Sensible Guide for
Healthier School Renovations
Key Environmental Health Considerations
When Renovating Schools
                 United States
                 Environmental Protection
                 Agency

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   Keep   Kids  Safe   During
      School   Renovations
School renovations have the potential
to increase children's exposures to harmful
contaminants which can lead to serious health risks.
Addressing the unique challenges and opportunities
of school renovation proactively can help the school
save money and support student performance.
School environments play an important role in the
health and academic success of children. Children
spend 90% of their time indoors and much of
that time is spent in school. Recent surveys report
that 53% of public schools need to spend money
on repairs, renovations, and modernization — at an
estimated overall cost of $197 billion, Institute of
Education Sciences, Condition of America's Public School
Facilities: 2012-2013. Indoor environmental quality
can be compromised during school renovations,
potentially exposing building occupants to
damaging hazardous airborne chemicals (indoor air
contaminants). Common indoor air contaminants
include asbestos, lead, mold, radon, and
polychlorinated biphenyls (PCBs). Dermal contact
or incidental ingestion may also be significant
exposure pathways for chemicals (e.g., PCBs or lead)
contained in building materials
or construction debris.

Children are especially susceptible to the damaging
effects of environmental hazards. A child's
developing biological systems are often more
sensitive to environmental stressors, and children are
frequently more heavily exposed to toxic substances
in the environment than are adults. Children in
minority, low-income, and other underserved
populations, as well as  children with disabilities,
can experience higher exposures to multiple
environmental contaminants where they live, learn,
and play, and may be at a disproportionate risk for
associated health effects.

Healthy school environments play an important
role  in the health and academic success of children.
Exposure to environmental hazards in schools can
negatively impact the health of students and school
staff. Unhealthy school environments can also affect
attendance, concentration, and performance, as well
as lead to expensive, time-consuming cleanup and
remediation activities.
During school renovations it's important to be
aware of potential environmental hazards and
know the best practices for healthy and sustainable
schools. It is also an opportunity to evaluate
hazardous materials storage, become more energy-
efficient, integrate pest management by design, and
incorporate green building practices.


This booklet provides school administrators, facility
managers, staff and the school community with an
overview of how to avoid key environmental health
hazards and ways to minimize children's exposures
as they prepare for and undergo renovations. School
renovations should be consistent with applicable
local, state and federal environmental health
regulations. More in-depth guidance on all of these
risks has been developed by EPA, state agencies,
and other organizations. School administrators,
facility managers, and staff should reference the
information in this booklet and resources listed
on pages 19-20 to plan and conduct healthier school
renovations.

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Protect   Indoor  Air  Quality
Protect Indoor Air Quality
Good indoor air quality (IAQ) in schools is a critical
component of a healthy and comfortable learning
environment. IAQ affects the health, productivity,
performance, and comfort of students, teachers
and staff.

When there is poor IAQ in a school building, students
and staff may suffer from common symptoms of
respiratory infections and allergic or other adverse
health reactions. Renovations may significantly
alter the IAQ of a school building. IAQ topics
are particularly relevant for renovation projects and
present unique challenges. Some of the IAQ issues
related to construction activities include the presence
of asbestos, mold, radon, vapor intrusion, lead and
PCBs. These require planning during the design
phase and special precautions during the execution
phase of a renovation or construction project.

IAQ Issues during
Construction Activities
Construction dust and materials such as adhesives,
paints, and sealants have the potential to degrade
IAQ. Poor IAQ increases the risk of developing
health problems that affect the overall performance
of students or staff. It is a best management practice
to conduct construction activities outside of the
                               .
school year whenever possible to reduce impacts
to students and staff. However, when construction
activities must be conducted during the school
year, developing and implementing an IAQ plan
can help protect the building inhabitants' health
by preventing exposure to hazardous chemicals.
Communication with building occupants is essential
for reducing impacts. Communication should begin
during the planning phase of any construction
activities and should continue through the project's
completion. Refer to EPA's IAQ Design Tools for Schools
website for additional details on IAQ Plans.
           Integrating indoor air quality protections and
                   energy efficiency improvements
   EPA's Energy Savings Plus Health IAQ Guidelines for School
   Building Upgrades provides specific assessment protocols
   and recommendations for protecting and even enhancing IAQ
   during school energy efficiency retrofits and other building
   upgrade projects.
   http://www2.epa.gov/iaq-schools/indoor-air-quality-design-
   tools-schools
   Download EPA's School IAQ Assessment mobile app
   to keep IAQ on track before, during and after school
   building upgrades.

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During  School   Renovations
         Construction Dust
         Construction activities generate a lot of dust
         that may contain hazardous chemicals. Exposure
         to construction dust can irritate the eyes and
         nose, causing immediate health effects, and may
         also trigger asthma attacks in students and staff.
         Reducing the amount of dust in the air by sealing
         off areas (particularly ductwork) with plastic sheeting,
         ensuring adequate ventilation, and using high-
         efficiency participate air (HEPA) filtration attached
         to dust-generating equipment will protect the health
         and comfort of building occupants and may reduce
         the risk of asthma attacks. Other best practices
         include cleaning up at the end of the workday and
         having a separate outdoor staging area for activities
         that generate dust, such as sawing and sanding.
         Construction Materials
         New building materials should meet building design
         specifications and be in compliance with applicable
         federal, state, local regulations and building codes.
         Verifying product content/labels is particularly
         important, especially when building materials are
         imported from other countries that may not have
         as stringent specifications (e.g., asbestos containing
         building materials are still manufactured and used in
         other countries). Schools should strive to ensure that
         quality building materials are installed and potential
         IAQ issues are avoided by selecting low-toxicity,
         lowemitting, moisture-resistant materials during
         renovation design.
Construction materials such as adhesives, paints,
or sealants can volatilize as they dry or cure,
contributing to indoor air quality issues. Properly
ventilating areas where these construction materials
are used and stored, and promptly cleaning up any
spills, can reduce impacts. In addition, construction
materials should be staged away from classrooms
and heating, ventilation, and air conditioning
(HVAC) intakes during renovations. Care should
also be taken  to protect materials from moisture and
humidity to avoid introducing potential hazards
such as mold.

