State law encourages districts to address air quality issues in schools.
Healthy School Environment
This document addresses indoor air quality in schools
Texas Administrative Code 19 61.1036 School Facilities Standard for Construction on or after January 2004
(b) Implementation date. The requirements for school facility Standard shall apply to projects for new construction or major space renovations for which the construction documents have been approved by a school district board of trustees, or a board's authorized representative, on or after January 1, 2004. For projects for which a school district approved the construction documents prior to January 1, 2004, if a school district makes changes or revisions to the design of the projects on or after January 1, 2004, and before the end of construction, the changes or revisions are subject to the Standard specified in § 61.1033 of this title (relating to School Facilities Standard for Construction before January 1, 2004). For projects funded from bond elections passed prior to October 1, 2003, and for which a contract for construction has been awarded no later than December 31, 2005, a school district may comply with the Standard specified in § 61.1033(d)(2)(B)(ii) of this title in lieu of the Standard specified in subsection (d)(5)(C)(iii) of this section, and with the Standard specified in § 61.1033(d)(2)(C)(ii) of this title in lieu of the Standard specified in subsection (d)(5)(D)(ii) of this section.
Texas Administrative Code 25 297.1 General Provisions
(b) (1) The department does not have any enforcement authority requiring implementation of these guidelines. They do not create liability for a governmental entity for an injury caused by the failure to comply with the voluntary guidelines established by the board under Health and Safety Code, § 385.002.
(2) Additional information on IAQ and a list of other resources for more information can be provided by the Indoor Air Quality Branch of the department. There are several resources available free of charge which offer guidance on the development of an IAQ Management Plan and which provide forms that can be used or modified to fit the needs of governmental buildings. These include the U.S. Environmental Protection Agency (EPA) publications, "Building Air Quality Action Plan and Building Air Quality: A Guide for Building Owners and Facility Managers, Indoor Air Quality Building Education Assessment Model (I-BEAM) Software" and "IAQ Tools for Schools Action Kit". These resources are available on the Internet at www.epa.gov/iaq.
(3) The needs, costs and available funding for improving the IAQ vary greatly in different governmental entities. Governmental administrators should evaluate, and adopt or promote those guidelines that in their judgment are relevant, applicable and feasible to implement. It is important to realize that these guidelines are presented as a basic standard of practice that the department is encouraging governmental administrators to strive for.
Texas Administrative Code 25 297.2. Definitions
The following words and terms, when used in these sections, shall have the following meanings, unless the context clearly indicates otherwise. (1) Acceptable indoor air quality--The quality of air in an occupied enclosed space that is within an established temperature and humidity comfort zone, and which does not contain air contaminants in sufficient concentration to produce a negative impact on the health and comfort of the occupants. (2) Air contaminant--A gaseous, liquid, or solid substance or combination of substances in a form transported by or in air that has the potential to be detrimental to human health. (3) ASHRAE--American Society of Heating, Refrigerating and Air-conditioning Engineers, Incorporated. (4) Board--The Texas Board of Health. (5) Building commissioning--The process of ensuring that all building systems are designed, installed, functionally tested, and operated in conformity with design intent. Commissioning includes planning, design, construction, start-up, testing, documentation, owner acceptance, and training throughout the life of the systems and building. (6) Department--The Texas Department of Health. (7) Government building--A building that is: (A) owned, or leased for a term of at least three months, by a state governmental entity or by a political subdivision of this state, including a county, municipality, special purpose district, or school district; and (B) regularly open to members of the public or used by the state or local governmental entity for a purpose that involves regular occupancy of the building by an employee or by a person in the custody or control of the governmental entity such as a public school student. (8) HVAC system--The heating, ventilation, and air-conditioning system that provides the processes of comfort heating, ventilating and/or air conditioning within, or associated with, a building. (9) IAQ--Indoor Air Quality. The attributes of the respirable atmosphere (climate) inside a building including gaseous composition, humidity, temperature, and contaminants. (10) IAQ coordinator--A designated person who provides leadership and coordination of IAQ activities. The responsibilities should include coordination of an IAQ team, preparation for emergency responses, dissemination of IAQ information, tracking of IAQ complaints and direction of responses, and communication of IAQ issues and status to interested parties. (11) IAQ management plan--A written plan for preventing and resolving IAQ problems. (12) Indoor air pollution--The presence, in an indoor environment, of one or more air contaminants in sufficient concentration and of sufficient duration to be capable of causing irritation and/or adverse effects to human health. (13) MERV--Minimum Efficiency Reporting Value. A number that reflects the filter efficiency based on the testing procedure defined in ASHRAE Standard 52.2-1999. (14) Microbials--Agents derived from, or that are, living organisms (e.g., viruses, bacteria, fungi, and mammal, bird and dust mite antigens) that can be inhaled and can cause adverse health effects including allergic reactions, respiratory disorders, hypersensitivity disorders, and infectious diseases. Also referred to as "microbiologicals" or "biological contaminants." (15) Negative pressure--A condition that exists when the air pressure in an enclosed space is less than that in the surrounding areas. Under this condition, if an opening exists between these locations, air will flow from surrounding areas into