in expansion projects at older schools in recent years. Compare this to the mo re 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 accura te than the PCS data, because it used nearly complete enumeration, while the PCS used stra tified sampling and acquired data for <10% of schools and <1% of classrooms. Nonethele ss, while the Pre-PCS study used fewer age categories, the two studies are in close agreem ent regarding portable cl assroom 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 statew ide average (0.9% versus 0.3%). Six districts grew over 2% between school years. The larg est districts’ classroom s were somewhat more crowded (22.5 versus 21.8 students per classroom) and used portables at the same proportion as the statewide average (~30%). No tably, the portables used at the largest districts were frequently older units (44% versus 28%), a nd 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% statew ide. Subsequent to the 2000- 01 survey, Los Angeles Unified reported purcha sing 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 ClassroomsII-8Table 7. Data for 20 Largest School Districts in California (2000-01)As % of PortablesRank District County2000-01EnrollmentGrowthRatea#SchoolsAverageStudentsbperClassroom# AllClassroomsPortablesas % AllOlder Newer Planned1 Los Angeles Unified Los Angeles 720,534 1.7% 655 23.1 28,493 29.2% 63.5% 20.5% n/a2 San Diego City Unified San Diego 140,328 -0.6% 175 19.8 7,043 34.9% 53.4% 37.0% n/a3 Long Beach Unified Los Angeles 93,235 2.5% 85 21.0 4,268 28.8% 15.5% 61.7% n/a4 Fresno Unified Fresno 77,588 1.3% 94 21.7 3,433 37.7% 17.4% 19.2% n/a5 San Francisco Unified San Francisco 59,979 -2.4% 113 17.6 3,500 8.4% N/a n/a n/a6 Santa Ana Unified Orange 59,837 -1.1% 50 24.5 2,527 31.4% n/a n/a n/a7 Oakland Unified Alameda 54,264 -4.2% 92 23.3 2,262 29.1% 67.4% 35.3% 17.9%8 Sacramento City Unified Sacramento 53,693 0.9% 79 18.7 2,752 38.7% 38.8% 35.6% n/a9 San Juan Unified Sacramento 50,167 2.0% 83 19.9 2,433 21.2% 42.6% 27.6% n/a10 Garden Grove Unified Orange 48,742 1.6% 65 25.0 1,926 21.0% 27.5% 48.3% n/a11 San Bernardino City Unified San Bernardino 52,031 0.5% 62 26.2 1,911 37.9% 45.5% 54.2% n/a12 Capistrano Unified Orange 40,913 -2.7% 39 21.8 1,790 37.4% 24.3% 21.3% 6.3%13 Elk Grove Unified Sacramento 46,090 4.5% 50 26.0 1,723 54.6% 21.5% 20.7% n/a14 Riverside Unified Riverside 38,124 4.1% 44 26.6 1,621 31.5% 8.2% 28.4% 2.0%15 Mt. Diablo Unified Contra Costa 36,614 0.3% 54 19.9 1,777 18.7% 86.3% 7.0% n/a16 Stockton City Unified San Joaquin 37,322 2.9% 44 22.4 1,607 34.9% 18.7% 35.7% 2.9%17 Saddleback Valley Unified Orange 35,199 -0.2% 37 23.1 1,569 24.9% 12.0% 56.3% -18 Montebello Unified Los Angeles 34,794 0.7% 28 25.2 1,350 37.0% 48.3% 21.4% 2.6%19 Fontana Unified San Bernardino 37,244 3.1% 34 25.4 1,440 35.3% 3.3% 34.0% 9.8%20 West Contra Costa Unified Contra Costa 34,499 -4.6% 59 21.1 1,650 26.1% 44.6% 32.7% -LARGEST DISTRICTS1,751,197 0.9% 1,942 22.5 75,076 30.1% 44.3% 27.0% 7.7%ALL DISTRICTS6,007,002 0.3% 8,554 21.8 268,030 29.5% 27.9% 39.3% 5.2%a. Enrollment increase from 2000-01 to 2001-02b. District-wide average of school valuesDHS Survey of Portable Classrooms

II-9 SUMMARY

When planning for the PCS commenced, no statew ide inventory of portable classrooms existed. A labor-intensive enumeration method was usedto survey all Calif ornia school districts specifically about classroom facili ties. Data for over 90% of stat e 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 al l portables, respectively. Distri cts 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. Elem entary 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 di stricts’ classrooms used portables at the same proportion as the statewide average. However, th e portables used at the largest districts were more frequently older units (44% versus 28%). Th e 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 facilitie s represent a substantia l capital investment of state resources. Data on classroom facilities, including portable classrooms, should be collected routinely. It is needed for surveys of environm ental 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 East in to District Superintendents) October 2000

Example of Follow-up Letters Sent to District Superintendents and District Facility Directors January 2001DHS Survey of Portable Classrooms Appendix

II-11 Portables Survey Form for ARB/DHS Study

Instructions: Please fill out the short form below. Fo r 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 we eks (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 su rvey, 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-12DHS 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 Conditi ons 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 stat ewide 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 st aff. 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 fo rm (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 “P ortables Study, CDHS-EHLB, 2151 Berkeley Way, Berkeley, CA 94704”.

This survey is part of a joint study by the Stat e 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 a nd DHS must make to the Governor and the Legislature. These recommendations will help shape future program and funding decisions at the State level. Further informati on about the study can be found on the web: http://www.arb.ca.gov/res earch/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 EducationEnvironmental Health Conditions in California’s Portable Classrooms

III - I 

## APPENDIX III

RTI-ARB-DHS PROJECT EXECUTIVE SUMMARYIII-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 2003III-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 Ca lifornia’s portable classrooms. The objective of the study was to examine environmental health c onditions, especially thos e related to indoor air quality and health risks, in K-12 portable classrooms in California. These environmental conditions included levels of air borne chemicals; the presence of potential pollutant sources; the performance of heating, ventilating, and air-condi tioning 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 administra tors, 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 mo re 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 condu cted by DHS in Fall, 2000, indicated that 85 percent of K-12 public schools ha d 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 sensitiv e individuals; irritate mucous membranes in the eyes, nose and throat; cause respiratory infec tions or headaches; a nd contribute to the development of cancer. Some contaminants iden tified 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 carcinog ens and reproductive toxicants.III-4 In light of the concerns raised, the California Air Resources Board (ARB) and Department of Health Services (DHS) request ed funding in the 2000-2001 State budget to jointly conduct a comprehensive study of the environmen tal health conditions in portable classrooms. The State Legislature approved the request, and specified milestones and requirements in Assembly Bill 2872, Shelley (Calif ornia 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 f ound 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 fo rmaldehyde monitors were sent to a randomly selected sample of all public schools with at least one portable classr oom 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 Oc tober 2001 through February 2002. Both portable and traditional classrooms we re studied in both phases.