Equipment  and
Vehicle  Emissions
Emissions from diesel- or gas-powered construction
equipment can impact the health and comfort
of students and staff near the construction site.
Exposure to these emissions may cause symptoms
such as headache, nausea, coughing, difficulty
breathing, or irritation of the eyes, nose, and throat.
Diesel- or gas-powered equipment should be stored
and operated away from classrooms, HVAC intakes,
doors and windows, and playground/sporting areas.
If possible, use newer or retrofitted equipment and
limit engine idling.

  Best Management Practices:
  • Plan ahead to maintain good indoor air
   quality during renovations.

  • Reduce potential exposure to construction
   dust by sealing off work areas from non-
   construction workers, using equipment
   with HEPA filters, and frequently cleaning
   work areas.

  • Select staging areas for construction
   materials, equipment, and vehicles away from
   classrooms and HVAC intake.

  • Review product labels and product
   specification sheets to verify content. When
   in doubt, ask the manufacturer to verify
   contents or lack thereof.

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                         Asbestos
Know the risks
Asbestos is a mineral fiber that naturally occurs in
rock and soil. Because of its fiber strength and heat
resistance, asbestos has been used in a variety of
building construction materials for insulation and
as a fire retardant.

When asbestos containing material (ACM) is in
good, non-friable condition (meaning it cannot be
crumbled, pulverized, or reduced to powder by hand
pressure), emission of asbestos fibers from ACM
to air generally does not occur. As the condition
of ACM deteriorates or renovation activities disturb
ACM, asbestos fibers can be released into air.
Asbestos fibers can stay suspended for hours and
up to days, creating an exposure risk. Exposure
to airborne asbestos fibers can cause serious health
issues and may lead to asbestosis, mesothelioma, or
lung cancer. Other cancers, primarily of the digestive
tract, are also possible.
          ASBESTOS
           REMOVAL
Know the regulations
Building materials with greater than one percent
asbestos are considered ACM and are subject to
federal and state regulations.
EPA regulations include:
•  The Toxic Substances Control Act (TSCA)
•  Asbestos Hazard Emergency Response
  Act (AHERA)
•  Asbestos Model Accreditation Plan
•  Asbestos National Emission Standard for
  Hazardous Air Pollutants (Asbestos NESHAP)
Know where to find ACM
in Schools
ACM is commonly found in:
                                          • Insulation

                                          • Adhesives

                                          • Millboard

                                          • Textured paint

                                          • Cement sheets/board
                    Floor tiles and mastic

                    Roofing

                    Acoustic ceiling tiles

                    Caulking

                    Quick-set cement
                                           Joint/patching compounds

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Know how to prevent exposure
The NESHAP regulations under the Clean Air Act
specify work practices for asbestos to be followed
during school renovations. The regulations require
the school to notify the appropriate state agency
before any demolition or renovations of buildings
that could contain a certain threshold amount of ACM.

Under AHERA, schools are required to perform an
inspection to determine whether ACM are present
and re-inspect ACM every three years. Schools
are required to develop an asbestos management
plan (AMP) and designate a person responsible
for implementing the AMP. Refer to EPA website
Asbestos in School Buildings and EPA Document
Model AHERA Asbestos Management Plan for further
information on drafting an AMP.

When school renovation projects involve ACM,
special procedures must be performed by licensed
and trained asbestos abatement professionals.
Special containment, equipment, and disposal
procedures are also  required.

Additional, more stringent local and state regulations
may also apply during renovations when ACM is
disturbed (e.g., Occupational  Health and Safety
Administration (OSHA) Safety and Health
Regulations for Construction).
Best Management Practices:
• Include the school's AHERA designated
  person in communications during the design
  phase of renovation projects to ensure ACM
  is properly addressed and no new ACM is
  utilized (e.g., thermal system insulation).

• Review the AMP and ACM reports to ensure
  that ACM remains untouched or proper
  ACM abatement procedures are included in
  the design.

• When deciding how to address ACM
  during renovations, consider the impact
  to the renovation budget, long-term costs,
  and asbestos management responsibilities
  associated with each alternative.

• Set a project schedule so that asbestos
  abatement occurs outside of the school year
  or during holiday breaks.

• Communicate and coordinate with the
  project manager and site manager during
  asbestos abatement and renovation projects.

• Be sure to request and review the final air
  clearance sampling results prior to allowing
  students and staff to re-occupy the affected
  area after asbestos abatement.

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                                    Mold
Know the risks
There are several thousand different species of
molds. They can grow on virtually any organic
substance, as long as moisture and oxygen are
present. There are molds that can grow on wood,
paper, carpet, foods, and insulation.

All molds have the potential to cause health effects
that may include irritation of the eyes, skin, nose,
throat, and lungs. Molds can trigger allergic reactions
or even asthma attacks in people allergic to mold.
Some molds are known to produce potent toxins
or chemical irritants.