the negatively pressurized space. A negatively pressurized building will have airflow from the outside into the building through available openings. (16) Occupied zone--the region within an occupied space between the planes three and 72 inches above the floor and more than two feet from the walls or fixed air-conditioning equipment (ASHRAE Standard 62-2001). (17) Positive pressure--A condition that exists when the air pressure in an enclosed space is greater than that in the surrounding areas. Under this condition, if an opening exists between these locations, air will flow from the positively pressurized space into surrounding areas. A positively pressurized building will have air flow from the building to the outside through available openings. (18) Preventive maintenance--Regular and systematic inspection, cleaning, and replacement of worn parts, materials and systems. Preventive maintenance helps to keep parts, materials, and systems from failing by ensuring they are in good working order. (19) Public school--A building owned by a public school district or leased by a public school district for three months or more that is used by the district for a purpose that involves regular occupancy of the building by students. (20) Qualified--Personnel possessing the necessary education, experience and equipment (where required) to accomplish the activities being performed. Certifications may be required for some regulated functions, such as asbestos and lead-based paint abatement. (21) Recognized best practices--Those procedures that are considered by knowledgeable practitioners to be necessary to produce the most favorable results.
Texas Administrative Code 25 297.3. Recommendations for Implementing a Governmental Building IAQ Program
(a) Initial program development. The development of a governmental IAQ program should include the following considerations. (1) IAQ coordinator. An IAQ coordinator should be appointed and trained to manage the IAQ program. (2) Occupant considerations. When implementing an IAQ program for a building, characteristics and activities of the population occupying and visiting the building should be considered, as these may indicate unique needs relating to indoor air quality. (3) Facilities assessment. An IAQ and operational assessment of all facilities should be performed to identify and document building operations and problem areas based on current use and recognized codes and Standard where available. Operational and maintenance needs that can be addressed immediately, and in the future, should also be identified and documented. (4) Development of goals. Based on the results of the IAQ occupant needs and facility assessment, and resources available, each IAQ coordinator should develop goals, written plans and programs, which must be achieved for the implementation of an effective IAQ program. (5) Governmental administrative support for stated goals. Administrative support from the highest level of the organization and a written commitment from the governmental entity and other key personnel to the goals are necessary for an effective IAQ program. (6) Funding. Adequate budgets are necessary for IAQ and maintenance staff to meet the stated goals, plans and programs. The amounts of funding will vary based on the scope of each governmental program. (7) Staff. An IAQ support team should be developed and trained as necessary to achieve the goals of the governmental entity. The team may include administrators, facility managers, health officials, custodians and maintenance personnel, an energy manager, design and construction staff, occupants, and others. (b) IAQ management plan. A written IAQ management plan should be developed and maintained. The plan should include the following. (1) Training. Education and training of the IAQ coordinator, support team, and building occupants on the recognition, prevention and resolution of IAQ problems. (2) Communication. A procedure for communicating with building occupants regarding IAQ issues. Communication methods should be in writing utilizing any of the following methods: E-mail, posting in common areas visible to all employees, memo to each area of the facility. The notification should be posted at least five days prior to any activity (pesticide use, painting, dust-producing activities or other maintenance activities which may impact IAQ). (3) Complaint response. A written procedure for documenting and responding to IAQ complaints and problems. The response procedure should include: instructions for obtaining information from complainants, assessing the urgency of the problem and appropriate action to follow, the communication plan for dissemination of information, investigating the complaint or seeking assistance to investigate the complaint as appropriate, deciding on the remedial actions to be implemented and by whom, assessing the effectiveness of the remedial action, and follow-up actions to check the long-term effectiveness of the remedial action or to monitor the recurrence of the original complaint, if no remedial action was performed. This procedure should define the forms that should be used to document and report all activities conducted in response to the complaint and their results. (4) Record keeping. A written procedure that defines the minimum documentation to be collected, handling instructions and length of time for record retention in response to IAQ complaints, including any maintenance, repair or remodeling activities conducted in the building that could adversely impact the IAQ. Records retention rules specific for each agency should be followed. (5) Maintenance and operation plan. A written building maintenance and operation plan containing: a written description of the building systems and functions, and occupancy, schematics and/or as-built drawings with equipment locations and performance criteria, outside air requirements, sequences of operation, daily building and system operation schedules, test and balance reports, maintenance schedules, building inspection checklists and maintenance equipment checklists. The plan should be updated and approved by the IAQ coordinator annually. (6) Implementation schedule. A schedule to implement the IAQ plans and programs. (7) Annual review. Annual IAQ inspection/review of facilities including a walk through by the IAQ coordinator or designee should be conducted. (c) Administrative Review. A review of the IAQ program status and future needs should be presented annually to the appropriate governing body by the IAQ coordinator.
