School Environmental Health Newsletter - Winter 2013
Think Asbestos Before Your Next Building Project
Rules for managing and removing asbestos containing materials in schools have been in force since the 1980’s so you’d think that the rules would make the management and removal process easy by now. Yet, too often asbestos becomes an issue for schools, especially during remodeling or construction projects. If you know you have asbestos- containing materials or suspected materials in your building, it’s best to talk to your licensed Asbestos Inspector-Management Planner early in the process. Include them in your architect and contractor meetings as you build a project timeline. They can help keep you in compliance and build a realistic timeline that accounts for abatement project reporting and timelines. For smaller projects, have your inspector-management planner work with your building manager and contractor to ensure few or no surprises to complicate your project.
Remember that under the EPA rules, it is the building owner who bears the liability for asbestos, not the architect or contractor. The building owner must notify all contractors working in their buildings of the location and type of asbestos in the building. The contractor is responsible for training and protecting only their own employees. Under the EPA asbestos in schools rule, inspectors do not have to test or inspect hidden materials. If you plan to break open walls, remove multiple layers of flooring or remove exterior materials, be aware that contractors might uncover materials that are not on your management plan or have been tested. If this happens, work has to stop until the material is tested. If it is positive, an emergency abatement will need to occur. It is always a good idea to build time into your construction schedule for asbestos contingencies.
In Minnesota schools, most asbestos removal for the purpose of remodeling or construction can only be done by licensed abatement companies. Projects over 260 linear feet or 160 square feet must have a project design completed by a licensed asbestos project designer. Building maintenance workers who have received 2 days of asbestos training are limited to removing only 3 square or 3 linear feet in emergency situations.
Asbestos is regulated under multiple agencies, EPA, OSHA, the Minnesota Department of Health and Minnesota Pollution Control Agency. Also, rules may vary according to the type and condition of the asbestos-containing materials in your building. The best way to avoid pitfalls is to rely on your trained and state licensed asbestos professionals to guide you through process of maintenance, testing and removal. Planning early in the process can save you time and money and make for a much smoother project.
Certain Mercury-Contaminated Soils, Demolition Debris and Mercury-Catalyzed Flooring Now Allowed in Appropriate Minnesota Landfills
By Carol Hubbard, Minnesota Pollution Control Agency
In September of 2013, Minnesota Pollution Control Agency (MPCA) management signed a memorandum allowing the landfill disposal of mercury-contaminated soils, renovation/demolition debris and mercury-catalyzed polyurethane flooring (MCPF) and its subflooring.
The memorandum states soils and construction/demolition debris contaminated with mercury at concentrations that are non-hazardous, and MCPF that is non-hazardous and contains less than 1000 ppm mercury, may be disposed of in appropriate Minnesota landfills under the landfill’s Industrial Solid Waste Management Plan. Prior approval from the MPCA is required if the mercury-contaminated soils or renovation/demolition debris contains between 10 and 1000 ppm mercury. This provision does not apply to these types of waste that do not meet these requirements. Industrial wastes such as ash, materials that have been determined to have a beneficial use or those that have elemental mercury or materials contaminated with free mercury are not included in this allowance.
As before, waste which contains elemental or recoverable mercury, including mercury-containing devices such as batteries, lighting, switches, thermostats, etc., mercury-containing compounds or bulk mercury may not be disposed of in Minnesota landfills.
For details of this memorandum or if you have questions, you may call Scott Parr (MPCA) at 651-757-2638 or Carl Hubbard (MPCA) at 651-757-2452.
School districts that have MCPF or think they may have MCPF and are evaluating their removal and disposal options should call Carol Hubbard at 651-757-2452.
Carbon Monoxide Poisonings Spike in the Winter
On November 13, 2013, more than 40 students and staff of Montezuma Creek Elementary School in rural Utah were hospitalized with carbon monoxide (CO) poisoning. A water heater venting problem was identified as the CO source. Unfortunately, these incidents occur in schools throughout the country each year, especially in winter.
Carbon monoxide is an odorless, colorless gas that can cause sudden illness and death when inhaled. CO poisoning is often misidentified because of the similarity of its symptoms to common illnesses. At lower exposures CO causes headache, dizziness, weakness, nausea, vomiting, chest pain, and confusion. When people breathe higher concentrations of CO the result is unconsciousness and eventually death.