Know where to find mold
Molds grow best in damp and humid conditions.
They spread by releasing spores. When excessive
moisture accumulates in buildings or on building
materials, mold growth often occurs, particularly
if the moisture problem remains undiscovered
or unaddressed. It is impossible to eliminate all
mold and mold spores in the indoor environment.
However, mold growth can be controlled indoors
by controlling moisture.
The key to controlling mold is removing the
source(s) of moisture that caused the mold issue in
the first place. Check for humidity and condensation
problems as well as actual water leaks, maintenance
issues, and HVAC system problems. Fix any issues
that are identified.

Know how  to identify and
cleanup mold
No EPA or other  federal agency threshold limits
have been set for mold or mold spores. Mold is
generally identified with visual inspection or by
smell, but  sampling can be done to determine
the source (s) of the mold contamination and
the specific mold present. Analytical methods
recommended by the American Industrial Hygiene
Association (AIHA) or the American Conference of
Governmental Industrial Hygienists (ACGIH; should be
used to identify mold.

The steps needed  to clean up mold vary based on
the magnitude and surface area of mold growth.
A more cautious or conservative approach to
remediation is warranted in cases where:

•  a particularly toxic mold species has been
  identified or is suspected;

•  when extensive hidden mold is expected (such as
  behind vinyl wallpaper or in the HVAC system);

•  when the chances of the mold becoming airborne
  are estimated to be high; or

•  sensitive  individuals (e.g., those with severe
  allergies or asthma) are present.

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If the affected area is small or less than 10 square
feet, small-scale mold remediation efforts may
include cleaning or limited building material
removal and replacement. Always use personal
protective equipment (PPE) including gloves and
eye  protection when working with mold. Additional
PPE such as N-95 respirators or respirators with
HEPA niters may also be necessary to ensure
compliance with OSHA standards. Building
occupants should be isolated from the affected
area by setting up containment areas with proper
ventilation when mold remediation is underway.
Know how to prevent exposure
Renovation projects may have to tackle existing
mold issues (known or hidden) and include mold
remediation. A key objective of any renovation
should be to maintain proper moisture control after
renovations are complete. Thus, the renovation
design should include proper construction
techniques and building materials to prevent future
moisture problems. Renovation design specifications
need to address:

• moisture control issues related to surface water
  drainage;

• foundation construction/repair;

• wall construction;

• roof and ceiling assembly;

• plumbing system installation/repairs; and

• HVAC system installation/modifications.


  Best Management Practices:
  • When moisture problems are found,
    promptly initiate repairs to minimize
    mold growth.

  • If the extent of the mold issue is severe
    and a more time-critical removal (with
    containment) is needed, consider removing
    mold outside of school hours, during
    evenings or weekends, if it cannot be delayed
    to summer or a holiday break.

  • Do not paint or caulk over surfaces  that
    have mold.

  • Maintain proper moisture control after
    renovations are complete.

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                 Vapor   Intrusion
Know the risks
Vapor intrusion generally occurs when changes in
pressure and/or temperature cause a chemical to
evaporate in the underground environment and
penetrate buildings by migrating through subsurface
soil and into cracks of the building's foundation
slab. Chemicals that may cause IAQ issues through
vapor intrusion are primarily from a category of
compounds known as volatile organic compounds
(VOCs). Semi-volatile organic compounds or
inorganic chemicals (e.g. mercury) may also volatilize
and present an IAQ issue. In rare cases, the vapors
may accumulate in occupied buildings to levels that
may pose immediate safety hazards (e.g., explosion),
acute health effects, or odors. However, in most
cases, vapor concentrations are low and the main
concern is whether the volatile chemical (s) pose
an unacceptable risk of developing chronic health
effects due to long-term exposure at these low levels.
Chronic health effect(s) vary based on the specific
volatile chemical, but typically carcinogenic effects
and/or non-carcinogenic effects are risks associated
with prolonged exposure to volatile chemicals. For
example, leukemia and decreased white blood cell
count are the health effects associated with chronic
benzene exposure.
Know where to find vapors
There must be a source of contamination in soil
or groundwater near the school in order for a vapor
intrusion issue to exist. EPA considers soil
or ground-water contamination within 100 feet of
a school building to be a potential source for vapor
intrusion (see EPA Source). A potential source could
be a former leaking underground storage tank
that resulted in contaminated ground-water within
100 feet of a school building. A review of the
current and historical land use in the vicinity of
the school will help identify if there is a potential
source for vapor intrusion. If a suspected source
is identified, often, a seasonal vapor intrusion
evaluation (including sampling and analysis) is
needed to confirm the presence or absence of
volatile chemicals. Groundwater, soil gas, ambient
air, and indoor air- samples may be collected
by a trained professional and sent to a certified
analytical laboratory for analysis. The sample results
are compared to chemical-specific action levels
(under EPA and/or state regulations and guidance,
depending on the situation) to determine if source
removal, cleanup, or vapor intrusion mitigation
systems are needed. Vapor intrusion mitigation
methods may include sealing openings (filling
in cracks in the floor slab and gaps), installing
vapor barriers, passive venting, installing sub-slab
depressurization, or adjusting a building's HVAC
system  to over-pressurize the building.

Know how to prevent exposure
Vapor intrusion is an important consideration when
planning a renovation. First, if a renovation project
includes expansion of the school it is important
to perform due diligence and verify that there are
no potential  sources of vapor intrusion on the land
where the expansion is set to occur. Second, if
the renovation project includes an existing school
building that has a vapor intrusion issue, then
mitigation methods need to be incorporated into
the renovation design or the current vapor intrusion
mitigation system(s) should remain in place.