Texas Administrative Code 25 297.5 Building Operation and Maintenance Guidelines
(a) Written preventive maintenance program. A written preventive maintenance program should be established for each public building to provide a healthy environment. The program should include procedures for the following. (1) HVAC Systems (A) Filters. A system filter change-out program should be developed and implemented. A filter upgrade program should be implemented if the filters do not meet the latest recommended efficiency of MERV 9 or higher. Some low capacity air handlers may only have sufficient capacity to utilize MERV 6 filters. (B) Coils and condensate drain systems. A cleaning program of the coil and condensate drain systems of the HVAC systems should be developed and implemented. (C) Cleanliness. The air supply and return systems and mechanical rooms should be kept clean and properly maintained. [...] (b) Training. Personnel should be educated and trained in the prevention, recognition, and resolution of IAQ concerns. (c) Scheduling maintenance. Schedule and conduct maintenance activities that could produce high emissions (painting, roofing repair, pesticide applications) to minimize occupant exposure to indoor air contaminants. Develop and utilize effective ventilation protocols based on system capabilities, occupancy, and contaminant characteristics for each facility and operation. Increase ventilation in occupied areas as necessary to control odors. [...] (f) HVAC systems. (1) Outside air. The HVAC systems should be operated to provide acceptable outside air with quantities in conformance with the most current and accepted standard, such as ASHRAE Standard 62, up to the equipment capabilities. Proper operation and flow rates should be verified annually. The outside intake should be covered with a grill to prevent insects or birds from entering the intake ducts; the grills need to be routinely inspected and cleaned to prevent clogging by dirt and debris. In humid areas, the outside air should be humidity-controlled if the outside air is vented directly into occupied spaces, is continuously left running, or the HVAC unit cannot handle the humidity load on very hot and humid days. (2) Positive pressure. The HVAC systems should be operated to provide a positive building pressure to significantly reduce the entry of outside contaminants, and provide more effective temperature and humidity control. (3) Moisture control. The HVAC systems should be operated to prevent excessive moisture that could cause microbial growth or high humidity. (4) Ducts. (A) Inspection. Periodic (annually is recommended) visual inspection of ducts for mold, dirt and deterioration should be performed. (B) Cleaning. Routine cleaning of ducts in well-maintained systems (i.e. systems that are sealed properly, have high efficiency filters that are correctly installed, and are being maintained per the manufacturers' instructions) is rarely required. Cleaning of ducts internally lined with fibrous or soft material that can be damaged by mechanical cleaning devices is discouraged. Replacement of these types of contaminated lined ducts is preferred. If need is indicated, the ducts should be cleaned using methods that will not expose occupants to potentially harmful substances. Where applicable, the National Air Duct Cleaning Association Standard are recommended. The use of "blown in" chemicals to clean, seal or sanitize ductwork is discouraged. (C) Replacement. When a duct is repaired or replaced, those with internal surfaces that are easily cleaned, not damaged by typical cleaning methods, do not harbor dust and microbials, and that will not emit materials or gases that can harm the occupants should be used. (5) Drain pans. Condensate drain systems should be free of microbial growth and other debris. The condensate pan should drain completely so there is no standing water. The use of unregistered chemicals in the drain pans or on the coils to reduce mold growth that could cause air quality problems for the occupants is discouraged. (6) Exhaust air. Exhaust air systems should be operating properly and vented to the outside. Proper operation and flow rates should be verified annually. (7) Preconditioning. The HVAC systems should be operated for sufficient time prior to building occupancy to remove contaminants and to condition the air. (8) Access. If existing access to the HVAC systems does not allow proper inspection and maintenance, access ports, preferably hinged with good seals and latch(es), should be installed. (9) Responsibility. Assignment of responsibilities for maintenance and operations of all areas and systems is essential to an indoor air quality program. (10) Documentation. Documentation provided by design, construction and renovation projects must be maintained and updated. (11) Standard. Maintenance Standard should be developed and maintained for all systems and operations.
