Coordinator's Guide for Indoor Air Quality: Appendix B

Appendix B - Developing Indoor Air Policies

An IAQ policy statement demonstrates a strong commitment by the school administration to address the health and comfort of staff and students, as well as the environmental quality in the school. In addition, an IAQ policy sets an overall direction for efforts to prevent and correct IAQ problems. General issues that may require policies include, but are not limited to:

• Painting
• Smoking
• Renovations and repairs
• Pest management
• Ventilation system operation
• School supply and purchasing
• Food or pets in the classroom
• Disinfectants
• Vehicle idling
• and maintenance schedules

This appendix presents general considerations related to developing an IAQ policy. In addition, it presents four sample IAQ policies targeted to specific indoor pollutant sources. The first sample is a policy on integrated pest management (IPM). The second sample is a memo and letter to parents regarding painting. The third sample is a policy that limits bus idling on school grounds and includes a sample memo to bus drivers about anti-idling procedures. The final sample is a nonsmoking policy, including a sample letter to staff. The samples presented are intended only as guides, and may be modified in any way to meet the site-specific needs and intent of individual schools.

• General Considerations
• Sample Pest Management Policy Statement
• Sample Painting Memo
• Sample Parental Notification Letter for School Painting
• Anti-Idling Policy
• Nonsmoking Policy

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General Considerations

An IAQ policy should include the following components:

• A statement indicating that the school administration’s commitment to good IAQ and the health, safety, and comfort of staff and students.
• A statement indicating the intent to identify, prevent, and correct IAQ problems.
• Authorization of an IAQ Coordinator for each school or district and delegation of authorities to the IAQ Coordinator.
• Guidance on appropriate steps for maintaining good IAQ (see specific activities in the various IAQ checklists for ideas).
• Guidance on appropriate actions for correcting IAQ problems.
• Reporting requirements.

Developing an IAQ policy should be an open process. A health and safety committee is a good forum for developing consensus recommendations. In the absence of an existing committee, consider establishing an ad hoc committee comprised of administrators, teachers, support personnel, school health officers, maintenance personnel, physicians, union representatives, and community leaders. Interested parents may also wish to serve on this committee.

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Sample Pest Management Policy Statement

• Pests
• Pest Managements
• Integrated Pest Management Procedures
• Education
• Record Keeping
• Notification
• Pesticide Storage and Purchase
• Pesticide Applicators

When a pesticide must be used to meet important management goals, the least hazardous material adequate to control the pest should be chosen and label directions should be followed exactly. The application of pesticides may be subject to

• School district policies and procedures
• The Federal Insecticide, Fungicide and Rodenticide Act (7 United States Code 136 et seq.)
• EPA regulations in 40 Code of Federal Regulations
• OSHA regulations
• and state and local regulations

Pests

Pests are unwanted populations of living organisms (animals, plants, or microorganisms). Strategies for managing pest populations will be influenced by the pest species and whether that species poses a threat to people, property, or the environment.

Pest Management

Approved pest management plans should be developed for the site and should include proposed pest management measures to:

• Reduce any potential human health hazard or to protect against a significant threat to public safety.
• Prevent loss of or damage to school structures or property.
• Prevent pests from spreading into the community or to plant and animal populations beyond the site.
• Enhance the quality of life to students, staff and others.

Integrated Pest Management Procedures

Integrated pest management (IPM) procedures will be used to determine when to control pests and whether to use:

• Mechanical
• Physical
• Chemical
• or biological means

IPM practitioners depend on current, comprehensive information about the pest and its environment and the best available pest control methods. Applying IPM principles prevents unacceptable levels of pest activity and damage by the most economical means and with the least possible hazard to people, property and the environment.

The decision to use a pesticide will be based on a review of all other available options and a determination that these options are not acceptable or are not feasible. Cost or staffing considerations alone will not be adequate justification for use of chemical control agents, and selected non-chemical pest management methods will be implemented whenever possible to provide the desired control. It is the policy of this school district to utilize IPM principles to manage pest populations adequately. The full range of alternatives, including no action, will be considered.

Education

• Staff
• Students
• Pest managers
• and the public

will be educated about potential school pest problems and the IPM policies and procedures that will be implemented.

Record Keeping

Records of pesticide use shall be maintained onsite to meet the requirements of the state regulatory agency and school board. Records must be current and accurate for IPM to be effective. In addition, pest surveillance data sheets that record the number of pests or other indicators of pest populations should be maintained to verify the need for treatments.

Notification

[School name] will be responsible for notifying school staff and parents in advance of any pesticide applications.

