HEALTHY SCHOOLS NETWORK, INC.
with
Members of the Coalition for Healthier Schools
To:
US EPA/Indoor Environments Division
Re:
Technical comments on EPA's draft "Design Tools for Schools"
Fm:
Coalition for Healthier Schools and Healthy Schools Network, Inc.
Date: July 29, 2002
Healthy Schools Network coordinated the development of the following technical
comments on EPA's new draft "Designs Tools for Schools". For clarity and brevity, the
technical comments follow the text that EPA made available for public comment and are in
bulleted outline form.
General comments.
We extend congratulations to US EPA for making this document available for public
comment. It is a well done, well integrated, and highly detailed manual that will tend to
promote healthier school design and construction procedures. It promotes a holistic
approach to Indoor Environmental Quality (IEQ). But it does not quite fulfill the goals of a
true high performance building or a healthy school facility. We think this can and should be
fixed.
We recommend that new sections be added on Acoustics, Daylighting, Energy Efficiency,
Construction and Demolition Waste Management, and Water Conservation, features that
can produce cost or resource savings and can affect occupant health and productivity. It
should also be made clear that “Commissioning” is a process that can be applied to many
building elements. Because these key issues were omitted in the draft, if the manual is used
as the sole source of design guidance it will tend to drive up school construction costs,
causing long-term negative repercussions that are otherwise easily avoidable.
We also strongly recommend that the manual reference the goals and specifications of the
federal Healthy and High Performance Schools Act which is intended to offer state-based
incentives and information for energy and water conservation as well as materials and
equipment selection processes.
We also recognize that it can be very difficult to monitor local school construction activities.
For this reason we recommend an active advisory committee that includes the school facility
director. New York State regulations require such as committee with a monitoring role.
Because of the level of detail of the draft manual, we also recommend that EPA indicate in
the text to the readers-- local school districts and communities who may be new to design
and construction-- which issues are usually addressed by which types of technical specialists,
and show which items are of high, medium, and lesser priority in designing a healthier
school. If items are essential to child, occupant, or worker health & safety, those should be
clearly identified as such and not shown as "as needed" or "if feasible" options. For
example, the protection of occupants from asbestos, lead, and chemical fumes in buildings
under renovation is not really an “option”; occupant health protection is legitimately part of
the total project.
We also strongly recommend that EPA lead off its manual with "child environmental health
101", since so few state and local communities have enjoyed the benefit of the information
or its practical applications.
SECTION BY SECTION BULLETED COMMENTS FOLLOW
THE TEXT OUTLINE, BELOW:
http://www.epa.gov/http://www.epa.gov/
DRAFT - DO NOT CITE OR QUOTE!
In the next five years, an
estimated 6,000 new
schools will be built and
thousands of portable
classrooms put into
service in the United
States.
The information
presented here is
designed to help school
districts and facility
planners design the next
generation of learning
environments so that the
school facility will help rather than hinder schools in achieving their
core mission of educating
children.
Hot Topics | Site Map |
Links | Facilities and
Learning | High
Performance Schools |
Case Studies | Tool Box |
EPA Programs for Schools
Introduction | Design
Overview | Pre-Design |
Schematic Design |
Heating, Ventilation and
Air-Conditioning (HVAC) |
Controlling Pollutants and
Sources | Moisture Control
| Construction |
Commissioning |
Operations and
Maintenance | Renovation
and Repair of Existing
Schools | Portable
(relocatable) Classrooms
Introduction
Indoor air quality is a critically
important aspect of creating and
maintaining school facilities.
IAQ Design Tools for Schools will
help school districts find the
information resources they need
to design new school facilities,
and repair existing facilities.
Though its primary focus is on
