___________________________________________________ SCHOOL ENVIRONMENTAL HEALTH INSPECTION _____________________________ GUIDANCE DOCUMENT _____________________________________________________ Indoor Environments Section Bureau of Environmental Health Ohio Department of Health 246 N. High Street Columbus, Ohio 43215 ODH School Environmental Health Program Inspection Guidance Forward The Ohio Department of Health (ODH), Bureau of Environmental Health (BEH), Indoor Environments Section (IES) began the process of revising the school inspection manual in 2002 because many sanitarians from local health departments around the state expressed a desire for an updated, more comprehensive inspection manual to use while conducting the annual inspection of the school building and its environment. This manual is the culmination of years of research, meetings, drafts, edits, pilot programs and revisions. In 2004, a survey was distributed to all local health departments regarding their school inspection program. The survey asked questions about the number of school inspections conducted each year, the length of time involved in school inspections, the importance of inspecting different items in the school environment and the equipment used to conduct the inspection. This survey was returned by 97 percent of all local health departments. Many of the respondents indicated a need for updated school inspection guidance. The revision process began with staff from the ODH and local health departments meeting to discuss what the new school inspection manual should contain. The IES gathered information, prepared a comprehensive standard and drafted an inspection manual. The Ohio School Inspection Advisory Committee (OSIAC) was formed, comprised of representatives from: The Association of Ohio Health Commissioners Ohio School Boards Association Washington Township Fire Department General Health District of Cuyahoga County Highland County Health Department Marion County Health Department Delaware County General Health District Worthington City Schools Facilities Department The Ohio State University The American Lung Association of Ohio Ohio Bureau of Workers Compensation ODH Prior to the first meeting of the OSIAC, staff from the ODH pilot tested the revised manual to evaluate it for ease of use, duration of inspections and opportunities for improvements. The OSIAC began meeting in January 2005. The committee met monthly for a year and members’ input was invaluable in the crafting of this manual. When Jarod’s Law was proposed and adopted through the efforts of Rep. Tom Raga, an additional advisory group was initiated to work on rule development. Organizations represented on this advisory committee include: The Association of Ohio Health Commissioners Auditor of State’s Office Buckeye Association of School Administrators ODH Indoor Environments Section 2 Revised: 10-29-10 ODH School Environmental Health Program Inspection Guidance Jarod Bennett’s Father Ohio Association of Boards of Health Ohio Association of Elementary School Administrators/Ohio Middle School Association Ohio Association of Independent Schools Ohio Association of School Business Officials Ohio Association of Secondary School Administrators ODH Bureau of Environmental Health Ohio Education Association Ohio Environmental Health Association Ohio Federation of Teachers Ohio School Boards Association Ohio School Facilities Commission Rep. Tom Raga’s Office Warren County Board of Health Jarod’s Law (Ohio Administrative Code 3701-54-01 through 3701-54-09) became effective Sept. 27, 2007. In July, 2009, the House Bill 1 (Budget) repealed the Ohio Revised Code Sections 3701.93 through 3701.936 and amended ORC 4736.01 removing enforcement of Jarod’s Law from the definition of Environmental Health practice and removing the authorization for the administrative rules. The statutory language reverted to the language prior to Jarod’s Law which means local health districts are required to conduct sanitary school inspections semi- annually or twice per year. Although, schools are required to be inspected twice per year, there are no rules or standards to which those inspections should adhere. Historically, ODH Bureau of Environmental Health provided guidance for the conduct of these inspections. ODH will continue to provide this information on its website as a reference to inform sanitary school inspections. Since Jarod’s Law is no longer applicable, there is no legal requirement to use this guidance. Rather, the content of each school inspection will be determined by the local health department in whose jurisdiction the school is located. ODH remains committed to assisting local health departments and schools in maintaining a healthy and safe school environment for all Ohio’s children. ODH Indoor Environments Section 3 Revised: 10-29-10 ODH School Environmental Health Program Inspection Guidance Introduction Approximately 20 percent of the US population spends their day in a school building. In 1994, a Government Accounting Office report to the U.S. Congress indicated that 83 percent of Ohio’s schools had at least one unsatisfactory environmental factor. Nearly half (48 percent) of schools reported problems with the HVAC systems in their buildings. The rate of childhood asthma has increased dramatically over the years to one out of 10 children. Poor Indoor Air Quality (IAQ) has a direct impact on persons with asthma resulting in more frequent asthma episodes. According to a 2004 report to the Under Secretary of the U.S. Department of Education, “The overall evidence strongly suggests that poor environments in schools, due primarily to effects of indoor pollutants, adversely influence the health, performance and attendance of students.”1 There has been much legislation passed since 1978 that has had a direct impact on school buildings, for instance, the banning of lead-based paint, prohibition on the use of asbestos containing products, clean water and clean air acts and the Americans with Disabilities Act. While this manual is more comprehensive than the previous 1977 school inspection manual, it is not all inclusive. This manual is designed to give the local health department and school district officials a “snapshot” of the school environment at the time of the inspection. It is recommended that school systems have annual comprehensive school safety inspections as well. This safety inspection can be performed, upon request, by staff from the Public Employees Risk Reduction Program (PERRP) or by the Bureau of Workers’ Compensation or by an independent safety inspector. “Inadequate indoor environments in schools may decrease performance by causing health effects that either directly impair concentration or memory or indirectly affect learning.”2 Simply stated, students who are educated in buildings with fewer health and safety concerns perform better than students who are educated in buildings where a lack of maintenance has allowed the school building to deteriorate. School district officials are encouraged to use this manual to prepare for the local health department inspection, but should be aware there is much more than what is contained in this manual that school officials can and should do to maintain and improve their school facilities. The items in this manual constitute what ODH believes to be both important to the proper operation and maintenance of these environments and easily inspected by public health inspectors and school officials. School administrators are also advised the inspection performed by the local health department sanitarian is meant to address hazards in the school building that can be identified at the time of inspection. Remediation of all the problems indicated on an inspection report does not indicate the school is safe and free of all hazards throughout the school year. ODH makes the following recommendations for sanitarians conducting inspections of school environments: 1. Use this manual in its entirety to conduct a health and safety inspection. The manual provides additional reference material on subjects that you might find helpful or that might be 1 U.S. Department of Education, Office of the Under Secretary, A Summary of Scientific Findings on Adverse Effects of Indoor Environments on Students’ Health, Academic Performance and Attendance, Washington, D.C., 2004. 2 U.S. Department of Education, Office of the Under Secretary, A Summary of Scientific Findings on Adverse Effects of Indoor Environments on Students’ Health, Academic Performance and Attendance, Washington, D.C., 2004. ODH Indoor Environments Section 4 Revised: 10-29-10 ODH School Environmental Health Program Inspection Guidance helpful to schools. Inspection items can be broken into two inspections and completed during the two required inspections during a one year period. Inspections should be conducted while school is in session and building occupants are present so use of the building (from the perspective of health and safety) can be evaluated. School personnel should be encouraged to plan for remediation of these items as they can be fit into the regular budget and maintenance plan for the school building. 2. Prior to conducting the health and safety inspection of the school building, it is recommended the sanitarian contact the school administrator to schedule the inspection. Doing so in advance will enable the school to assign a staff person to accompany the sanitarian and may reduce the amount of time at the end of the inspection in reviewing the identified