CO is formed by the incomplete combustion of fossil fuels, usually the result of insufficient make-up air (venting). All fuel-burning appliances, such as dishwashers, water heaters, washers and dryers, furnaces and boilers are potential sources of CO. Other common sources in schools are small engines and vehicles in shops and maintenance and grounds keeping areas. Some schools have attached indoor ice arenas, where the ice is maintained with fuel-burning resurfacing equipment, which emits CO as well.
Although Minnesota law requires CO alarms or detectors within 10 feet of all sleeping areas in residential buildings, no similar requirement applies to schools or other commercial buildings. There are CO monitoring regulations for indoor ice arenas, for more information see Indoor Ice Arenas.
To prevent student and staff from being exposed to CO, schools should:
- Have heating system, water heater and any other gas, oil, or coal burning appliances serviced by a qualified technician every year,
- Install a battery-operated or battery back-up CO detector in or near all areas with heating system or fuel-burning appliances and check or replace the battery when you change the time on your clocks each spring and fall.
- If the detector sounds evacuate the building and call 911.
- Seek prompt medical attention for students and staff if they report feeling dizzy, light-headed or nauseous or you suspect CO poisoning.
- Don't allow vehicles or small engines to be run inside or near the building without proper exhaust venting control.
Any questions about CO monitoring or exposure prevention can be directed to the MDH Indoor Air Unit. The US Center for Disease Control has comprehensive information about CO and CO Poisoning on their web page Carbon Monoxide Poisioning.
Additional information on CO and other environmental health topics can be found on the MDH School Environment Health Web Portal.
Carbon Dioxide in Schools: An Indicator of ‘Fresh Air’
Carbon dioxide (CO2) is a colorless, odorless gas. It is produced both naturally and through human activities, such as burning gasoline, coal, oil, and wood. People exhale CO2 which contributes to CO2 levels in the indoor air.
Unlike carbon monoxide, CO2 is commonly found in schools and the outdoor air. The outdoor concentration of CO2 can vary from 350 to 400 parts per million (ppm) or higher in areas with high traffic or industrial activity. Carbon dioxide concentrations indoors can vary from several hundred ppm to over 1000 ppm in areas with many occupants present for an extended period of time and where outdoor air ventilation is limited.
Carbon dioxide is often measured in indoor environments to quickly but indirectly assess approximately how much outdoor air is entering a room in relation to the number of occupants. CO2 can be measured with relatively inexpensive real-time digital air monitoring equipment. CO2 measurements are commonly used as a screening test of indoor air quality in schools and offices because levels can be used to evaluate the amount of ventilation and general comfort.
Outdoor "fresh" air ventilation is important because it can dilute contaminants that are produced in the indoor environment, such as odors released from people and contaminants released from the building, equipment, furnishings, and people's activities. Adequate ventilation can limit the build up of these contaminants. It is these other contaminants and not usually CO2 that may lead to indoor air quality problems, such as discomfort, odors "stuffiness" and possibly health symptoms.
The American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) has developed ventilation guidelines that should maintain a comfortable environment for most occupants. The amount of fresh air that should be supplied to a room depends on the type of facility and room. For example, in elementary school classrooms, ASHRAE recommends 15 cubic feet per minute person of outdoor air (for a 1000 square foot room occupied by 35 people). This rate of ventilation should keep carbon dioxide concentrations below 1000 ppm and create indoor air quality conditions that are acceptable to most individuals.
Carbon dioxide is not generally found at hazardous levels in indoor environments. The MNDOLI has set workplace safety standards of 10,000 ppm for an 8-hour period and 30,000 ppm for a 15 minute period. MDH is not aware of lower standards developed for the general public that would be protective of sensitive individuals. For more information see MDH Carbon Dioxide webpage.
Would you like personal assistance with your school environmental health plan?
Staff from the Indoor Air Unit at the Minnesota Department of Health are available to work with you one-on-one to help you create or further implement your school environmental health plan. Whether you are starting from scratch or need assistance on a specific issue, we are here to help!
We can help you in many ways such as: Investigating specific concerns or problems in your building; Conducting a general proactive indoor air quality walk-through assessment; Reviewing, improving, and proposing written policies.
Helping you conduct and interpret radon testing, including lending a continuous radon monitor for free advising on various other school environmental health issues.
Contact the Indoor Air Unit for more information:
or toll free 800-798-9050