indoor air quality, it is also
intended to encourage school
districts to embrace the concept
of designing High Performance
Schools. High performance
school design is about taking a
holistic and integrated approach
to addressing a myriad of
important – and sometimes
competing – priorities such as
energy efficiency, indoor air
quality, day-lighting, materials
efficiency, and safety and doing
so in the context of tight
budgets and limited staff.
Design Overview
The typical design process for
schools begins with
programming and selection of
the architectural-engineering
team. It then proceeds through
schematic design, design
development, contract
documents, construction,
commissioning and occupancy.
The sooner high performance
goals – including those intended
to ensure superior indoor air
quality – are considered in the
design process, the easier and
less costly they are to
incorporate.
Heating, Ventilation and AirConditioning Systems
(HVAC)
The main purposes of an HVAC
system are to maintain good
indoor air quality and provide
thermal comfort, two key
requirements for high
performance schools. HVAC
systems are among the largest
energy consumers in schools.
Controlling Pollutants and
Sources
To protect indoor
environmental quality the
designer should understand
indoor air quality problems and
seek to eliminate potential
sources of contamination that
originate from outdoors as well
as indoors.
Moisture Control
Excess moisture indoors can
cause major damage to the
building structure, as well as to
furnishings and to finish
materials like floors, walls, and
ceilings. Excess moisture can
trigger the growth of bacteria
and mold that not only damage
the school facility, but can lead
to health and performance
problems for students and staff.
Construction
No matter how well designed a
building, poor job-site
construction practices can
frustrate the best design by
allowing moisture and other
contaminants to become
potential long term problems.
Pre-Design
Preventive job-site practices can
Building a school with indoor air prevent residual problems with
quality that supports the school indoor air quality in the
completed building and reduce
in its primary mission of
undue health risks for workers.
educating children requires
attention to indoor air quality
Commissioning
issues at the very beginning of
If building materials, equipment
Related Topics:
Operations and Maintenance
Effective maintenance and operations procedures are fundamentally important to sustaining
the performance of all building systems. Student health and productivity can be affected when
building systems fail to operate as designed. Sub-standard maintenance or incorrect operation
of building systems usually results from a combination of factors. First, maintenance budgets
are often the first to be reduced or eliminated when money becomes tight. Second, designers
and contractors typically provide the building staff minimal or no training about how the
building systems are supposed to operate or be maintained. Finally, schools eventually lose their
institutional knowledge of the building systems because of staff turnover and lack of
communication.
Renovation and Repair of Existing Schools
You can minimize problems during renovation and repair by making good indoor air quality
(IAQ) one of the criteria during project planning. Also, contract language and negotiations with
service providers (contractors) can help ensure that proper materials and procedures are used,
such as performing work during unoccupied periods in the school. This Renovation and
Repairs Checklist is for use before and during renovation projects.
Portable (Relocatable) Classrooms
Portable -- or "relocatable" -- classrooms have been a feature of many school districts for years.
From a district's perspective, the two advantages of portable classrooms are low initial cost and
short time between specification and occupancy. They are intended to provide flexibility to
school districts, enabling quick response to demographic changes and providing the ability to
be moved from one school to another as demographics change. In reality, portable classrooms
are seldom moved and become permanent fixtures of the school.
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EPA Home | Privacy and Security Notice | Contact Us
Last updated on Friday, June 28th, 2002
URL: http://www.epa.gov/iaq/schooldesign/
TECHNICAL COMMENTS BY COALITION FOR HEALTHIER SCHOOLS.
Introduction.