Results from this study will be used by ARB, DHS, and other stake holders to assess the potential for adverse health impacts from envir onmental 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 act ions that can be taken to remedy or prevent any unhealthful conditions found.

This project summary provides a brief overvie w 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 Califor nia 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 c ode and selected a 1-in-7 systematic sample from the sorted frame. The result was a sample of 1,216 schools th at was stratified by c ounty and district. DHS then conducted a preliminary survey of the resu lting school districts and eliminated 177 schools that did not have any portabl e classrooms. These schools were deleted from further consideration for the PCS, leaving 1,039 elig ible schools for inclusion in Phase I.

Two questionnaires, a Facilities Questionnair e (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, a nd government agencies obtained during public workshops held across the state. The questionna ires 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 sc hools. The FQ provided school-level and classrooms-level information on the physical cond itions, operation, and maintenance of buildingIII-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 rece ipt 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 to tal of 1,181 teachers provided additional classroom level data via the TQ. The classroom data were collected for three classrooms—usually two portable classrooms a nd 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 da ys to collect indoor air samples that were analyzed to determine formaldehyde con centrations. Valid indoor air formaldehyde concentration data were obtained for 911 classr ooms (644 portable and 267 traditional) from 320 schools. Prior to mailing the samplers, ARB c onducted 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 sa mplers, which had been used in previous mail surveys by DHS (Sexton et al., 1989; Liu et al., 1991). Analysis of the labo ratory 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 e nvironmental 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 monitori ng 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 w ith apparent or reported problems actually had serious environmental problems. The Phas e 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) havi ng one or more portable classrooms. The sample of schools selected for the Phase II survey is st atistically 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 a pproach, classroom data were co llected for three classrooms per school, usually two portable clas srooms and one traditional classroom. Field technicians inspected the HVAC system and building interiors and exteriors. Various types of data were collected at each partic ipating school including:

• Questionnaire and checklist data : (1) Facilities Qu estionnaire II, (2 ) Consultation with Facilities and HVAC Managers (Part 2); (3) Teacher Questionnaire II; (4) Classroom Form; (5) Consultation with Facilities and HVAC Ma nagers (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, w ith samplers set up in the morning prior toIII-6 arrival of students, and removed at the end of the day. HVAC testing, noise measurements, and sampling for culturable airborne organi sms were conducted during lunch breaks (see Table PES-1). Environmental samples were st ored on ice and shippe d weekly by overnight delivery.

• Field QC samples: Field QC checks were perf ormed 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 CO 2 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 classr ooms 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 popu lation 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, que stionnaire responses, observations, and measurements of indoor pollutant levels, ventilation conditions, noise and lighting levels were characterized, and comparisons to environmen tal 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 intere st by the participating schools. The overall response rates of 40-45% are considered good for mail surveys.

Phase II

Questionnaire data and environmental monitori ng data were successfully collected in 67 of 81 sample schools, resulting in an overall wei ghted school-level response rate of 83%. Such a response rate for school-level part icipation 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 par ticipation: recruitment began early in the school year, permission was obtai ned from superintendents before contacting principals, and three experienced staff me mbers made repeated recruitment calls to superintendents and principals.

Phase I Results

School Characteristics and Maintenance Practices

The sample consisted largely of elementa ry schools (59% of th e total), schools in suburban areas (74%), and schools more than 30 y ears old (64%). About half of the schools hadIII-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 pe r student each year (Edwards, 2001).

In the past year, facility managers received major complaints about environmental problems in classrooms--such as air quality, wate r leaks, and noise--in ab out 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 (Tool s 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 a ll schools are required to keep such logs. About 5% of the facility ma nagers 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 re ported building characteristics, environmental complaints, and teacher symptoms were found between portable classrooms and traditional classrooms. Portable classrooms were most ofte n used at elementary schools, and typically for general instruction rather than la boratory, art, or other special cl asses. 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 fl oors, vinyl tackable wallboard, pressed wood bookcases, suspended ceilings, and metal roofs. Traditional classrooms we re located more often at high schools and middle schools, were used more often for special classe s, 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 r oom (45%). Teachers reported opening the windows or exterior doors at least occasionally in a bout half the portable classrooms (58% and 42%, respectively). A high percentage (60%) of the teachers in porta bles turned off the HVAC system due to noise. About half the teachers (52%) repo rted disruptive noises in classrooms, and aboutIII-9 two thirds (64%) reported disr uptive noises outside the portabl e 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 fact ors 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 laborat ory chemicals and cleaning products. Less commonly reported pollutant sources included office equipment, pest icide 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 classr ooms and about 30% of the traditional classrooms.

Table PES-3. Selected Pollutant Source Ca tegories Reported by Teachers (% yes)

Classroom Type Paints, Marker

Pens Glues, Correction Fluids Laboratory Chemicals,

Cleaning

Fluids Pesticide Use a Construction in Classroom b Air Fresheners

Portable 97 c 67 44 21 16 39 c

Traditional 91 66 52 d 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 fr om portable classrooms in some of these categories. Air fresheners, and paints and ma rker pens, were reporte d slightly less often in traditional classrooms (p < 0.05). On the other hand, traditional classrooms had slightly more reports of the presence of la boratory chemicals (p < 0.10).

With regard to moisture and mold indicato rs, 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). Vi sible mold, either curren tly 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 t eachers reported the temperature to be too hot (13%) or too cold (9%). Over one third of thes e teachers described the room air as too stuffy (38%). About one-third of the teachers in porta ble classrooms reported the lighting to be too dim (21%) or too bright (7%). Over one-seven th (13%) of these teachers rated the overall environmental quality of their classroom as poor . About one-third of the teachers (30%) inIII-10 portables preferred working in po rtable classrooms, and another th ird (35%) preferred traditional classrooms.