Pesticide Storage and Purchase

Pesticide purchases will be limited to the amount authorized by [committee/department] for use during the year. Pesticides will be stored and disposed of in accordance with the EPA-registered label directions and state regulations. Pesticides must be stored in an area inaccessible to students or unauthorized personnel.

Pesticide Applicators

Pesticide applicators must have a working knowledge of the principles and practices of IPM and use only pesticides approved by this school district. They must follow regulations and label precautions. Applicators must comply with this school district IPM policy and pest management plan.

Pests and pesticides can pose significant problems and risks to people, property and the environment. It is, therefore, the policy of [school name] to incorporate IPM procedures for control of structural and landscape pests. This policy will minimize the amount and toxicity of pesticides used in the school.

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Sample Painting Memo

MEMORANDUM

TO: School Principal
FROM: District Facilities Manager

This memo and attachments are provided for your use in preparation for the interior painting of your school. Based on past experience, certain steps must be taken by the school prior to painting to ensure minimal disruption to the teaching process and to ensure that maximum information is communicated to the parents.

The Paint Foreman or a designated representative will meet with you no later than one month prior to the start of work to coordinate the effort and discuss any items that may be of interest to you. Classrooms or other confined spaces must be vacated throughout the painting process. The attached Material Safety Data Sheets will provide information on drying time and other precautions that must be taken. The principal reserves the right not to allow occupancy of a classroom until he/she is satisfied that it will not pose a hazard to the students. The paint crew can complete an average classroom in 1 day.

As it pertains to cafeterias, painting will not start until after lunch is completed. This means painting will occur only 2 to 3 hours in the afternoon each working day. Thus, the painting of this area will likely take longer than in any other part of the school.

The attached notices to parents are provided for school consideration. All parents must be notified by some means. Two choices are offered, one in the form of an official memorandum; the other less formal option is a "flyer."

Parents may express concern over their child’s presence in school during the painting. Since the length of time required to paint the interior of your school will be a minimum of [# of months], this issue should be resolved mutually on a case-by-case basis.

If you have any questions concerning this memo or the painting process, please contact [contact name], or discuss your questions or concerns at the scheduled pre-painting meeting.

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Sample Parental Notification Letter for School Painting

Name
Address
City, State, Zip Code

Dear Parent or Guardian:

The Maintenance Division plans to start painting in our school on or about [day and date].

The school building is an important factor in the success of the total educational program. Proper maintenance of school buildings is necessary to provide a healthy and pleasant atmosphere. The majority of paint being used in [name] Public Schools is latex water-based. Some heavy traffic areas and trim will require the use of oil-based paint. Paints containing lead or mercury are never used in school painting.

Instructional areas will be unoccupied during painting and drying times. We anticipate that paint crews will be in the school for a period of [# of days], beginning on [day and date].

The health and safety of all students is a primary consideration as the painting crews undertake this maintenance and beautification project. If you have any questions or concerns about the scheduled painting, please feel free to contact me at [phone #].

With the cooperation of parents, students and staff, this painting project will result in a bright, new look for our school. I hope you will stop by when the project is completed to see the results for yourself!

Sincerely,

Principal

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Anti-Idling Policy

This section includes a sample anti-idling policy and memo. The announcement letter should address the main issues covered by the school’s anti-idling policy:

• Explicitly state when/where/for how long buses are allowed to idle.
• Define individuals and vehicles covered by the policy.
• Outline the stages and dates of policy implementation.
• State the enforcement procedures taken when the policy is violated.
• Identify the appropriate contact for questions and concerns.

The sample policy is intended to provide a framework for developing an anti-idling policy and highlights issues of emission exposure and health concerns. The level of detail and specificity of any policy will depend on the type of school, the actions to be taken and the level of communication required to reach all affected individuals. A simple, clear-cut policy, for example, will require few specifics and will be easily monitored.

The anti-idling policy should be placed in the personnel manual (including that of bus drivers), employee handbook, school by-laws, or another location that will facilitate the distribution of this information to all affected individuals. Signs can also be posted in areas where cars, buses, or delivery trucks wait to remind drivers that their engines should be turned off.

Following is a sample anti-idling policy that reduces idling on school grounds.

For additional information on mobile sources and anti-idling, see Appendix I: Mobile Sources" in the IAQ Reference Guide.

