Boston Public Health Commission School Inspection Training by Damon Chaplin

1. Boston Public Health Commission School Inspection Trainingby Damon Chaplin

2. Table of Contents • 1. Introduction • 2. Purpose • 3. History • 4. Background • 5. Definitions • 6. Equipment • 7. Scope of Inspection • 8. Inspection • 9. Post Inspection • 10. Data retrieval and collection • 11. Reporting

3. Introduction -Purpose The purpose of this training is to provide instruction to qualified environmental health professional within the indoor air quality unit of the Boston Public Health Commission and/or it’s successors towards monitoring the quality of air in all public school buildings within the City of Boston in accordance with mandates listed in the City of Boston Local Ordinance 1999 c.10 as well as to insure schools are complying with state IPM reporting regulations and using best practices for Integrated Pest Management(IPM). -History In 1996, the City of Boston Counsel passed an Indoor air quality ordinance sponsored by Counselor Maura Hennigan. This ordinance resulted in an unfunded mandate requiring the local public health department to conduct indoor air quality inspections twice a year in all public school buildings and from time to time public buildings by request of the officer have charge of city owned or occupied buildings. IPM The Act Protecting Children and Families from Harmful Pesticides (Act), Chapter 85 of the Acts of 2000, took effect on November 1, 2000. The Act amends the Massachusetts Pesticide Control Act (Chapter 132B of the MGL) and applies to the use of pesticides in schools, day care centers, and school-age childcare programs. The act requirement are to: 1.)prevent unnecessary exposure of children to pesticides 2.)promote lower risk alternatives to pesticides 3.)ensure notification to the school community 4.) prevent and address causes of pest problems effectively What schools must do: 1.)Submit Indoor/Outdoor IPM plan to MDAR? 2.)Insure individuals applying pesticides on the school property hold valid pesticide licenses? 3.)Insure pesticides used are allowed by law such as baits, gels and dusts 4.)Insure school does not use pesticides that are prohibited by the law

4. Introduction Integrated Pest Management (Cont.) www.massdfa.org/cpa/cpa.htm Integrated Pest Management (Inacted Nov. 12, 2000) IPM- Is a systematic strategy for managing pests which considers prevention, avoidance, monitoring and suppression. Where chemical pesticides are necessary, a preference is given to materials and methods which maximize public safety and reduce environmental risk (Massachusetts IPM Council's ). LEGALITIES AND LIABILITIES RELATED TO IPM IN MASSACHUSETTS: - The implementation of IPM programs is required by Massachusetts Act Protecting Children and Families from Harmful Pesticides. Pursuant to section 15 of this act, violators can be subject to fines. - Ultimately, the new legislation intent is to encourage the use of integrated pest management (IPM) and minimize pesticide exposure especially to children and employees. WHO IS RESPONSIBLE?Those persons who perform, contract, and/or administratively oversee pest management services for schools, day care centers, and school-aged child care programs play significant roles in the implementation of these new changes. Also, the new changes include others such as utility companies and state agencies. WHAT ARE THE REQUIREMENTS?