Move and expand introductory comments on child environmental health to the lead
paragraph position;
Stress prevention of all problems through excellence in engineering and design;



Strengthen the section by citing NIOSH school investigations and health issues;
Enrich the web links to states with new legislation and regulations on indoor
environments;
Add link to NYC/DDC green building design and other public agencies and not for
profit public interest groups with expertise in green design programs.
Design Overview.

Insert new paragraph about need to protect occupant health in buildings under
renovation (parts take place in the design and construction documents)
Pre-Design.
Planning: include 'easy to clean' and maintenance and instructional storage spaces as goals of
over-all efforts; identify existing building health/structural problems before entering design
phase.
Siting: add creation of a local community advisory group to assist board with site
identification and selection; teachers, support staff, and parents are in the
community/neighborhood and may have knowledge of available sites; add NOISE to site
assessment.
A&E Selection: recommend that the local district consult with its state energy or
environment offices on energy efficiency audits/engineering/design issues; add reference
checks, including firm's track record on health & safety, meeting budgets and goals, working
with community; verify that firm is familiar with materials selection and willing to work with
outside agencies; ask firm to include a dedicate IAQ expert on the design team.

In talking about integrated design, the design section should call out special design
deliverables that relate to IAQ and to energy efficiency, for example the provision by
the A&E team of computerized energy modeling.

We also recommend that EPA provide practical guidance on how local schools can
write an RFP for A&E work consistent with the final guidance document.
Schematic Design.


HVAC.
Expand web links and other cites, including sections on Daylighting, Acoustics, etc.
that are addressed in this phase. HSN's guide on Daylighting should be cited.
Plan to incorporate "pest-proofing" into the finished structure, including secure and
separate food storage areas, garbage and trash bins, recycling containers, landscaping
to discourage pest entry. Beyond Pesticides provided a checklist that is attached.

While we agree with the statement that sealed buildings, if properly maintained, have
energy and filtering advantages, given the well-documented problems of deferred
maintenance and inadequate custodial staffing levels, amply highlighted by EPA's
intensive work on IAQ/TfS program, operable windows have specific advantages.
EPA should encourage simple, occupant-friendly systems that are easy to maintain.

ASHRAE ventilation: It is important for EPA to include a note for school
communities that ASHRAE industry committees have historically not included
representatives of children's environmental health and thus the recommended
standards may not necessarily be protective of children.

CO2 sensors: EPA should add information about programming the sensor to restart equipment when CO2 levels are low, not when they reach an alert level. Normal
equipment settings will lag the human sensors; CO2 levels may not return to
acceptable levels until a class is dismissed.

Air Filtration: say "animal" dander, not 'cat' dander; this is also a good place to note
the escalating numbers of children with asthma and other environmentally triggered
health problems whose federal educational and civil rights include accessible facilities
and programs.

Air Cleaning for Gaseous Contaminants: link to text on the source reduction of
VOC's
Commissioning:
Commissioning applies to more than just HVAC systems. This concept could well be a
section unto itself; we recommend that it include recommendations to provide operating
manuals and training for facility staff that will operate the new systems.
Commissioning of HVAC systems should also take place during actual operating conditions:
for example, in natural ventilation where the body heat of occupants and equipment help
create air currents, without warm bodies or operating equipment or products in routine use,
there is no way to determine how effective or efficient the installed system is.
Controlling Pollutants.
This section should contain information or cross-link to protection of occupant health in
schools under renovation.
Preventing the Entry... add, "...shoes, or on clothing", and dele "that have not been
effectively cleaned at building entry points"...since this implies that mats can clean all
contaminants. Keep and enhance strong statement about making school entryways places
where outdoor dirt and debris can be significantly mitigated. Entryway information should
also link to the siting and landscaping choices.
Radon: add data on health effects of radon
Sewer Gas: health effects-- dele "paralysis", insert "seizures and comas".
Materials Selection. This section is very weak; needs significant improvements to help schools
participate in environmentally preferable purchasing (EPP) of products with few or no longterm or short term health effects, and that are chemically stable. Thus schools can enjoy the
benefits of low-emissions and sturdy, durable interiors. Without this information, a new
generation of energy efficient schools, children and personnel at risk of avoidable health
problems and health risks. An example of how materials specs can be written to ensure EPP
products and finishes should also be provided, in context of 'lowest responsible bidder'
stipulations of public agencies.
Flooring: We recommend setting or referencing goals on creating a building with lowemissions interiors and that are easy to clean and to maintain. Durable and resilient floorings
can also include rubber, cork, and linoleum.

Acoustics is a separate issue that stands alone and should not be addressed as a
'carpet' issue. Carpets are only one of many ways to reduce noise.

Consider occupant ages and activities when selecting flooring: carpets are not
appropriate for cafeterias and must be replaced if waterlogged and not dried out. As
a way to underscore the child health message, EPA should mention that in practical
usage, some school occupants will pee, vomit, bleed, nap and roll around, all on the
same carpet (that is documented as serving as a reservoir for pesticide residues and
heavy metals), all in the same week.