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Sample Anti-Idling Policy

[Forest Lake School] is committed to providing a healthy and productive environment for all persons using our school. In light of the significant risk posed by school bus exhaust emissions, especially to children, [Forest Lake] is implementing an [anti-idling policy or limited bus idling policy]. This policy is intended to improve the health and safety of all individuals in or around the school and school grounds and reduce risks associated with exposure to diesel exhaust such as:

• Aggravated respiratory and cardiovascular conditions
• Decreased lung function
• Acute respiratory symptoms
• and chronic bronchitis

Queuing of buses for pick-up and drop-off as well as periods of idling during the bus commute itself can cause particular problems. The following steps indicate the exact timing of specific changes to current operations and outline the procedures for conflict resolution and enforcement:

1. Implementation of Policy to [Eliminate or Reduce] Exposure to School Bus Exhaust Emissions, also known as diesel exhaust emissions.
   Beginning immediately, [Forest Lake] requires all buses to limit their idling on school grounds to:
   • Improve surrounding air quality
   • Protect the health of drivers, students and others
   • Conserve fuel (save money)
   • and decrease engine wear
2. Policy Guidelines to Reduce Exposure to School Bus Exhaust Emissions.
   This rule applies to any bus service, including home-to-school, activity, or charter transportation.
   1. To the extent possible, eliminate idling upon reaching your destination:
      • While waiting for passengers to board at place of origin, all engines should be shut off.
      • When arriving at your location, all buses should be shut off as soon as it is practical; buses should not idle while waiting for passengers.
   2. During morning start-up, buses should idle no longer than necessary to bring engines to proper operating temperature and to defrost all windows.
   3. Exceptions to the policy may be made when the air temperature is below 32 degrees, and when it is necessary to run the engine to operate required safety equipment or to maintain a safe environment for passengers with special health needs. The guidelines for maximum engine idling are:
      • Above 32° F: 3 minutes
      • Between — 10° and 32° F: 10 minutes
      • Below — 10° F: no limit
   4. Signs will be posted to remind all (car, bus and truck) drivers of our school’s Anti-Idling Policy.
3. Conflict Resolution
   Bus drivers, employees and visitors are expected to honor the anti-idling policy at all school buildings and facilities by shutting off their engines upon arrival. Individual complaints or concerns regarding the implementation and/or enforcement of this policy should be discussed with the school bus fleet manager, [designated person], who will contact the individual bus driver. Concerns about staff or parents who idle their vehicles on school grounds can be directed to [designated person] at [phone #].
4. Enforcement of Policy
   All persons share in the responsibility of adhering to and enforcing this policy. Any person violating this policy will be subject to the similar disciplinary actions that accompany other infractions of our policies including:
   • Oral reminder
   • Written reprimand
   • Probation

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Sample Anti-Idling Letter

To: All School Bus Drivers

Re: Limiting Bus Idling

The [State School Transportation Association] has teamed up with the [State Environmental Agency] and the [Local School District] to protect school children and each of you from excessive exposure to diesel exhaust emissions. As part of this effort, we support and encourage you to follow their guidelines restricting engine idling time whenever practical, effective immediately.

To the extent possible, eliminate idling:

• While waiting for passengers to board at place of origin, shut off all engines.
• When arriving at your location, shut off all buses as soon as it is practical.
• Guidelines for maximum engine idling [consistent with existing state regulations]:
  • Above 32° F: 3 minutes
  • Between — 10° and 32° F: 10 minutes
  • Below — 10° F: no limit

Please help us do our part to reduce air pollution and protect children’s (and your own) health. Minimizing vehicle idling will also save money by reducing fuel consumption and engine wear.

Thank you for your support and cooperation with this effort.

[School district] School Bus Drivers Doing Their Share for Clean Air!

Sincerely yours,

Fleet Manager

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Nonsmoking Policy

This section includes a sample announcement for a nonsmoking policy and memo. The announcement letter should address the following main issues covered by the school’s nonsmoking policy:

• Define individuals who are covered by the policy.
• Clarify exactly what constitutes smoking. Explicitly state where smoking is prohibited (if permitted at all).
• Outline the stages and dates of policy implementation.
• State the enforcement procedures taken when the policy is violated.
• Identify the appropriate contact for questions and concerns.
• Define individuals who are covered by the policy.

The policy may also include information on smoking cessation or other staff education programs being offered or covered by the school.

The sample policy is intended to provide a framework for developing a nonsmoking policy and highlights issues of particular importance for both large and small schools. The level of detail and specificity of any policy will depend on the type of school, the actions to be taken and the level of communication required to reach all affected individuals. A simple, clear-cut policy, for example, will require few specifics and will be easily enforced.

The nonsmoking policy should be placed in the personnel manual, employee handbook, school by-laws, or another location that will facilitate the distribution of this information to all affected individuals.