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Best Management Practices:
• Review land use records, typically available at
  city and county offices, to determine potential
  sources  for vapor intrusion, especially when
  considering school expansion projects.

• Maintain a library with any vapor intrusion
  evaluation reports, vapor intrusion mitigation
  systems construction reports, and vapor
  intrusion mitigation systems operation and
  maintenance (O&M) reports for future
  reference.
• Be actively involved in the renovation design
  phase when there is an existing vapor
  intrusion issue, and ensure that the renovation
  designs incorporate adequate vapor intrusion
  mitigation methods or leave the current vapor
  intrusion mitigation systems in place.

• Vapor intrusion can be a highly complex
  issue and challenging to address. Reach out to
  available EPA and state resources with questions
  and concerns regarding vapor intrusion, such as
  the EPA Vapor Intrusion website.
     How Vapor Intrusion Works
                                                                  Clean Groundwater
           Contaminate
           Groundwater

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           Hazardous   Materials
                       and  Mercury
      Know the risks
      Hazardous materials, such as glues, sealants, acids,
      bases, oxidizers, compressed gases, flammable
      solvents, and mercury can often be found in schools.
      During renovation activities, these hazardous
      materials may need to be cleaned out or relocated.
      Improper disposal, spills and other accidents can
      pose health and safety risks to students and staff
      as well as incur considerable expenses, including
      potential liabilities/lawsuits. Hazardous materials
      and chemicals are associated with a variety of
      serious health problems, including cancer, brain and
      nervous system disorders, reproductive disorders,
      organ damage, and asthma. Chemicals also can
      irritate the skin, eyes, nose and throat. Some
      chemicals pose significant physical safety hazards,
      such as fire or explosion risks.
Mercury is a hazardous chemical of particular
concern because the nervous system is very sensitive
to all forms of mercury. Exposure to high levels
of metallic, inorganic, or organic mercury can
permanently damage the brain and kidneys. Effects
on brain functioning may result in irritability,
shyness, tremors, changes in vision or hearing, and
memory problems. Short-term exposure to high
levels of metallic mercury vapors may cause lung
damage, nausea, vomiting, diarrhea, increased
blood pressure or heart rate, skin rashes, and/or
eye irritation.

Know the regulations
Hazardous materials and chemicals may need to be
managed and disposed of as hazardous waste under
Resource Conservation and Recovery Act (RCRA)
or state regulations. Refer to ERA'S Schools: Chemical
Management Regulation webpage for additional
information. Specifically, mercury wastes must
be properly managed and disposed of if it meets
the toxicity characteristics of RCRA hazardous
waste. Mercury-containing batteries, thermostats,
and lamps are managed under the Universal Waste
Program, provided the state does not regulate the
wastes more stringently.

Know where to find hazardous
materials and mercury
Hazardous materials may be found in science
laboratories or classrooms, art classrooms, shop or
mechanic classrooms, or maintenance closets.

Some materials containing mercury may be found
throughout school buildings and some common
sources of mercury in schools include:

• Glass thermometers

• Fluorescent (CFL) lamps and light bulbs

• Science equipment

• Thermostats, switches, and other electrical devices
10

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Know How to Prevent
Exposures
Having a chemical management program can help
schools reduce the risk of chemical exposures and
accidents. Program information can help renovation
project managers plan for and mitigate risks.
Individuals with knowledge of chemical hazards
should be consulted before attempting to move any
chemicals, as some may have become shock-sensitive
or explosive over time. If hazardous chemicals need
to be temporarily relocating during renovations,
designate a temporary storage area that has proper
ventilation, and adequate space to accommodate the
chemical-specific handling and storage requirements,
including temperature control.
When renovations remove mercury-containing
equipment, special handling and disposal requirements
are necessary to avoid a release. Schools should
conduct and maintain an up-to-date inventory
list of all mercury-containing equipment prior to
renovation; so, proper removal procedures can be
incorporated into the renovation ahead of time.

  Best Management Practices:
  • Establish a chemical management program
    for preventing and/or controlling a variety of
    health and safety hazards in schools.

  • Ensure all chemicals are properly labeled and
    stored before renovations begin. Ensure that
    OSHA materials safety data sheets (MSDS)
    for each product are readily displayed near
    chemical storage areas.

  • Renovation provides an opportunity for
    schools to remove inappropriate, outdated,
    unknown and unnecessary chemicals from
    schools. EPA's Schools:  Chemical Management
    Regulation webpage provides the tools to
    successfully implement a  cleanout.

  • If possible consider removing all mercury
    compounds and mercury-containing
    equipment from the school, and discontinue
    their use.

  • Isolate and label the mercury-containing
    devices to ensure proper handling and
    disposal. Dispose of mercury and mercury-
    containing devices at a facility permitted
    to accept hazardous waste and/or
    universal waste. Contact your county, state
    environmental, or solid waste office for
    services available in your  area.

  • Never crush or break  fluorescent lamps,
    because mercury will be released.
                                                                                                     11

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                  Lead   Based   Paint
       Know the risks
       Lead is a naturally occurring metal that has been
       used in a variety of products, including primer,
       varnish, paints, plumbing pipes, batteries, glassware,
       and metal products (e.g., solder). Lead exposure
       can occur through ingestion or inhalation. Lead
       based paint (LBP) is of particular concern for
       schools because it can chip and become dust, and
       be ingested through hand-to-mouth contact, or be
       sanded and inhaled as dust particulates.