Texas Administrative Code 25 297.7. Assessing and Resolving IAQ Problems
(a) A written plan should be developed as part of the building indoor air quality plan to include specific steps for investigating and resolving IAQ problems. Each facility or governmental entity should decide when and if investigations will be handled by in-house staff or if outside assistance is needed. (b) Complaint response. All IAQ complaints should be acknowledged and investigated as quickly as possible. A written record should be kept of the complaint, investigation findings and resolution. (c) Information gathering. The person(s) complaining or reporting an IAQ situation should be interviewed by a trained IAQ coordinator or qualified individual to gather as much information as possible. This information should include the nature of the complaint, the timing, complainant's symptoms, health effects, observed conditions at time of symptoms, such as odors, weather, occupant activities, and specific location(s) of problem(s). If several people and locations are involved, an occupant questionnaire can be used to help determine if the problem covers a specific location or is throughout most of an area or building, and if there are one or more problems. Results of the questionnaire may also be used to compare with building drawings to locate causes of the problem(s) and sources. (d) On-site inspection. The complaint area should be inspected to locate any problem conditions or materials. Measuring temperature and humidity is recommended. Any visible microbial, chemical or material contamination sources, including the presence of odors, should be noted. During the inspection, the information gathered from the interviews should be compared with possible health effects of various contaminants and their sources, such as listed in Table 1, in § 297.8(b), to aid in determining possible sources and contaminants to look for in the problem and related areas. (e) HVAC system. The operation and condition of the HVAC system should be verified to ensure that adequate acceptable outside air provisions are being met. Check for drafts or stagnant areas. Check whether the layout of air supplies, returns, and exhausts promotes efficient air distribution to all occupants and isolates or dilutes contaminants. Check for short circuiting, airflow patterns and air velocity in occupied zone. Possible exterior contamination sources, such as vehicle exhausts, maintenance and construction operations and levels of natural exterior allergens should be noted. (f) Resolution. Resolution of problem conditions determined as a result of occupant interviews and on-site inspections are often the only actions needed to resolve the complaint. (g) Testing. Performing tests for contaminants of concern and factors affecting IAQ, unless conducted at the time of exposure, are unlikely to locate or measure a transient condition, and are not recommended for most investigations. If specific conditions are suspected and a need for verification testing is required, based on the visual inspection, health symptoms, clinical data and contents, and practices of the facility, then appropriate test methods should be performed by qualified personnel. Laboratory analysis of samples, where required, should be performed by a laboratory recognized or, preferably, certified in performing the analyses requested. Equipment utilized in the evaluation procedures should be calibrated according to manufacturers' recommendations and the sampling methods utilized. Outdoor samples may be needed for comparison with indoor samples for some conditions, such as temperature and relative humidity, and some contaminants, such as carbon dioxide and air-borne mold. (h) Evaluating data and exposures. (1) Before any sample collection, a standard of comparison and/or recognized acceptable Standard should be selected. (i.e., carbon dioxide 700 ppm above outside level). (2) Compare samples collected to Standard established by the same testing methods. (3) Compare indoor and outdoor sample results if appropriate. (4) Compare sample results to the symptoms and complaints using standard toxicological procedures. (i) Remediation. If suspected or other contaminants are identified, perform any necessary remediation using established and appropriate control methods for the situation. (j) Communication. Any perception by building occupants that management is withholding information about an indoor air problem can be very damaging. Steps should be taken to ensure that up-to-date information is provided to building occupants and other concerned parties regarding any on-going IAQ investigations, survey results, planned repairs or remediation projects. (k) Hiring professional assistance. (1) Professional companies or contractors hired to solve, prevent, or control IAQ problems should provide evidence of meeting minimum criteria, to include at least: (A) Education. The contractor should provide evidence of having obtained formal education appropriate to the scope of their professional expertise. (B) Training. The contractor should provide a record of all training in IAQ issues for all workers, as appropriate. (C) Licensure. Contractors performing services that require licensure, such as physicians, engineers, architects, lawyers, asbestos or lead abatement contractors, and similar categories, should provide proof of licensure. (D) Experience history. The contractor should provide verifiable references for at least five projects of similar size and scope. (E) Compliance history. The contractor should provide a list of all compliance actions initiated by the U.S. EPA, U.S. Occupational Safety and Health Administration, the Department, the Texas Commission on Environmental Quality (formerly the Texas Natural Resources Conservation Commission) or similar local agencies that are applicable to the job. (F) Proof of insurance. The contractor should provide proof of insurance that includes general liability and/or errors and omissions coverage, as appropriate, to cover the job. (G) Equipment. The contractor should have knowledge and skill to use the proper testing and inspection equipment needed to perform the job. (2) Avoid conflicts of interest. Ensure that contractors are not in a position of (or the appearance of) creating work for themselves, nor inspecting or approving their own work.