Compared to teachers in portable classroom s, the teachers in traditional classrooms reported fewer of the above problems with room air quality (especially stuffiness) and with lighting (especially dim conditi ons) (p < 0.01). Temperature problems, especially excessive heat, were reported more frequently in traditi onal classrooms (p < 0.05). Teachers in traditionals less frequently rated their cla ss room environmental quality as poor (p < 0.10). A much higher percentage of these teache rs (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 cl assrooms. 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 pa int were reported significantly more often (41% and 15%, respectively).

Measurement Results

In Phase I, valid indoor-air formaldehyde c oncentration data were obtained from 911 classrooms (320 schools). The mean formalde hyde 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 concentrati on levels, i.e., less than 6 ppb. Thus , nearly all of the classrooms had indoor, 10-day average formaldehyde levels greate r than typical outdoor levels in California (3 ppb), the Proposition 65 notific ation level equivalent for ai r (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 a nd nasal/upper airway in jury resulting from long-term exposures.

The short-term health-based guidelines fo r 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 protec t sensitive individuals against eye irritation and effects on the respiratory and immune systems resulting from acu te, short-term exposures. The 10-day average levels of formaldehyde are designed as screen ing estimates, and do not directly compare to standards and guidelines based on shorter time pe riods. However, because they are longer-term averages, they are probably conservative esti mates of 1- and 8-hour levels of formaldehyde reached in classrooms.

As can be seen in Table PES-4, the form aldehyde concentrations were significantly higher for portable classrooms than for traditi onal classrooms. For example, 50% of the portables had concentrations above 27 ppb, whereas only 29% of the trad itional classrooms were higher than 27 ppb. Also, 4% of the portable s 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 type s was only significant in the newer classrooms.III-11 Table PES-4. Phase I Formaldehyde Concen trations 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-f ormaldehyde 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 particul ar 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 popul ation 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 fi ndings, except that the aw areness 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 t hose observed in Phase I of the study.

Physical and Environmental Characteristics

Similar to Phase I results, portable classr ooms 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 of ten had carpet or rugs on the fl oor, vinyl tack able wallboard, fiber/particle board or plywood walls, and pres sed 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 me tal 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 fo r portable classrooms is as follows: 42.6% are less than 2” above th e 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 moreIII-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 informati on 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 por table 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 el ectricity-based (94.6% versus 76.9%);

• The air filter for the HVAC unit in portable cl assrooms was more likely than traditionals to have a light or medium loading of dirt.

• During the Phase II inspections, portable clas sroom HVAC units were less likely to have clean condensate drain pans and lines (30.0 ve rsus 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 ha ndling units more often for portable classrooms than for traditional classrooms (10.8% versus 2.7%).

As can be seen in Table PES-6, both porta ble and traditional cl assrooms had school-day average concentrations of carbon dioxide (CO 2 ) greater than 1000 ppm, and both classroom types had one-hour average CO 2 levels above 1000 ppm for about 40% of the school day. Both classroom types had one-hour average CO 2 levels above 2000 ppm for about 10% of the school day. These results indicate insufficient ventil ation in a substantia l portion of California classrooms.

Table PES-6. CO 2 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 ofIII-14 8.8% of the portable classrooms and 4.4% of th e traditional classrooms failed to meet the Illuminating Engineering Society of North Ameri ca’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 betw een 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 Ameri can National Standards Institute (ANSI, 2002) acoustic standard and World Health Or ganization (WHO, 1999) guideline for unoccupied classroom acoustics. In fact, 50% of the nois e 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 citi es 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 porta ble and traditional classrooms, except that indoor noise near th e 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 cla ssrooms in California do not achieve the ASHRAE standards for acceptable temperature and relative humidity. Portable classrooms had temperatures below 17 E C (63 E F) for more of the time (6.3% versus 3.2%); and they had temperatures below 20 E C (68 E F) for more of the time (27.0 % versus 17.0%). Both portables and traditionals exceeded 23 E C (73 E F) about 27% of the time, but traditionals had a higher percent of time at very high temperatures (> 26 E C [79 E F] and > 29 E C [84 E F]). None of the RH summary measures exhibited statistically significant differences between the means of the two types of classrooms; average RH measur ements 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 achie ve 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 Classroom s Traditional Classrooms All <30% 11.0 11.4 11.3 >50% 44.7 45.6 45.3 >60% 16.9 12.6 14.1III-15 Airborne Pollutant Levels

Aldehydes

Of the 13 specific aldehydes included in the an alysis, 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. Fo r virtually all of the al dehydes, the indoor levels were higher than the outdoor leve ls, 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 95 th percentile was 3 times higher than ou tdoors (see Table PES-8). Statistically significant differences (0.10 level of signifi cance) between mean levels of portable and traditional classrooms (portable classroom aver ages were always higher) were found for formaldehyde (15.1 versus 12.3 ppb) and acetald ehyde (7.2 versus 6.4 ppb). Significant differences were also found in o,p-to lualdehyde (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 fo rmaldehyde concentrations were considerably lower than those observed in Phase I. The differences were not unexpected, and are likely attributable to seasonal differen ces, the different measurement methods used in the two Phases, and possibly other factors. For example, the Ph ase 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 exch ange rates for the Phas e II classrooms might haveIII-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 leas t 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 c oncentrations than did the portable classrooms, but none of the differences in mean concentrati ons were significant st atistically, 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-cla ss 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 averag es were in the range of 1 to 2 ppb.

Particulate Matter

Real time counts of particles were measur ed in each classroom and outdoors. Although particle counts cannot be dir ectly associated with mass concentration standards, the measurements provide a relative indi cation 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 differe nt 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 classr ooms, especially for the smaller size range. In addition, at the 95 th percentile, the difference is even more rema rkable for the higher por table concentrations in both size ranges. One possible explanation is th at, 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 classroom s may be nearer outdoor sources such as busy roadways and parking lots, especi ally in urban areas wh ere school site space is limited.