       There is no safe level of lead exposure. It can
       cause several health effects, including anemia,
       decreased kidney function, high blood pressure, and
       reproductive issues. Children under the age of six
       are especially susceptible to lead exposure and may
       have additional health effects including behavior and
       learning problems, lower IQ, hyperactivity, slowed
       growth, or hearing problems. In rare cases, ingestion
       of lead can cause seizures, coma and even death.

       LBP was banned as a consumer product in 1978.
       Current EPA regulations define LBP as paint
       containing more than 0.05% lead by weight or
       surface coatings containing more than 1.0 milligram
       per square centimeter (mg/cm2) of lead.
       EPA Lead-Safe Certified Guide to Renovate Right
12
Know the regulations
EPA regulates lead renovation, repair, and painting
(RRP) under the TSCA Sections 402(a) and 404 as
well as 40 CFR Part 745 Subpart E. Additional state
and federal regulations may apply to LBP (e.g., the
Residential Lead-Based Paint Hazard Reduction Act
of 1992 and OSHA Safety and Health Regulations
for Construction).

Under the RRP Rule, paint is assumed to be LBP
unless analytical data shows otherwise. The RRP rule
requires that firms performing renovation, repair,
and painting projects that disturb lead-based paint
in child-occupied facilities built before 1978 have
their firm certified by EPA (or an EPA authorized
state), use certified renovators who are trained
by EPA-approved training providers and follow
lead-safe work practices. A child-occupied facility
is narrowly defined as a building, or portion of a
building, constructed prior to 1978, visited regularly
by the same child, under 6 years of age, on at least
two different days within any week (Sunday through
Saturday period), provided that each day's visit lasts
at least 3 hours and the combined weekly visits
last at least 6 hours, and the combined annual visits
last at least 60 hours.

The RRP rule also has a pre-renovation education
component and requires distribution of a lead
hazard information pamphlet regarding the potential
risk of exposure from renovation activities within a
child-occuplied facility.

Know where to find LBP
Schools constructed after 1978 are unlikely to have
an issue with LBP, but old painted furniture or
bookcases could potentially have LBP present.
Schools built prior to 1978 may still have LBP present
on interior or exterior walls under new layers of paint.
LBP can also be found on playground equipment or
sport/recreational areas (e.g., athletic field bleachers).

Dried paint can be tested for lead by collecting paint
chips and sending them to an accredited analytical
laboratory.  Alternatively, a trained and certified lead
inspector can use an X-ray fluorescence analyzer on
paint chips or surfaces to provide real-time results
on whether LBP is present or absent. If LBP  is

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present on painted surfaces it can be removed
or enclosed.

Know  how to  prevent exposure
Common  renovation activities, like sanding, cutting
and demolition, can create hazardous lead dust
and chips. LBP can cause challenges for school
renovation projects, even if it doesn't meet the
definition  of child-occupied facility, because LBP
should be  left untouched or must be addressed
with lead-safe work practices under OSHA Safety
and Health Regulations for Construction. In
schools built prior to 1978, it is a best management
practice to identify LBP early so the renovation
design accounts for LBP. Special work practices and
disposal procedures are required if LBP abatement
is needed.  Therefore, LBP abatement has to be
sequenced before renovations.
Best Management Practices:
• Maintain records and reports showing the
  locations of LBP in the school, LBP testing
  results, and areas where LBP abatement has
  been performed.

• Hire a certified lead-safe contractor if
  renovations will disturb paint in child-
  occupied facilities.

• Be actively involved in renovation design
  phase when LBP is present and
  share available LBP  reports with the
  renovation firm.

• If the LBP records are incomplete or not
  current for areas where renovations are
  planned, conduct additional LBP testing
  prior to renovation.  It is much less costly
  to test than to clean up lead dust released
  throughout the school during renovations.

• Conduct lead dust sampling after LBP
  abatement projects have been performed. Be
  sure to request and review the final clearance
  sampling results prior to allowing students
  and staff to re-occupy the affected area after
  LBP abatement.
                                       Did you  know?
    Lead can leach into drinking water as it moves through a building's lead-pipe distribution system. Even though the drinking
    water you receive meets federal and state standards, your school may have elevated lead levels due to plumbing materials
    and water use patterns. Consider testing the drinking water and correcting any problems during renovations to reduce lead
    exposure to students and staff. Refer to 3Ts for Reducing Lead in Drinking Water in Schools for additional information.
    In addition, dyes or pigments in LBP may also contain polychlorinated biphenyls (PCBs). Recommend concurrently testing
    paint for lead and PCBs.
                                                                                                         13

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                    Polychlorinated
                               Biphenyls
      Polychlorinated biphenyls (PCBs) are a class of
      synthetic organic chemicals that were widely used in
      building construction, including schools built between
      about 1950 and the late 1970s. The manufacture and
      use of PCBs were banned by the TSCA and phased
      out by 1979, except for certain limited uses. PCBs
      are toxic and continue to be closely regulated.

      If PCBs are present in buildings, the scope and
      process of renovation often becomes substantially
      more complex and time-consuming. The potential
      presence of PCBs in schools also presents regulatory
      compliance issues. The process and specific cleanup
      requirements are less straight forward than for the
      other materials addressed in this booklet.

      EPA has several web pages (listed at the end of
      this booklet) that provide guidance on addressing
      PCBs in schools and other buildings, including
      building renovation.
Know the risks
Exposure to elevated levels of PCBs has been
demonstrated to cause cancer in animals and non-
cancer effects on the immune, reproductive, nervous,
and endocrine systems in animals and humans.
Studies in human populations provide supportive
evidence for potential cancer and non-cancer health
effects of PCBs. Exposure in school buildings
during renovation may occur through inhalation
of PCBs in the air (vapors or dust-borne); ingestion
of PCB-containing dust; and through direct
dermal contact.