5. Introduction City of Boston Local Ordinance 1996 c.10  7-14     INDOOR AIR QUALITY. • 7-14.1     Indoor Air Quality Unit. •      There is hereby established within the Environmental Health Office of the Department of Health and Hospitals or its successors an Indoor Air Quality Unit which is charged with monitoring the quality of air (a) in buildings to which the public has access which are not subject to monitoring by the U.S. Occupational Safety and Health Administration (OSHA) for air quality standards substantially as contemplated by its Proposed Indoor Air Quality Rule (59FR15968), (b) in all public school buildings within the City, (c) in all other buildings owned or leased by the City or any agency or instrumentality thereof (except foreclosed real estate,) and, (d) in any other structure in Boston where there is an apparent risk to health likely to be caused or aggravated by poor air quality. • (Ord. 1996 c. 10) •      7-14.2     Air Quality in School Buildings. •      No less than twice each year the Indoor Air Quality Unit shall inspect each school building, and, using as guidelines the then current recommendations and standards of OSHA and the Environmental Protection Agency, shall ensure that the air quality in each such building is appropriate to the maintenance of good health, with special regard to airborne pollutants in concentrations harmful to children. Each inspection shall include (a) electronic environmental air quality monitoring, (b) visual inspection, (c) review of health complaint surveys, heating, ventilation and air conditioning evaluations, building inspection records, and, (d) such other procedures as building history and inspection of similar structures suggest. In the event an inspection shall detect a situation likely to cause ill health, the Unit shall forthwith make written record thereof and report the same to the person in charge of the building, to the Superintendent of Schools, and to the School Committee. The Unit shall cooperate with City and school officials and employees to take appropriate action to cure the situation and minimize adverse effect on the public health. In the event subsequent inspection, or other facts known to the Unit, indicate a failure to act with expedience toward correction of the situation, the Unit shall give immediate report to the Board of Health and Hospitals or its successors and to the Mayor. • (Ord. 1996 c. 10) •      7-14.3     Air Quality in Other Public Buildings. •      The Unit shall from time to time and when requested by the officer having charge of a City owned or occupied buildings, or any other building upon request of the owner, inspect buildings owned or leased by the City, and, using as guidelines the then current recommendation and standards of OSHA and the Environmental Protection Agency, shall ensure that the air quality in each such building is appropriate to the maintenance of good health. Each inspection shall include (a) electronic environmental air quality monitoring, (b) visual inspection, (c) review of health complaint surveys, heating, ventilation and air conditioning evaluations, building inspection records, and (d) such other procedures as building history and inspection of similar structures suggest. In the event an inspection shall detect a situation likely to cause ill health, the Unit shall forthwith make written record thereof and report the same to the person in charge of the building, and to the Mayor. The Unit shall cooperate with City officials and employees to take appropriate action to cure the situation and minimize adverse effect on the public health. In the event subsequent inspection, or other facts known to the Unit, indicates a failure to act with expedience toward correction of the situation, the Unit shall give immediate report to the Board of Health and Hospitals or its successors. • (Ord. 1996 c. 10) •      7-14.4     Annual Report. •      The Unit shall make annual report of its doings, including a listing of inspections made and any recommendations it may have for legislative action, to the Mayor, who shall convey a copy to the City Council and to the Board of Health and Hospitals or its successors, which Board shall maintain the same as a public record. • (Ord. 1996 c. 10)