Pollens and Spores

In general there were few spore types that we re observed frequently in either the outdoor or indoor environments. In the outdoor environm ent, only six were freq uently seen (on 80% or more of the slides)—Amerospores, Ascospores, Cladosporium, Mycelial Fragments, Pollen Count, and Total Fungal Spores. Not too surpri singly, 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 vac uum 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 we re stored on ice for shipping and frozen until analysis. The samples were sieved at two cut po ints, less than 500 microns for the portion sent to California DHS for analysis of allergens, and th e 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 co sts. Accordingly, for each school , there was one sample analyzed to represent the portable clas srooms, and there was only one sample from the traditional classroom. Results are reported in concentration units ( : g/g) and loading units (ng/cm 2 ).

Pesticides

Results were reported for 20 pesticides. Six pesticides were detected in over 80% of the samples: chlorpyrifos, cis- and trans-perm ethrin, o-phenylphenol, piperonyl butoxide, and esfenvalerate. Diazinon, 4,4’ DDE, and propoxur we re measurable in over 50% of samples. Dieldrin, pendamethalin, propetamphos, bifenthri n, cyhalothrin, cypermet hrin, and delta/tralomethrin were detected in 10-50% of the samples. Four of the pestic ides were only rarely detected (<10% of samples): malathi on, lindane, resmethrin, and cyfluthrin.

At the 95 th percentile, nine of the pesticides were measured at concentrations above 1.0

: g/g, although several of these had few measur able samples. There were no significant differences in the mean levels in portable and traditional classrooms.

Esfenvalerate, a commonly used insecticide, had the highest dust c oncentration and the highest median loading level (0.34 ng/cm 2 ), while many of the pesticides had median loading levels less than 0.01 ng/cm 2 . No statistically significant di fferences between the means for the portable and traditional classrooms were found for e ither the concentration results or the loading results.

Metals

Fifteen of the 18 elements were above the de tection limit for all of the samples analyzed. The only three that were not always above th e 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 traditiona l classrooms for 8 of the 15 elements (arsenic, chromium, copper, manganese, vanadium, cesium, iron and strontium). Conversely, the samples from traditionals showed highe r dust concentrations than the composite samples from the portable classrooms for the other 7 elements, in cluding lead. Some samples of both types had lead levels that exceed the DHS and U.S. EP A acceptable floor dust levels for protection of children’s health.III-18 When the floor dust metals results are cons idered in terms of dust loading, all the elements show higher loadings in the samp les from portable classrooms, except copper. However, none of these differences were statisti cally significant at the 0.10 level of significance.

Lead, arsenic and chromium concentration results ( : g/g) and loading results (ng/cm 2 ) for the median and 95 th percentile are shown below in Table PE S-9. The table illustrates that there are not clear patterns ac ross the elements, and probably reflec ts 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 accu mulation in the traditional classroom. Arsenic, on the other hand, may indicate the closer proxim ity of portables to the school grounds, where there may be treated wood, or they may have treated foundations.

Table PES-9. Concentration and Load ing Results for Selected Elements

Concentrations ( : g/g) Loadings (ng/cm 2 ) Element Median 95 th Percentile Median 95 th 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 a llergens and cockroach al lergen 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 classr ooms had higher estimated concentrations for each species than the portab les, 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 highe r median levels in the traditional classroomsIII-19 (fluorene and perylene/benzo[b]fluoranthene). Similar results can be seen using the 95 th 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 e fforts did not include dust results.)

• Factors Affecting Indoor-Air CO 2 Concentrations . Based on modeling results, the indoor CO 2 levels were estimated to be approximat ely 30% lower when the teachers reported that the indoor air quality was acceptabl e. Models also showed a sign ificant effect of school type, with high schools having the highest indoor CO 2 levels (and thus in dicating the greatest likelihood of ventila tion insufficiency).

• Factors Affecting Noise Associated with HVACs . Classroom age had a positive effect (older rooms had higher noise levels), and the porta ble 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 cl assrooms 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-Ai r Aldehyde Concentrations . Various models were fit for log (Formaldehyde Concentration), log (Ace taldehyde Concentration), and log (o,pTolualdehyde Concentration). The preferre d models for the thr ee species were quite different. For formaldehyde, the type of clas sroom was generally statistically significant, with portables having higher le vels. Acetaldehyde showed no significant differences for portable and traditional classrooms, while tolualdehyde models included significant outdoor air by room-type interactions. On the other ha nd, they both showed si gnificant associations with their outdoor levels, while the formaldehyde models generally did not show a relationship with the outdoor levels. When ad justments for some other indoor variables were made – namely the CO 2 and temperature variables – ther e was a significant relation with outdoor formaldehyde levels. These two mode ls accounted for 22% and 32%, respectively, of the total variation in th e indoor levels. The model including “pressed wood bookcases” as a predictor, which also included a significan t classroom age variable (positive slope), accounted for only about 14% of the total va riation in the indoor formaldehyde levels; however, this model implied about a 30% incr ease in formaldehyde levels when pressed wood bookcases were present, and about 30% hi gher concentrations fo r portable classrooms. The model for acetaldehyde that included “pressed wood bookcases” as a predictor accounted for about 24% of the to tal variation in th e indoor levels of that analyte, andIII-20 indicated a significant increa se 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 predicto rs. There were signifi cant associations with outdoor levels in virtually a ll of the VOCs, except for ben zene, and these associations appeared somewhat stronger than for the alde hydes. For toluene, significantly lower levels were estimated when new construction/repair ac tivities were on-going (which may reflect the fact that doors and windows might be more fr equently closed when those activities were outside of the immediate classroom). The vari ables in this model accounted for 69% of the total variation in i ndoor toluene levels.

• Factors Affecting I ndoor-Air Pollen and Spores . A number of different models were fit for log (Pollen Count) and log (Total Fungal Spores ). There was a sta tistically si gnificant association between indoor and ou tdoor levels – with higher outdoor levels being associated with higher indoor levels. The te sts for significance for the candi date predictors revealed that only one predictor exhibited statistical si gnificance – namely “windows open,” which indicated that classrooms with “windows open t oday” 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 am ong teachers, or other factor s that would result in window closing.