Know the regulations
PCBs are regulated by EPA under the TSCA
through the PCB Manufacturing, Processing,
Distribution in Commerce, and Use Prohibitions
Rule (40 CFR Part 761). The regulation  is very
complex and the presence of PCBs can substantially
complicate renovation.

A few of the relevant TSCA regulatory  requirements
for schools include:

 •  Prohibition on PCB uses not allowed in the
   TSCA PCB regulations;

 •  Proper disposal of PCB-containing material;

 •  EPA approval when cleaning up or leaving
   PCBs in place.

Know where to find  PCBs
Fluorescent light ballasts and caulking are the most
common sources of PCBs in schools. Most schools
have implemented programs for removing fluorescent
light ballasts but some ballasts or residues may
remain. PCB-containing caulk has been  found in
window glazing and around window frames, door
frames, in masonry columns and in other building
materials. However each building is different and
PCBs may also be found in electrical equipment,
floor tile mastic, adhesives, sealants, paint, and other
construction materials. Additionally, residues from
previous PCB releases may still be present and
may have been absorbed into other porous
building materials.
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Know how to prevent exposure
The TSCA regulates use of PCBs and places the
responsibility for compliance on the user; in this
case the school. EPA guidance on preventing
exposure is presented on ERA'S website regarding
PCBs in buildings. The information on many of the
technical and regulatory issues for PCB-containing
caulk is useful for addressing the similar issues for
other PCB-containing materials.
 Renovation projects may have to deal with PCB-
 containing materials or electric equipment during the
 design phase. This may include testing of materials,
 obtaining EPA approval, worker protection and
 management and disposal of any PCB-containing
 materials or equipment. Disposal of PCB-containing
 materials must be at an approved facility.
  Best Management Practices:
  • Replace PCB-containing fluorescent light
    fixtures with energy-efficient lighting (e.g. LED
    lighting) as a green building practice; a complete
    lighting retrofit reduces the PCB hazards and
    increases energy efficiency by 30-50 percent
  • Evaluate the potential for the presence
    of PCB-containing building materials prior
    to renovation
  • Comply with OSHA regulations and employ
    personal protective equipment for dust-
    generating work
• During renovation with the potential for PCB-
  containing building materials, set appropriate
  controls in place to minimize spreading dust
  during the renovation and/or repair activity
• Maximize use of manual tools that minimize
  generation of heat and dust
• Employ properly trained workers to clean areas
  potentially contaminated by PCB-containing
  materials using wet cloths and vacuums with
  HEPA filters
• Check TSCA requirements for proper disposal
  of different cleanup-related materials
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                                       Radon
       Know the risks
       Radon is an odorless, colorless, tasteless radioactive
       gas that is produced by the decay of naturally
       occurring uranium in soil and water. Radon can
       be found in both outdoor and indoor air. Ionizing
       radiation emitted from radioactive chemicals is a
       proven carcinogen and prolonged exposure to radon
       may cause lung cancer. EPA estimates that about
       21,000 lung cancer deaths each year in the U.S. are
       radon-related.
       EPA estimates that nearly one in five U.S. schools
       have at least one ground level room with short-term
       radon levels above 4 picoCuries per liter (pCi/L);
       the level at which the EPA suggests mitigation
       (see EPA source).

       Know where to find radon
       Radon enters any type of building (new or
       old) through cracks in the foundation and can
       accumulate in rooms on or below ground level.
       EPA's national long-term goal for radon is that
       air within buildings is consistent with ambient air
       outside of buildings. Radon levels in indoor air can
       be determined by long-term or short-term testing.
Know how to prevent exposure
When renovations change the dynamics of the
HVAC system of a building, such as adding/
removing walls or changing air flow patterns, the
radon levels can also change. Renovations that
change HVAC air exchange rates or pressure
differentials can result in a radon issue when there
was not one before, or reduce an existing radon issue.

EPA recommends that all schools conduct an
initial short-term test and follow-up with testing
if the radon level is above 4 pCi/L. Follow-up
testing should include short-term and long-term
testing to get a better understanding of the school-
year average radon level. If the follow-up testing
indicates that radon levels are above 4 pCi/L,
schools should take steps to reduce the radon levels.
  Best Management Practices:
  • Maintain records of radon testing and
    installed radon mitigation systems. Review
    these records and incorporate radon
    reduction methods into the renovation
    design and/or leave existing radon mitigation
    systems in place. For additional information
    on radon reduction, refer to ERA'S Radon
    Website (http://www2.epa.gov/radon).

  • Conduct post-renovation radon testing to
    verify that radon is not an IAQ issue.

  • Disseminate information to parents, students,
    and staff as needed.
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               Construction   &
                       Demolition
Know the risks
School renovations often generate construction
and demolition (C&D) debris which can include
concrete, wood, metals, glass, and salvaged building
components. Sometimes these materials may contain
asbestos, lead-based paint, mercury, or other chemicals
that present a hazard to human health and the
environment. Therefore, it's important to characterize
materials early on in a project to avoid releases on
school grounds and to ensure that the C&D debris
are properly managed.