6. Definitions • Leaks – This is the number of rooms that have evidence of one or more water leaks. This could • include water stains or discoloration on walls, floors, or ceiling tiles as well as active leaks where • water is present. Leaks are of concern because persistent moisture can promote mold growth as well as • encourage insect or rodent infestations. • Visible Mold Growth – Mold and mildew are often asthma triggers. Often they can look like greyblack • powder near the water-damaged areas or spots or patches of various colors. When attempting to • rid an area of mold and mildew, it is most important to find and eliminate the water source in order to • make sure the mold doesn’t grow back. • Pests – These are counts of the number of rooms visited where the inspector saw signs of pest • infestation including dead insects, insect parts, traps, rodent droppings, etc. Pests are of concern for • sanitation reasons as well as being sources of animal dander that can be an asthma or allergy trigger. • Boston Public Schools are implementing integrated pest management (IPM) plans designed to control • pests without using heavy amounts of chemical pesticides. IPM strategies include conducting pest • surveys, blocking entrances such as holes or cracks that let pests into the building and eliminating • sources of food and water (leaks, trash, food crumbs, etc.) that attract pests, and using minimal • amounts of pesticide only where necessary. BPS will be requiring community and extra curricular • school building user groups to cooperate with the plan’s implementation. • IPM Plans Available – “Yes” indicates that an IPM Plan has been submitted to the MA Department • of Food and Agriculture and is in use and available for inspection in the principal’s office. • Clutter – It is important to control clutter in the classroom as it can contribute to the buildup of dust, • hide places where mold might be growing, block ventilation, or provide places for pests to hide. • Clutter includes books or other materials placed on ventilation units, piles of loosely organized papers • or student projects, visual aids scattered around a classroom, etc. • Dust – There should be as little visible surface dust in the school as possible. Indoor dust is made up • of outdoor dust, human residues such as dry skin flakes, and material released from items within the • school. Dust mites are extremely small organisms that feed on skin flakes. Dust and dust mites are • both asthma triggers. Dust and dust mites thrive in carpeting. Damp mopping of floors or vacuuming • of carpeting should be done regularly to reduce dust. Minimizing clutter in the classroom and wet • wiping of solid surfaces can also control dust. • PM10 (Respirable Dust) – PM10 stands for particulate matter (dust and other dust-like materials) that is • small enough to be inhaled into the deepest parts of the lungs, and can cause health problems. The • national ambient air quality standard is 0.05 milligrams per cubic meter of air (mg/m3) for long-term • exposure and 0.150 mg/m3 for a single 24-hour period. Possible sources of elevated indoor PM10 • levels are construction activities, tobacco smoking, inadequately vented furnaces, water heaters, stoves, • and other appliances burning fuels. Outdoor respirable dust levels vary considerably and must be • taken into consideration when evaluating indoor exposures. Indoor airborne dust levels are often • similar to the outdoor air level except for buildings with well-filtered central ventilations systems • where indoor airborne dust levels are often lower. One important effort for controlling dust in school • buildings is to ensure that construction/renovation work is done in areas that have been isolated from • the rest of the building (plastic barriers, etc.) and that proper cleanup is done in the work area and • surrounding areas when the job is done. Also, it is best to conduct all such work during hours when • the school is not occupied, if possible. • Carbon Dioxide (CO2) – Carbon dioxide is a natural gas breathed out by humans and other animals or • produced by combustion. It can accumulate in buildings with poor ventilation. Its outdoor • concentration is about 375 parts per million (ppm). Indoor levels usually tend to be higher than • outdoor levels. An indoor level greater than 1,000 ppm while the building is fully occupied can mean • the building has inadequate ventilation. Carbon dioxide levels may reach higher levels during the cold • weather, when windows are usually closed. Though such high levels are not, in themselves, toxic, the • carbon dioxide level is an indicator that can give the inspector an idea about possible build-up of other • substances in the air that could impact health but for which there is no monitoring equipment. • Carbon Monoxide (CO) – Carbon monoxide is a toxic gas released during the burning of fuels in • open fires, appliances, and internal combustion engines, like cars. Inhaling carbon monoxide can • cause headaches, fatigue, fainting, brain damage, or even death if its concentration is high or the • exposure continues for a long period of time. The national ambient air quality standard for carbon • monoxide is 9 ppm (parts per million). Therefore, values well below 9 ppm are safe. • Volatile Organic Chemicals – Volatile Organic Chemicals (VOC’s) can aggravate respiratory • problems like asthma. The levels of organic vapors in the outdoor air are typically 70-100 parts per • billion (ppb). The normally expected indoor air concentration range is 150-300 ppb. • VOC’s are found in building materials, furnishings such as carpeting and furniture, white board • markers, air fresheners, common items such as glass and floor cleaners, some types of paints, • varnishes, and other chemicals used in schools. Anytime chemical products are used, it should be in a • very well ventilated area (open the windows if possible). If VOC levels are high, efforts should be • made to determine their sources, which chemicals are present, and their potential for toxic effects. • BPS purchases low VOC cleaning products and construction materials to the extent feasible, • and discourages bringing unauthorized home purchased consumer cleaning products into its schools. • If renovation or construction that involves painting, surfacing, or other work that involves VOCreleasing • chemicals is planned, it should ideally be done after hours or during school breaks when the • building is unoccupied. Regardless of when such work is done, the work area should be isolated from • the rest of the building and should be well ventilated. If possible, time should be provided for offgassing • and curing before reoccupation. Choose low VOC products over high VOC products (low- • VOC products usually note this on the product label) when they are shown to perform well in use. • Chemical Storage – Some rooms throughout the school may contain chemicals