• Factors Affecting Indoo r-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 c onsidered, the only predictor show ing significance was (for the 2.5 μm case) the presence of carpet/rugs (rooms w ith carpet/rugs had lower levels). For that model, traditional classrooms exhibited lowe r 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, co mbined with the many types of data collected, allow one to ascertain important conclusions re garding 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 schoo ls were less than 30 years old, th at the majority (54.4%) of the schools have 10 or fewer portable classrooms, a nd 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 ofIII-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 th e portable classrooms were devot ed to general instruction, as compared to 75.1% of the trad itional classrooms. Classroom age was not known for many classrooms; however, there is a dramatic differen ce in the estimated age di stributions 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 di fferences—e.g., differences in structural characteristics, HVAC characteristics, and type s of environmental problems/complaints. As compared to traditional classrooms, for instan ce, portables tend to have more carpet, more tackable wallboard, more pressed wood bookcas es, more exterior doors, more opening of windows, and more air conditioning (and thermost at 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 of ten for portable classrooms; an exception was plumbing leaks, which were more common in tr aditional classrooms. Pest related problems seemed to be about the same in portable and traditional classrooms.

The methods and materials used in the study were ge nerally 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). St atistically significant a ssociations were found for geographic region, season, over all air quality rating by the te acher, 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 l east part of the overall differen ce between the room types was due to the disparity in their age distributio ns and differences associated with age.

Phase II provided measurement and observational inform ation in greater detail than was obtained from Phase I. The data base provides a robust basis for statistic al inferences regarding the population of schools with portable classroom s because response rates and data completeness were quite good for most analytes and questionna ire 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 pr ecision were reasonably good for most analytes. Hence, the quality control samples verified th at 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 a nd traditional classrooms. Thos e 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). Fo r 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 porta ble classrooms were not significantly different at the 5% le vel; however, outdoor air flow (cfm/ft 2 ) 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 a nd 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 por table 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 th an ASHRAE comfort sta ndards. 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 a nd 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 pr ocedures and timing of the two data collections. However, indoor levels are r outinely higher than outdoor le vels, and average formaldehyde levels are likely to fall between the Phase I a nd Phase II measurements. Thus, most classrooms exceed health guidelines for chronic effects, and a substantial percen tage exceed guidelines designed to address acute eff ects. Other aldehydes and VOCs have not yet been examined relative to health-based guidelines, but indoor leve ls generally exceeded outdoor levels (similar to results in other st udies), indicating the pr esence of indoor sources that may need to be addressed.III-23 Table PES-10. Overall Results of Contaminant and CO 2 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- orcomfortbased 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

CO 2 (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 CO 2 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 i ndoor levels of fungi are elevated primarily in cases of extreme mold or biological contamination. Howeve r, classroom wall, floor, and ceiling moisture measurements indicated excess moisture in build ing materials in about 17% of the classrooms, indicating potential mold problems in those lo cations. Traditional classrooms had excess wall, floor, and ceiling moisture more often than portab les, 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 sample s, indicating the widespread use of a variety of different products in or near classrooms. Six pesticid es were detected in over 80% of the rooms, with esfenvalerate (a common insec ticide) showing the highe st concentration and loading levels. Some of the pesticides are pers istent chemicals, lasting for years, while other have an environmental lifetime lasting just week s; thus, some of the pesticides were likely applied just a week or two prior to th e 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 carc inogenic effects. Most of the 16 PAHs studied (some of which are also known or suspected ca rcinogens) also were f ound 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 in gested or absorbed through the skin, as well as inhaled, maki ng 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 genera ting a massive amount of information about California schools and classrooms. Although the da ta summaries and analyses described in this report are quite extensive, they clearly represent only a small fract ion of the analyses that could be undertaken to address environmental quality issues and related concerns.

Conclusions: From the above discussions of signif icant results, it is cl ear 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 j udging the state of the environm ental conditions in classrooms. Further analyses of this very ri ch data base will likely reveal ot her factors that could prove useful for further identifying sources and measures to be taken to reduce th eir potential effects.III-25 REFERENCES

ANSI/ASA (American National Standards Inst itute, 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, Re frigerating and Air-Conditioning Engineers), Standard 55-1981. See http://www.ashrae.org

. Bell, J., 2001. Poverty Data, October 2000. Cali fornia Department of Education, CalWORKS California Work Opportunity and Responsi bility 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 Environmenta l Health Hazard Assessment, Air Toxics and Epidemiology Section, Oakland, CA. Presented at 10 th 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. Educati onal Facility Lighti ng 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. “E mission Rates of Formaldehyde from Materials and Consumer Products Found in California Ho mes.” 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 Pollut ants. 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 Chem icals Causing Reproductive Toxicity, March. http://www.oehha.ca.gov/prop65/pdf/Mar2002StatusReport.pdf

. OEHHA (2001). All Chronic Reference Exposur e 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 FORMALDEHYDEEnvironmental 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 el evated 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 reas onably 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 effe ctive 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-gassi ng 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 we ll as other undesirable chemicals. If some of these products must be used, ma ke 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 conditioni ng (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 manufactu rer for assistance with noise attenuation.

• Keep doors and windows open as much as possible . Additional ventilation can be provided by operating oscillating fans in side 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 an d air circulation will help accelerate the removal of formaldehyde from thes e 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 taki ng 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 loca l 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, alt hough other methods may be adequate.

• Obtain measurements during school hour s with the ventilation system in normal operating mode . This will provide a good estimate of the levels the occupants are actually exposed to in thei r classrooms. Ideally , a 6-8 hour test is desired, to cover the hour s the rooms are occupied.