C&D debris can consist of three types  of waste:
(1) inert or nonhazardous waste; (2) hazardous waste
as regulated by the EPA under the Resource
Conservation and Recovery Act (RCRA); and
(3) items that contain hazardous components that
might be regulated by some states.
Know what is in C&D debris
C&D debris needs to be characterized to determine
if it is hazardous and needs to be handled as
hazardous waste. Demolition of an old building may
result in lead-based paint debris, asphalt waste, or
treated wood debris. Renovation personnel may use
screening test results, analytical data, or consult the
hazardous waste regulations for listed wastes
to determine whether the waste is hazardous.
Know the regulations
Schools are subject to the hazardous waste regulations
of RCRA, the same as any other business within
the US. Keep in mind that other EPA regulations may
apply; depending on what C&D debris contains.
For example, C&D debris containing asbestos may be
subject to NESFJAP, and waste containing PCBs may
be subject to TSCA. Removal of mercury containing
material or equipment (i.e., fluorescent lamps,
switches, thermostats) requires special handling and
disposal under the universal waste rules. Also, be
aware that the department of transportation (DOT)
or state regulations may be more stringent than the
EPA regulations.

Know how to prevent exposure
Developing a waste management plan before
renovation work begins can help schools identify
what hazardous wastes may be present in C&D
debris, and proper ways to contain the waste to
prevent pollution and possible exposure. In addition,
determining whether any C&D debris can be reused
or recycled can help schools save money on disposal
fees and help the environment.


  Best Management Practices:
  • Develop a waste management plan to predict
   the types and quantities of waste that will
   be generated during the renovation project,
   identify proper containment of these
   materials, and identify ways to reduce the
   amount of waste that goes to landfills
   (i.e., reuse onsite, recycle, donate or sell).
  • Hire contractors that are trained and certified
   to handle and transport the types of wastes that
   will be generated during the renovation project.
                      Sustainable  Building  Practices
   If the C&D debris do not include chemicals that can present a hazard such as lead or asbestos, project managers should
   consider alternatives such as recycling or reuse. This practice will conserve landfill space, save money in avoided disposal
   fees and potentially generate income from the sales of salvageable materials.
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               References   and
                           Resources
Indoor Air Quality (IAQ)
EPA IAQ Tools for School
http://www2.epa.gov/iaq-schools
EPA Toolkit for Safe Chemical Management
in K-12 Schools
http://archive.epa.gov/schools/toolkit.html
EPA IAQ Design Tools for Schools
http://www2.epa.gov/iaq-schools/indoor-air-quality-design-
tools-schools
EPA IAQ Design Tools for Schools - Construction
http://www2.epa.gov/iaq-schools/construction-part-indoor-air-
quality-design-tools-schools
EPA IAQ Design Tools for Schools - Renovation
http://www2.epa.gov/iaq-schools/renovation-and-repair-part-
indoor-air-quality-design-tools-schools
Energy Efficiency Plus Health: IAQ Guidelines for
School Building Upgrades
http://www2.epa.gov/iaq-schools/iaq-guidelines-school-building-
upgrades-energy-savings-pl us-health
EPA IAQ Reference Guide
http://www2.epa.gov/iaq-schools/indoor-air-quality-tools-
schools-action-kit
EPA Managing Asthma in the School Environment
http://www2.epa.gov/iaq-schools/managing-asthma-school-
environment
EPA Clean Construction
http://www2.epa.gov/cleandiesel
Indoor Air Quality - Healthy School Environments
http://www2.epa.gov/schools-air-water-quality
OSHA Indoor Air Quality Website
https://www.osha.gov/SLTC/indoorairquality/index.html
NOISH Indoor Environmental Quality, Dampness and
Mold in Buildings Website
http://www.cdc.gov/niosh/topics/indoorenv/mold.html
NIOSH Good Practice Guidelines for Maintaining
Acceptable Indoor Environmental Quality During
Construction and Renovation Projects
http://www.cdc.gov/niosh/topics/indoorenv/constructionieq.html

Asbestos
EPA Asbestos
http://www2.epa.gov/asbestos
EPA Asbestos in School Buildings
http://www2.epa.gov/asbestos/school-buildings
EPA Asbestos NESHAP
http://www2.epa.gov/asbestos/asbestos-neshap

Mold
EPA Mold Remediation in Schools &
Commercial Buildings
http://www2.epa.gov/mold/mold-remediation-schools-and-
commercial-buildings-guide
EPA Mold and Moisture
http://www2.epa.gov/mold/mold-and-indoor-air-quality-schools
EPA Moisture Control Guidance for Building Design,
Construction and Maintenance
http://www2.epa.gov/indoor-air-quality-iaq/moisture-control-
guidance-building-design-construction-and-maintenance-O
Radon
EPA Radon
http://www2.epa.gov/radon
EPA Radon in Schools
http://www2.epa.gov/radon/radon-schools
ATSDR Toxicological Profile for Radon
http://www.atsdr.cdc.gov/toxprofiles/tp.asp?id=407&tid=71
Vapor Intrusion
EPA Vapor Intrusion
http://www2.epa.gov/vaporintrusion
EPA CLU-IN Vapor Intrusion
http://www.clu-in.org/issues/default.focus/sec/Va porjntrusion/
cat/Overview/
Hazardous  Materials  & Mercury
Mercury Concerns During Renovations for a Healthy
School Environment
http://www2.epa.gov/schools-healthy-buildings/mercury-
concerns-during-renovations-healthy-school-environment
Toolkit for Safe Chemical Management in K-12 Schools
http://www2.epa.gov/schools-chemicals/toolkit-safe-chemical-
management-k-12-schools
Chemical Use and Management in Schools
http://www2.epa.gov/schools-chemicals
Mercury in Schools Case Studies
http://www2.epa.gov/schools/case-studies-about-mercury-
cleanups-schools
EPA Schools and Mercury
http://www2.epa.gov/mercury
EPA Steps to Take When a CFL Breaks
http://www2.epa.gov/cfl/cleaning-broken-cfl
EPA Recycling CFLs
http://www2.epa.gov/cfl/recycling-and-disposal-after-cfl-burns-
outttwhererecycle
ATSDR Don't Mess with Mercury
http://www.atsdr.cdc.gov/dontmesswithmercury/
Lead
EPA Lead
http://www2.epa.gov/lead
EPA Renovation,  Repair and Painting Program
http://www2.epa.gov/lead/renovation-repair-and-painting-program
EPA Renovation,  Repair and Painting Program: Operators
of Childcare Facilities
http://www2.epa.gov/lead/renovation-repair-and-painting-
program-operators-childcare-facilities
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                      References   and
                                  Resources
       EPA Lead-Safe Certified Guide to Renovate Right
       http://www2.epa.gov/sites/praduction/files/documents/
       renovaterightbrochure.pdf