The following sample nonsmoking policy eliminates smoking indoors. If separately ventilated designated smoking rooms are being provided, this policy can be easily revised by omitting the step about eliminating smoking on all school grounds. Add specifics regarding additional enforcement procedures for potential and repeated infractions.

For additional information on secondhand smoke, see Appendix F: "Secondhand Smoke" in the IAQ Reference Guide.

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Sample Nonsmoking Policy

[Forest Lake School] is committed to providing a healthy and productive environment for all persons using our school. In light of the significant risk posed by secondhand tobacco smoke to human health as well as to sensitive equipment, [Forest Lake] has decided to implement a [nonsmoking policy or smoke control policy]. This policy is intended to improve the health and safety of all individuals using the school. The following steps indicate the exact timing of specific changes to current operations and outline the procedures for conflict resolution and enforcement.

1. Implementation of Policy to [Eliminate or Reduce] Exposure to Secondhand Smoke, also known as Environmental Tobacco Smoke (ETS)
   1. Beginning in [month, date], [Forest Lake] will offer smoking cessation programs to all school staff.
   2. Effective immediately, smoking will be prohibited on [Forest Lake] all school grounds. "No Smoking" signs will be posted as necessary to remind personnel and visitors of this policy.
      
      [Alternative Text for Separately Ventilated Smoking Room Policy:]
      
      Effective [October 1], smoking will be prohibited in meetings and all enclosed areas including conference rooms, offices and restrooms. Smoking will also be prohibited in all common areas including
      • The cafeteria
      • Break rooms
      • Hallways
      • Reception areas
      • and outside building entrances
      "No Smoking" signs will be posted in the restricted areas. Smoking will be permitted only in designated rooms that have been equipped with separate exhaust fans that isolate environmental tobacco smoke from nonsmoking areas. [NOTE: See Appendix F: "Secondhand Smoke" of the IAQ Reference Guide if school is receiving Federal funding.]
2. Conflict Resolution
   Employees and visitors are expected to honor the smoking restrictions at all school buildings and facilities. Individual complaints or concerns regarding the implementation and/or enforcement of this policy should be discussed with your supervisor [or other designated person]. If the supervisor is unable to resolve the individual complaint or concern, the employee may request that their concern be directed to the Nonsmoking Policy Committee [or other designated person or committee].
3. Enforcement of Policy
   All persons share in the responsibility of adhering to and enforcing this policy. Any person violating this policy will be subject to the same disciplinary actions that accompany any infraction of our policies including:
   • Employee counseling
   • Oral reminder
   • Written reprimand
   • Probation
   • Termination

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Sample Nonsmoking Memo

MEMORANDUM

To: All [Forest Lake] School Staff

From: [Name], Principal

Re: [Forest Lake’s] Nonsmoking Policy

In response to increasing staff concern and the U.S. Environmental Protection Agency’s (EPA) findings that secondhand smoke may be harmful to children’s health, [Forest Lake] is instituting a smoke-free workplace policy, effective immediately. This policy applies to all property owned or leased by [Forest Lake] and includes all:

• Offices
• Hallways
• Waiting rooms
• Restrooms
• Lunchrooms
• Elevators
• Meeting rooms
• and community areas

This policy applies to all staff and visitors. Smoking will not be allowed in areas adjacent to the building entrances.

[Forest Lake] considers any use of tobacco products that produce smoke as smoking. This definition includes, but is not limited to, cigars, cigarettes and pipes.

[Forest Lake] has taken several steps to facilitate a smooth transition to a smoke-free workplace:

• The policy will begin immediately.
• Beginning in [month], a smoking cessation class will be offered for individuals who would like to take this opportunity to quit smoking. Smoking cessation classes will continue to be offered through [month & year].
• Effective [date], smoking will be prohibited in all common areas.
• Effective [date], smoking will be prohibited throughout all buildings.

The success of this policy will depend upon the thoughtfulness, consideration and cooperation of smokers and nonsmokers. Everyone shares in the responsibility for adhering to and enforcing the policy. Any problems should be brought to the attention of the appropriate supervisor and handled through the normal chain of command. Individuals who violate this policy will be subject to the same disciplinary actions that accompany infraction of other school rules. Refer to your employee handbook for disciplinary policies.

The [Forest Lake] school administration welcomes questions and comments regarding the new nonsmoking policy. Please feel free to contact our Indoor Air Quality Coordinator, [name], at extension [####]; [he/she] will be happy to respond to your questions and concerns and can provide information on the health effects of secondhand tobacco smoke.

For more information, see Indoor Air Quality.