If Levels Are Still Higher Than Desired

If test results show that formaldehyde c oncentrations 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, viny l 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 duringIV-4 drying must be conducted under high ventilati on 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 or dered 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 t hat 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 leve ls 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/toxi cs/compwood/background.htm http://www.arb.ca.gov/research/indoor/formald.htm and http://www.arb.ca.gov/resear ch/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.htmlEnvironmental Health Conditions in California’s Portable Classrooms

V - I 

## APPENDIX V

LAUSD CHECKLIST

# Safe School Inspection Guidebook

L OS 

### A NGELES 

### U NIFIED 

### S CHOOL 

### D ISTRICT


### O FFICE OF 

### E NVIRONMENTAL 

### H EALTH AND 

### S AFETY

Preliminary Revis ion : August 27 , 2004Safe School Inspection Guidebook

Preliminary Revision 08/27 /04 

## S AFE 

## S CHOOL 

## I NSPECTION 

## G UIDEBOOK

TABLE OF CONTENTS

S ECTION 

### P AGE

I NTRODUCTION

................................ ................................ ................................ ................................ .......... 1

A SBESTOS M ANAGEMENT

................................ ................................ ................................ .......................... 2

C AMPUS S ECUR

ITY

................................ ................................ ................................ ................................ .... 4

C HEMICAL S AFETY

................................ ................................ ................................ ................................ .... 5

E MERGENCY P REPAREDNESS

................................ ................................ ................................ ..................... 9

F ACILITIES AND E QUIPM ENT M AINTENANCE

................................ ................................ ........................... 10

F IRE /L IFE S AFETY

................................ ................................ ................................ ................................ .... 16

I NDOOR E

NVIRONMENT

................................ ................................ ................................ ........................... 20

I NJURY AN

D I LLNESS P REVENTION

................................ ................................ ................................ .......... 22

L EAD M ANAGEMENT

................................ ................................ ................................ ............................... 27

M ISCELLANEOUS

................................ ................................ ................................ ................................ ..... 28

O FF

- SITE R

ISKS

................................ ................................ ................................ ................................ ........ 29

T RAFFIC AND P EDESTRIAN S AFETY

................................ ................................ ................................ ......... 33

V IOLENCE P REVENTION

................................ ................................ ................................ ........................... 34

I NDEX

................................ ................................ ................................ ................................ ...................... 36Safe School Inspection Guidebook

Preliminary Revision 08/27 /04 

## I NTRODUCTION

OEHS S AFE 

### S CHOOL 

### I NSPECTION 

### P ROGRAM
The education of our children requires a learning environment which is safe and health

- protective. Maintaining a

safe learning enviro

nment requires the commitment and active participation of school administrators, plant managers

, ce ntral support staff, and a n informed school community

. The Safe School Inspection Program was established to provide comprehensive routine assessment of saf ety conditions in all Los Angeles Unified School District s chools

.



### S AFE 

### S CHOOL 

### I NSPECTION 

### P ROCESS
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 wal k

- 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 saf ety officer and the site administrator to review the inspection findings and discuss any other safety concerns.



### O BJECTIVE OF THE 

### G UIDEBOOK

This G uidebook covers 1 4 safety areas and defines the mandatory health and safety standards applicable

to schools. Although the G uidebook 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 sit e : www.lausd

- oehs.org

.Los Angeles Unified School District

Off ice of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 2 

### A SBESTOS 

### M ANAGEMENT

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 § 7 63 .93

Current Confer with Asbestos Technical Unit (ATU) to e nsure that the Asbestos Management Plan is current and identifies the location of all A sbestos C ontaining M aterial (ACM). HSC § 25915; 40 CFR § 76 3 .93

3

- Y ear Survey Ensure a 3 Year Asbestos Survey is conducted by the Asbestos T echnical 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 § 76 3 .85

6

- M onth Surveillance Ensure a 6 Month Visual Surveillan ce 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 § 76 3 .85

Maintenance of Asbestos Containing Material (ACM) Condition Maintain all floors and other surfaces constructed of A sbestos C ontaining M aterial (ACM) in good condition to prevent deterioration. 8 CCR § 5208

Floor Buffing Do not b urnish or dry buff floors that may contain asbestos unless there is a sufficient finish to ensur e the pad does not contact Asbestos Containing M aterial. 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 § 76 3 .93

Restricted Access Restrict access to areas identified with damaged and friable A sbestos C ontaining M aterial (ACM) or areas undergoing abatement activities. 8 CCR § 5208Los Angeles Unified School District

Off ice of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 3 

### A SBESTOS 

### M ANAGEMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Training Provide 2

- hour Asbestos Awareness training to custodial and maintenance

s taff. Training should be provided within 60 days of employment. 8 C CR § 5208; 40 CFR § 763.92
Warning Signs Post warning signs on the entrance to boiler rooms, fan rooms and other maintenance areas that contain A sbestos C ontaining M aterial (ACM). W arning 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 l

abels on or immediately adjacent to known or suspected A sbestos C ontaining M aterial (ACM) in boiler room s, fan rooms and other maintenance areas

. W arning 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 § 763.95Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 4 

### C AMPUS 

### S ECURITY

Type Subtype Corrective Action for Identified Deficiency Reference

V isitation Policy Visitor’s Pass Ensure visitors entering school grounds sign

- i n and receive a visitor’s pass. OEHS Model Safe School Plan Volume 1

– Prevention Programs; Bulletin N

- 2 ; California State C ons titution, 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 st aff. 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 ChecklistLos Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 5 

### C HEMICAL 

### S AFETY

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 CF R § 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

a nd appropriate hazard warnings

. . 8 CCR § 5194; 29 CFR § 1910.1200

Training Provide employees with annual Hazard Communication training on hazardous chemicals used i n 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 Revi ew). 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 

### C HEMICAL 

### S AFETY

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 us ed 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

Restra ints 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 bon ded 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 material

s and ensure proper labeling. 8 CCR §§ 5531, 5532, 5533, 5534, 5535, 5538, 5541
Flammable Storage Labeling Ensure flammable storage bunke rs, rooms and cabinets are labeled “Flammable

- Keep Fire Away”.

Flammable Storage Room

- Location Do not locate flammable material st orage rooms in buildings occupied by students. 8 CCR § 5533; 29 CFR § 1910.10 6Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 7 

### C HEMICAL 

### S AFETY

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 apa rt 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 s witch is located outside the room. 8 CCR § 5533; 29 CFR § 1910.106

Gas Cylinder s Condition Ensure compressed gas cylinders are free of corrosion, dents, cuts, gouges, bulges and leaks. 8 CCR § 4649; 29 CFR § 19 10.101
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 g ases 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 trou ble 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 haz ard 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 PlanLos Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 8 

### C HEMICAL 

### S AFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Laboratory Safety (cont.) Locked Cabinets L ock 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 al l laboratory chemical storage areas cool (between 55 and 80 degrees F) and dry (relative humidity between 30 and 60 percent). C hemical Hygiene & Safety Plan

Hazardous Waste Management Aisle s Maintain unob structed 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
prov ided 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 gene rator. 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, contac t OEHS at (213) 241