       PCBs
       Renovations and PCBs for a Healthy School Environment
       http://www2.epa.gov/schools-healthy-buildings/renovations-
       and-polychlorinated-biphenyls-pcbs-healthy-school-environment
       EPA Steps to Safe Renovation and Abatement of
       Buildings That Have PCB-Containing Caulk
       http://www3.epa.gov/epawaste/hazard/tsd/pcbs/pubs/caulk/guide/
       EPA PCB-Containing Fluorescent Light Ballasts in Schools
       http://www3.epa.gov/epawaste/hazard/tsd/pcbs/pubs/ballasts.htm
       EPA TSCA Disposal Requirements for Fluorescent
       Light Ballasts
       http://www3.epa.gov/epawaste/hazard/tsd/pcbs/pubs/
       ballastchart.pdf
       EPA PCB Site Revitalization Guidance Under the TSCA
       http://www3.epa.gov/epawaste/hazard/tsd/pcbs/pubs/pcb-
       guid3-06.pdf
       ATSDRToxicological Profile for Polychlorinated Biphenyls
       http://www.atsdr.cdc.gov/toxprofiles/tp.asp?id=142&tid=26

       Miscellaneous
       EPA Healthy School Environments - Design and
       Construction Overview
       http://www2.epa.gov/schools-healthy-buildings/overview-
       design-and-construction-healthy-school-environment
       EPA School Siting Guidelines
       http://www2.epa.gov/schools/school-siting-guidelines
       EPA's State School Environmental Health Guidelines
       http://www2.epa.gov/schools
       The School Superintendents Association Healthy
       School Environments
       http://www.aasa.org/healthyschoolenvironments.aspx
       Collaborative for High Performance Schools,
       Operations Report Card
       http://www.chps.net/dev/Drupal/orc
       National Institute of Occupational Safety and Health
       (NIOSH) Safety Checklist for Schools
       http://www.cdc.gov/niosh/docs/2004-101/default.html
       Collaborative for High Performance Schools (CHPS)
       http://www.chps.net
       National Institute of Environmental Health Sciences (NIEHS)
       http://www.niehs.nih.gov
       American Clearinghouse on Educational Facilities
       http://www.acefacilities.org/
       Center for Environmental Innovation in Roofing
       http://www.roofingcenter.org/
       National Clearinghouse for Educational Facilities
       http://www.ncef.org/rl/index.cfm
Sheet Metal and Air Conditioning Contractors National
Association, Inc., Indoor Air Quality Guidelines for
Occupied Buildings under Construction
http://asc67.org/ASC_Previous_Problems/R7/Commercial/2007/
Student%20Disk/14.4%20SMACNA%20Guidelines.pdf
Construction Industry Compliance Assistance Center,
funded in part by EPA
http://www.cicacenter.org/
Integrated Pest Management
EPA Integrated Pest Management (IPM) in Schools
http://www2.epa.gov/managing-pests-schools
California Integrated Pest Management - Building
Design and Renovation
http://apps.cdpr.ca.gov/schoolipm/architects_designers/main.cfm
The San Francisco Department of the Environment's
Pest Prevention by Design Guidelines
http://www.sfenvironment.org/download/pest-prevention-by-
design-guidelines
Construction and Demolition
RCRA in Focus: Construction, Demolition, and Renovation
http://www3.epa.gov/epawaste/inforesources/pubs/infocus/rif-cd.pdf
C&D Debris: What You Can Do
http://www3.epa.gov/epawaste/conserve/imr/cdm/whatyoucan.htm
Calculating Effectiveness: The Waste Management Plan
http://www3.epa.gov/region9/waste/solid/pdf/cd5.pdf
Sustainable Design and Green Building Toolkit
for Local Governments
http://www2.epa.gov/smartgrowth/sustainable-design-and-
green-building-toolkit-local-governments
Green School  Design
ASHRAE Energy Design Guide for Savings in Schools
http://www.ashrae.org/publications/page/aedg50pct
ASHRAE Standard for the Design of High-Performance
Green Buildings
https://www.ashrae.org/resources-publications/bookstore/
standard-189-1
Green Building Council Website
http://www.usgbc.org
Green Building Initiative Green Globes
http://www.thegbi.org/green-globes/
Net Zero Building Design
http://living-future.org/netzero
RoofPoint
http://www.roofpoint.org/
USGBC Center for Green Schools Resources
http://www.centerforgreenschools.org/guides.aspx
Earth911 Recycling Search
http://search.earth911.com/
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