We also recommend that EPA include a note, referencing the well-documented lack
of maintenance and inadequate custodial staffing levels, and urge that carpets be
installed only where there is an 'endowment' or guarantee of daily maintenance with
HEPA vacuums or other provisions according to the manufacturer's specifications-for the life of the carpet.
Moisture Control: Preserve the Building, Prevent Molds and Pests.
This section is quite good; EPA should stress relationship of moisture control to mold
prevention and pest prevention. Also the manual should take note of special areas, such as
swimming pools and showers, that will need extra ventilation to control moisture. Moisture
damage can be on walls, floors, ceilings, and include rust build-up on lights and other
fixtures.
Construction.


Add web links to HSN guides on protection of occupant health during renovation
and to NYS Education Dept. regulations on the same topic.
Good section in which to cover Construction & Demolition Waste Management, as
well as sealing the site to prevent pest infiltration into newly built areas. Construction
monitoring should include daily clean-ups, removal of debris, posting of hazardous
areas, and inspections of areas such as ventilation ducts to make sure dead animals,
soda cans, and lunch leftovers are not sealed into the ductwork or building cavities as
work progresses.
Pest prevention techniques for construction/renovation:
§ Put screens on windows and doors
§ Install weather stripping around windows and doors
§ Seal off all gaps and openings between the inside and outside of
buildings, i.e. caulk, paint, sheet metal, steel wool, spray foam
insulation, cement or screen openings around all window frames, cables,
pipes, vents, duct work, exhaust fans, utility wires and conduits.
(Priority should be made to those areas leading to and from kitchen
areas, cafeterias, bathrooms, and storage.)
§ Install screen covers over floor drains.
§ Landscape so that plant materials are at least one foot away from
building.
§ Use gravel or stone mulch or keep bark mulch at least one foot away from the building.
§ Screen all intake and out-take vents.
§ Plan for and set aside secured areas for garbage cans and dumpsters
§ Plan for and set aside collecting and storage area for recyclables
§ Do not store paper goods in same area where food and trash is kept.
§ Insulate hot and cold water pipes.
§ Install dehumidifiers in areas of high moisture.
§ Ensure that drains, strainers and grates are easy to remove and clean.
§ Provide storage for paper products, books, and cardboard boxes at least 12 inches off
the floor, and not touching walls or moist areas.
§ Store products on metal, not wood, shelves.
§ Provide ventilation and drying areas for floor mops and cleaning supplies.
§ Maintain adequate drainage away from buildings.
§ Where possible, install low pressure sodium vapor bulbs which emit
yellow light and direct the beams towards the building.
>> Building operating manual should include IPM practices.
-- 30 -Technical contributors to this public comment document include:
Stephen Ashkin, The Ashkin Group, Bloomington, IN
Claire Barnett, MBA, Healthy Schools Network, Albany, NY
Kristin Benson, Children's Environmental Health Network, Washington, DC
Hillary Brown, AIA, New Civic Works, NY, NY
Ruth Etzel, MD, PhD, FAAP, Anchorage, AK
Sarah Gibson, Esq., Boston, MA (and MA Healthy Schools Network)
Ellie Goldberg, MEd, Healthy Kids: the Key to Basics, Newton, MA
Wendy Horde, CIH, New York State United Teachers, Albany, NY
Leyla McCurdy, MS, National Environmental Education and Training Foundation
Richard Monaco, CDF, HSN Board Member, Saratoga Springs, NY
Kagan Owens, Beyond Pesticides, Washington, DC
The national ad hoc Coalition for Healthier Schools seeks to assure every child and school
employee an environmentally healthy school that is clean and in good repair. The Coalition,
which and has helped win $1.2billion in federal funds for school repairs and secured
enactment last winter of the federal Healthy and High Performance Schools Act, is
coordinated by Healthy Schools Network.
For more information:
Claire Barnett, Executive Director
Healthy Schools Network, Inc.
773 Madison Avenue
Albany, NY 12208
www.healthyschools.org
518-462-0632, cbarnett@healthyschools.org