School Environmental Health Newsletter - Summer 2013
Advancing Healthy School Environments in Minnesota
Minnesota Department of Health’s Indoor Air Unit (MDH IAU) has received a grant to fund a project to advance the issue of healthy school environments in Minnesota. The project is intended to centralize existing state school environmental health activities with the primary aim to help Minnesota schools create healthier environments.
MDH, other state agencies (Department of Education, Pollution Control Agency, MnOSHA, Department of Commerce, Department of Public Safety, Department of Agriculture) and partners (EHS consultants, Services Cooperatives, MASMS, US Green Building Council, Green & Healthy Kids, educators) are collaborating to assist and recognize Minnesota schools’ implementation of comprehensive school environmental health programs. A new ‘Minnesota School Environmental Health Program’ (MSEHP) is being created with the assistance of a steering committee. THE MSEHP will include:
- a state plan to implement the new state school environmental health program, including measures to assess progress. The plan will describe educational and outreach goals and activities.
- compilation of all pertinent local, state, and federal standards and guidelines at a single location, the School Environmental Health web portal
- development of additional guidance, resources, and trainings for school officials to use in developing their school environmental health programs.
- dissemination of resources through new and existing communication channels, including school association trade shows, meetings, and publications.
- completion of training programs to assist schools with implementing a school environmental health program, including in-person trainings, webinars, and one-on-one consultations.
- survey of public schools to determine extent of school environmental health programs
- creation of a state recognition program for schools that have implemented a demonstrable and comprehensive school environment health program.
Topics addressed under the umbrella of “School Environmental Health”:
- Bloodborne Pathogens
- Chemical Safety;
- Drinking Water
- Energy Efficiency
- Food Safety
- Green Cleaning
- Indoor Air Quality
- Lead Paint
- Outdoor Air Quality
- Recycling & Waste Reduction
- Sustainable Construction
- UV Protection
- Vehicle Idling
- Water Efficiency
MDH predicts that at least 500 schools in the state will be identified as having implemented comprehensive environmental health programs. Those schools that apply for the recognition program will be further evaluated to measure the impacts of their programs on the school environment (contaminant reduction), learning (test scores), health (office visits), costs (energy use), and attendance. Recognition program awardees will receive a plaque and be listed on our website.
Expected outcomes of the project include:
- increased knowledge of school officials
- greater numbers of schools that have implemented school environmental health programs
- reduction in environmental health and safety risks affecting children and staff
- reduction in costs associated with green and healthier schools, such as energy, resource, and staff costs
- improvements in learning and attendance
Arena Rule Revision
The Minnesota Department of Health regulates the air quality in enclosed sports arenas to protect the public from exposure to harmful levels of combustion by-products. Minnesota is home to 274 indoor ice arenas. Air quality in ice arenas is relevant to schools because some schools own or operate arenas. Also, in some cases, students will use a neighboring arena for P.E. or students participate in hockey practice before coming to school.
The ice surface in ice arenas is maintained using resurfacing and ice edging equipment, which are usually powered with internal combustion engines. The combustion by-products emitted from this equipment include carbon monoxide (CO) and nitrogen dioxide (NO2), which are health hazards at elevated levels. Elevated levels of CO and NO2, including poisoning episodes, continue to occur at indoor arenas around the country. CO and NO2 can be measured using a variety of air testing equipment, including colorimetric tubes, electronic portable instruments, and continuous monitors at a fixed location.
The Minnesota State Board of Health adopted the MDH Enclosed Sports Arena Rules by resolution in 1973. In 1977, Minnesota’s Enclosed Sports Arena Rules were revised, primarily to comply with a new rule numbering scheme. The rule had not changed since then, until recent revisions that became effective on May 20, 2013. MDH is one of only three states in the country that regulate air quality in enclosed sports arenas, and we are not aware of any regulations in other countries.
Revising the Rules
About five years ago, the MDH decided to revise the rules. In drafting the proposed rules, MDH conducted extensive research. We analyzed about 100 scientific articles on the subject, and reviewed relevant governmental regulations and guidelines. We collected information from the manufacturers of resurfacing equipment and their service companies, as well as manufacturers of air monitoring equipment.