- 3199 or www.lausd

- oehs.org

. 22 CCR § 66262.11; 40 CFR 262.11Los Angeles Unified School District

Office of Environme ntal Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 9 

### E MERGENCY 

### P

REPAREDNESS

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 Proc edures

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 a ppliances. 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 a nd 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, pitc hers, 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 disinfecte d water ev ery 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 emerg ency supply storage containers. For assistance in o btaining 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 ye ar , and maintain documentation of date of training, agenda, training materials and sign

- in sheet. CEC § 35294 Collective Bargaining Agreement UTLA & LAUSD Articles XXIV and XXVIIILos Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 10



### F ACILITIES AND 

### E QUIPMENT 

### M AINTENANCE

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/ Facil ities 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 E nsure 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/ Fa cilities 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 ChecklistLos Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 11



### F ACILITIES AND 

### E QUIPMENT 

### M AINTENANCE

Type Subtype Corrective Action for Identified Deficiency Refe rence

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

Landscap

ing 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 tter s 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, A ttachment 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 Mot orized 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



### F ACILITIES AND 

### E QUIPMENT 

### M AINTENANCE

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 breake rs 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 § 19 10.304

Guarding Ensure electrical equipment components op erating 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, Extensio n 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 Inspection Form

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 ar ea. 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



### F ACILITIES AND 

### E QUIPMENT 

### M AINTENANCE

Type Subtype Corrective Action for Identified Deficiency Reference

Kitchen Waste Management (cont.) Fats, Oils & Grease En sure 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

Permi ts 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 "walkin g" or moving.

Playground and Sport Equipment Discontinue Use Discontinue use of playground equipment not meeting current specifications. 22 CCR § 65710;

CPSC Guidelines
Inspection s 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, 44Los Angeles Unified School District

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### F ACILITIES AND 

### E QUIPMENT 

### M AINTENAN CE

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 go od condition.

Storage Ensure lawnmowers and other powered equipment is stored in a secure area, not located in bu ildings occupied by students.
Training Ensure proper training of personnel that use steam cleaner s, 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 Lo g” and e nsure trouble call s are made in a timely

manner. OEHS IIPP Template, Attachment E Annual Campus/ Facilities Inspection Form

Restrooms Adequate Facilities

– Kindergarten Provide and main tain 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 maintai n 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 Faci lities

– 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 fa cilities 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 SectionLos Angeles Unified School District

Office of Environmental Health and Safety

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### F ACILITIES AND 

### E QUIPMENT 

### M AINTENANCE

Type Su btype 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 Appe ndix 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 employe es ; 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 rest room 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 

### F IRE 

### /L IFE 

### S AFETY

Type Subtype Corrective Action for Identified Deficiency Reference

Access and Egress Emergency Exit Grill s 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 classro oms 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 Polic y

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 buildin g 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 indi cating "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

c ase of e mergency

. Signs

- General Provide visible exit signs or directional signs for all exit doors and escape pathways. If necessary, place a trouble call to the Maintena nce 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 § 1910.36Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 17 

### F IRE 

### /L IFE 

### S AFETY

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 (e xception : auditorium side of stage ). If necessary, place a trouble call to the Maintena nce 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, 1 910.26

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 a ll 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

To e 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

- Heater s M aintain 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 .12Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 18 

### F IRE 

### /L IFE 

### S AFETY

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 lane s are provided and maintained free of obstruction. LA Fire Code § 57.111.07

Fire Alarm

s

– 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 Alarm

s

– Testing Conduct and document weekly inspections of fire alarms to ensure they are in

good working o rder. 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 extinguish ers 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 Extinguishers

Hydrostatic Testing Perform 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 a nd doc ument 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 t he building to an exterior exit or an enclosed

exit stairway does not exceed 150 feet in buildings without sprinkler s or 200 feet in buildings with sprinkler s

. 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 § 1910.157Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 19 

### F IRE 

### /L IFE 

### S AFETY

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 Pro vide 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 § 1910.22Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 20 

### I NDOOR 

### E NVIRONMENT

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.
Comp laint Log Maintain log of n uisance 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 trouble

call 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 ob jectionable 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 

### I NDOOR 

### E NVIRONMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Noise Classroom Noise Contact OEHS Industrial Hygiene Section at (213) 241

- 31 99 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 Conta ct 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 no ise 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 Ind ustrial 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 Cod e Chapter 11Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 22 

### I NJURY AND 

### I LLNESS 

### P REVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Injury and Illness P revention 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

ma y be downloaded at www.lausd

- oehs.org

. 8 CCR § 3203

Death/Serious Injury Report ing 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 st

aff 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, Att achment G

Inspection s 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 implemen tation of Injury and Ill ness Prevention Program (IIPP). 8 CCR § 3203 ; OEHS IIPP TemplateLos Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 23 

### I NJURY AND 

### I LLNESS 

### P REVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Injury and Illness Prevention Program (IIPP) (cont.) Safety Comm ittee Establish S chool S afety C ommittee that: m eets at least quarterly and records meeting minutes; r

eviews results of workplace inspections and incident reports to identify safety issues and determine incident causes; r eviews all eged hazardous conditions and safety suggestions brought to the at tention 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 implement ation 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 § 1910.1030Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 24 

### I NJURY AND 

### I LLNESS 

### P REVENTION

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 B loodborne P athogen

training , including name of empl oyee, 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 statu s 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 a re 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 ar e equipped with blade guards. 29 CFR 1910.212

General Ensure proper guarding is provided and maintained on all equipment t o prev ent 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 

### I NJURY AND 

### I LLNESS 

### P REVENTION

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 § 2 3 00; 29 CFR § 1910.305

UL Approved Ensure extension cords and cables are UL approved and suitable for the conditions of use. 8 CCR § 2 3 00; 29 CFR § 1910.305

Use

- General Ensure flexible extension cords and cables are not used in place of permanent wirin g. 8 CCR § 2 3 00; 29 CFR § 1910.305

Use

– In Series Ensure extension cords , outlet multipliers and surge protectors are not used in series. 8 CCR § 2 3 00; 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 § 2 3 00; 29 CFR § 1910.305

Use

– On Metal Do not hang extension cords and cables on metal hangers or supports. 8 CCR § 2 3 00; 29 CF R § 1910.305