such as art supplies, • cleaning supplies, or science class materials. This item counts the number of such rooms where the • inspector found chemicals being stored incorrectly. For example, concentrated cleaning products • should not be stored on top of a teacher’s desk and science classroom chemicals should be stored in an • organized manner in proper cabinets that can be locked. • Repairs needed – This item on the report is a count of rooms visited in the school where the inspector • found repairs that needed to be made. These could include replacing light bulbs; malfunctioning fans • or Unit Ventilators; patching holes in walls; repairing doors and lock sets; or replacing a leaking sink • faucet, paper dispenser, or damaged toilet. For follow-up information on the status of repairs, please • contact the school principal or site council. • Non-functioning Toilets – Toilets that are poorly functioning, missing pieces, leaking, loose, or • otherwise broken. • Non-functioning Urinals – Urinals that are poorly functioning, missing pieces, leaking, loose, or • otherwise broken. • Non-functioning Sinks – Sinks that are poorly functioning, have either no hot or no cold water, • missing pieces, leaking, loose, or otherwise broken. • Missing Stall Doors – Stall door is missing, cannot be closed, has a missing or non-functional latch, or • is otherwise in poor repair. • Number of Soap Dispensers – Number of soap dispensing fixtures present. Bar soap or liquid soap • dispensing bottles may be provided in lieu of dispensing fixtures. • Number of Broken Soap Dispensers – Number of soap broken dispensing fixtures present. • Percent of sinks/fixtures without adequate soap – Percentage of bathrooms where soap dispenser • fixtures with soap, bar soap, or dispenser bottles with soap are absent or not present in sufficient • quantities. IPM- a systematic strategy for managing pests which considers prevention, avoidance, monitoring and suppression. Where chemical pesticides are necessary, a preference is given to materials and methods which maximize public safety and reduce environmental risk (Massachusetts IPM Council's City of Boston Local Ordinance 1999 c.10- 7-14     INDOOR AIR QUALITY. • 7-14.1     Indoor Air Quality Unit. •      There is hereby established within the Environmental Health Office of the Department of Health and Hospitals or its successors an Indoor Air Quality Unit which is charged with monitoring the quality of air (a) in buildings to which the public has access which are not subject to monitoring by the U.S. Occupational Safety and Health Administration (OSHA) for air quality standards substantially as contemplated by its Proposed Indoor Air Quality Rule (59FR15968), (b) in all public school buildings within the City, (c) in all other buildings owned or leased by the City or any agency or instrumentality thereof (except foreclosed real estate,) and, (d) in any other structure in Boston where there is an apparent risk to health likely to be caused or aggravated by poor air quality. • (Ord. 1996 c. 10) •      7-14.2     Air Quality in School Buildings. •      No less than twice each year the Indoor Air Quality Unit shall inspect each school building, and, using as guidelines the then current recommendations and standards of OSHA and the Environmental Protection Agency, shall ensure that the air quality in each such building is appropriate to the maintenance of good health, with special regard to airborne pollutants in concentrations harmful to children. Each inspection shall include (a) electronic environmental air quality monitoring, (b) visual inspection, (c) review of health complaint surveys, heating, ventilation and air conditioning evaluations, building inspection records, and, (d) such other procedures as building history and inspection of similar structures suggest. In the event an inspection shall detect a situation likely to cause ill health, the Unit shall forthwith make written record thereof and report the same to the person in charge of the building, to the Superintendent of Schools, and to the School Committee. The Unit shall cooperate with City and school officials and employees to take appropriate action to cure the situation and minimize adverse effect on the public health. In the event subsequent inspection, or other facts known to the Unit, indicate a failure to act with expedience toward correction of the situation, the Unit shall give immediate report to the Board of Health and Hospitals or its successors and to the Mayor. • (Ord. 1996 c. 10) •      7-14.3     Air Quality in Other Public Buildings. •      The Unit shall from time to time and when requested by the officer having charge of a City owned or occupied buildings, or any other building upon request of the owner, inspect buildings owned or leased by the City, and, using as guidelines the then current recommendation and standards of OSHA and the Environmental Protection Agency, shall ensure that the air quality in each such building is appropriate to the maintenance of good health. Each inspection shall include (a) electronic environmental air quality monitoring, (b) visual inspection, (c) review of health complaint surveys, heating, ventilation and air conditioning evaluations, building inspection records, and (d) such other procedures as building history and inspection of similar structures suggest. In the event an inspection shall detect a situation likely to cause ill health, the Unit shall forthwith make written record thereof and report the same to the person in charge of the building, and to the Mayor. The Unit shall cooperate with City officials and employees to take appropriate action to cure the situation and minimize adverse effect on the public health. In the event subsequent inspection, or other facts known to the Unit, indicates a failure to act with expedience toward correction of the situation, the Unit shall give immediate report to the Board of Health and Hospitals or its successors. • (Ord. 1996 c. 10) •      7-14.4     Annual Report. •      The Unit shall make annual report of its doings, including a listing of inspections made and any recommendations it may have for legislative action, to the Mayor, who shall convey a copy to the City Council and to the Board of Health and Hospitals or its successors, which Board shall maintain the same as a public record. • (Ord. 1996 c. 10)

7. Scope of Inspection • IAQ • Pest • Mold • Dust • Clutter • Water Stains • Physical Condition • Bath Room • PCB’s • Et al

8. Equipment • Dust Trak • Q-Trak • P.I.D • Palm/I-touch • Flash Light • Multi-gas Meter ??? • Moisture Meter ???

9. Inspection • 1. Collect outdoor clearance samples • 2. Check-in with Principles office • 3. Check IPM Logbook • 4. IAQ monitoring • 5. Physical indoor inspection • 6. Data collection

10. Post-Inspection • Post outdoor clearance IAQ samples. • Data Download • Data Retrieval • Data upload

11. Data • QA • QC