During this research and drafting phase, MDH engaged the public extensively. In the Fall of 2009, the MDH held five public meetings around the state to inform the stakeholders of the problems with the existing rule and to provide an informal opportunity for attendees to provide comment. After these public meetings, MDH appointed three advisory committees in the summer of 2010: an ice arena advisory committee; a motorsports committee; and a health committee. These committees met a total of 13 times, and a wide range of topics were discussed and recommendations were presented to MDH. There were also three formal written public comment periods throughout the rulemaking process. On September 10, 2012 MDH’s notice of intent to adopt revised rules was published in State Register. On November 13, 2012, an administrative law hearing was held. The administrative law issued a report with recommendations and MDH made minor changes to the rule.
Changes to Rules
The following key changes to the Enclosed Sports Arena Rules went into effect on May 20, 2013.
- Separate set of rules for ice arenas and enclosed motorsport activities
- All indoor ice arenas regulated, including arenas with electric equipment
- Reducing acceptable air quality standards in ice arenas: CO is reduced from 30ppm (1hr. average) to 20ppm and NO2 is reduced from 0.5ppm (1hr. average) to 0.3ppm
- Annual certification of arenas
- Employee training requirement
- Increased monitoring requirements for ice arenas: monitoring is increasing from once per week to two times per week where internal combustion engine resurfacing is used and an additional once per week monitoring where internal combustion engine edging is used
- Allowance of electronic air testing devices without special departmental permission.
- More specific corrective action and follow up testing requirements (if unacceptable air quality conditions are observed)
- A lower evacuation criteria of 83 ppm carbon monoxide, down from 125 ppm
- Limits to prevent extended operation above the acceptable air quality limits
- Recordkeeping requirements (including public access)
- Notification of MDH prior to use and air testing when other fuel-burning equipment that vent to the indoor air is brought into ice arenas, such as portable generators, lifts, blowers, etc.
For more information, visit the Enclosed Sports Arenas
Revised Hazard Communication Standard
On March 26, 2012, federal OSHA published the final rule for Hazard Communication, 1910.1200, to conform with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS). Minnesota OSHA (MNOSHA) adopted the federal Hazard Communication Standard with minor exceptions, as published in the State Register, September 10, 2012.
The intent of the GHS is to standardize, on a world-wide basis, how chemicals are classified, labeled, and, thus, communicated to users. When fully implemented, it will end more than 30 years of enforcement of the Minnesota Right to Know Act (MN ERTK) for hazardous chemicals.
Some requirements of the MN ERTK rule will be retained. 1910.1200 contains language that ionizing and non-ionizing radiation and biological agents are not covered. MNOSHA did not adopt the federal exceptions and will continue to enforce the existing requirements for radiation and biological agents covered under MN ERTK. MNOSHA will also retain its annual training requirements under MN ERTK for all hazardous chemicals, physical agents, and infectious agents.
One of the first requirements resulting from adoption of the new 1910.1200 is for employers to provide training to employees on the new labeling system and safety data sheet (SDS) format. This is due by December 1, 2013.
Until the effective dates of the standard are reached, Minnesota employers may comply with the revised Part 1910.1200, the current MN ERTK Act, or both. Below is a summary of implementation dates for phasing-in the new Hazard Communication standard, 1910.1200:
|Effective Completion Date||Requirement(s)||Who|
|December 1, 2013||Train employees on the new label elements and safety data sheet (SDS) format||Employers|
|June 1, 2015||Compliance with all modified provisions of this final rule
(exception – distributors are allowed until December 1, 2015)
|Chemical manufacturers, importers, distributors, and employers|
|December 1, 2015||The Distributor shall not ship containers labeled by the chemical manufacturer or importer unless it is a GHS label||Chemical manufacturers, importers, distributors, and employers|
|June 1, 2016||Fully implement the hazard communication program and remaining MN ERTK program requirements. Up-date alternative workplace labeling as necessary.||Employers|
Additional information is available on Federal OSHA’s on-line Hazard Communication page that includes the full text of the new 1910.1200 standard, a side-by-side comparison of old vs. new, December 1st, 2013 training requirements, OSHA Brief on labels and pictograms, Downloadable pictograms, safety data sheet (SDS) brief and quick card, and a list of frequently asked questions regarding the new standard.