Use

– Through Opening Ensure extension cords and cables are not run th rough holes in walls, ceilings, floors or similar openings. 8 CCR § 2 300
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 3382Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 26 

### I NJURY AND 

### I LLNESS 

### P REVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Hearing Conser vation Program Ensure all personnel who are exposed to a time weighted average (TWA) noise level greater tha n 85 db(A)

are included in a Hearing Conservation Program. For assistance with noise monitoring, trai ning, 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 Distr ict 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 electri cal appliances pursuant to Bulletin C

- 26. Bulletin C

- 26

Medic ation Storage Ensure medication cabinet is secured at all times.
Respiratory Protection Program M aintain a writte n Respiratory Protection Program dealing with the use of

r espiratory protective equipment by employees or students

. 8 CCR § 5144; 29 CFR §§ 1910.134
Equipment Provide respiratory protection equipment when engineering/operational

cont rols 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 participatin g in interscholastic athleti

cs. 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

- 886Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 27 

### L EAD 

### M

A NAGEMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Drinking Fountains Flush drinking fountains , kitchen faucets and other water fixtures used to dispense drinking wa ter 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 clea n up paint debris

. If necessary, place a trouble call to the Mai ntenance 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 Contaminat ion 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 

### M ISCELLANEOUS

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 66Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 29 

### O FF


### - SITE 

### R ISKS

Type Subtype Corrective Action for Identified Deficiency Reference

Aband oned 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 Sourc e 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 S outh 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 occupan ts. 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 sa

fety 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 i nterrupt the learning environment. OEHS will notify a ppropriate regulatory agencies to assess and/or mitigate potential risk.
Pipeline s Off

- site survey identified one or more high pressure or petroleum pipelines that may pose a signif

icant health or safety risk to school occupants. OEHS will confer with appropriate regulatory agencies to assess and/or mitigate potential risk.

Power Line s 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 pos e 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 

### O FF


### - S ITE 

### R ISKS

Type Subtype Corrective Action for Identified Deficiency Reference

Sidewalk/Cu rb 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 pot ential 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

- 577Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 31 

### P EST 

### M ANAGEMENT

Type Subtype Corrective Action for Identified Deficiency Reference

Integrated Pest Management Program Maintain a copy of the District's Integr ated Pest Management (IPM) program in the main office. Contact Pest Managment at (213) 745

- 1435 to obtain a
copy. AB2260

Approved Pesticides List Post a current copy of the District’s Approved Pesticide Products List in the main office. CEC § 1761 2

Awareness Ensure all staff is familiar with the Integrated Pest Management ( IPM ) Policy and Program. California Education Code (CEC) § 1761 0

Notification Provide written annual notif ication 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 cop y 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 Dist rict Pest Management Tech nician

. 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 stan ding 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 f

or 72 hours after application. CEC § 1761 2

B ird 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

- 07Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 32 

### P EST 

### M ANAGEMENT

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

trou ble 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 Handb ookLos Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 33 

### T RAFFIC AND 

### P EDESTRIAN 

### S AFETY

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

o f 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/o r 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 Sc hool Plan, Volume 1

– Prevention Programs. Safe School Plan, Volume 1

– Prevention Programs
Training and Education Provide students, parents and employees with: AAA traffic safety an d pedestrian brochures; bicycle and bus s afety rules; information on pedes trian routes to and from school; student drop

- off/ pickup procedures; and seat belt /car safety information. Memorandum CT

- 1Los Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 34 

### V IOLENCE 

### P REVENTION

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 Prog rams 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 C risis Intervention T

eam and the sit e administrator has identified t eam members. Model Safe School Plan, Volume 1

- Prevention Programs ; Bulletin 9 62

Handbook Maintain a copy of the most recen t 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

Inter vention Notebook Maintain an intervention notebook to document the specifics of each critical incident and Crisis Intervention T eam actions taken in response

. Model Safe School Plan, Volume 1

- Prevention Programs

Traini ng Ensure that school C risis Intervention T

eam meet regularly for training and review of the crisis intervention plan. T raining documentation should include name of trainer, trainer affiliation, and location of t raining and date of traini ng. 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 XXVIIILos Angeles Unified School District

Office of Environmental Health and Safety

Safe School Inspection Guidebook Preliminary Revision 08/27 /04 35 

### V IOLENCE 

### P REVENTION

Type Subtype Corrective Action for Identified Deficiency Reference

Human Relations Leadership Team (HRLT) Team Establish a Human Relations Le adership 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 Educ ation, School Assessment Checklist," pages 76

- 79, 4

- 92.Safe School Inspection Guidebook 36

Revised 07/01/04 

## I NDEX

3

- Year Survey

................................ ................................ ...... 2 6

- Month Surveillance

................................ ........................... 2 Abandoned Vehicle

................................ ............................ 29 Access

................................ ................................ ................ 17 Access and Egress

................................ .............................. 16 Accident Report

................................ ................................ . 22 Ad equate 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

- 199 4)

.................... 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 P athogens

................................ ................. 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 K it

................................ ................................ ........ 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 Interven tion

................................ .............................. 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 Extingui

shers

- 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 S pacing

.......................... 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 Gu arding

................................ ................................ . 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

................................ ....................... 26Safe School Inspection Guidebook 37

Revised 07/01/04 Housekeeping

................................ ................................ ..... 11 Human Relation s 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 Contai ning 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 P ermits

................................ ................................ ............... 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 Recordkeepin g

................................ ............................. 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

................................ ......... 8Safe School Inspection Guidebook 38

Revised 07/01/04 Storage Temperatu re

................................ ............................ 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 W astewater Management

................................ ................... 15 Water Damage

................................ ................................ .... 20 Weeds

................................ ................................ ................. 11 Wheel Chocks

................................ ................................ .... 11Environmental Health Conditions in California’s Portable Classrooms

VI - I 

## APPENDIX VI

WORKING DRAFT SUGGESTIONS FOR PREVENTIVE AND REMEDIAL ACTIONSEnvironmental 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 docum ent. 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 s ee 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 ventila tion systems for providing constant ventilation when the central system is inefficient or too noi sy. Include air intakes in locations away from outdoor pollutant sources. Design the systems and measure indoor-outdoor pressureEnvironmental 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 in ches 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 cons truction 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 replac ement; 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 fo r 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 ).