Texas Administrative Code 25 297.8. Guidelines for Comfort and Minimum Risk Levels
(a) IAQ Comfort. Comfort is an important part of indoor air quality. The major comfort issue is thermal comfort that involves temperature, relative humidity, and air velocity. Other comfort issues not covered here but that could affect the indoor environment are lighting, noise, and vibration. Maintaining the proper temperature range is not sufficient to achieve thermal comfort; it is also necessary to properly control the combination of temperature, relative humidity and air velocity. (1) Temperature. The room temperature for a typical occupied office or classroom environment should be kept between 72 to 76 degrees Fahrenheit in the summer and 70 to 75 degrees in Fahrenheit in the winter and controlled within a temperature range of +/-2 degrees in Fahrenheit for a given day. Temperature at body and head height and near the floor needs to be considered. Occupant preferences, activity and attire will influence the comfort. Additional guidance documents for other situations are available, including ASHRAE Standard 55-1992 and 55a-1995. (2) Relative Humidity. The relative humidity for a typical occupied office or classroom environment should be generally between 30 to 50%. The relative humidity should never exceed 60% due to potential mold growth. In geographical regions where the outdoor relative humidity is typically below 30%, no humidification is recommended if the occupants do not complain of discomfort due to the dryness. (3) Air Velocity. Some air movement is recommended to avoid a feeling of stagnant air, typically 25 to 55 feet per min (fpm). Higher air speeds may be acceptable if the affected occupants have control of local air speeds. Air supplied to the occupied zone (standing and sitting positions) should be supplied at a moderate velocity within the recommended temperature and relative humidity ranges. Air supplied from a diffuser at elevated speeds can create drafts in the occupied zone, causing complaints of too hot or too cold, dry eyes, sore throats and nasal irritation. Directing diffusers directly onto occupants' work zones or directly overhead may cause occupants discomfort, resulting in them "modifying" the supply system (e.g., placing cardboard over diffusers). The system should be properly tested and balanced. The appropriate supply and exhaust diffusers based on the occupant locations should be installed. These diffusers should supply air at an acceptable temperature and humidity. Additional guidance documents are available, including ASHRAE Standard 55-1992 and 55a-1995. (b) Minimum Risk Levels. Table 1 in paragraph (4) of this subsection provides Minimum Risk Levels (MRLs) for common contaminants found in indoor air. The MRLs in Table 1 are not IAQ Standard. There are no required federal or Texas Standard for indoor air contaminants. The MRLs are based on the data contained in the Texas Commission on Environmental Quality's (formerly the Texas Natural Resources Conservation Commission) Effects Screening Levels List (July 19, 2000), the Agency for Toxic Substances and Disease Registry's (ATSDR) Minimal Risk Levels for Hazardous Substances (December 2001), and the Environmental Protection Agency's (EPA) Integrated Risk Information System (IRIS) inhalation RfC values and the National Primary and Secondary Air Quality Standard (40 CFR 50). These information sources can be used as a reference for other contaminants not listed in Table 1. (1) These levels are based on inhalation for an eight hour exposure for the general public. If a particular contaminant is expected to last significantly longer, the MRL should be lowered to compensate for the longer duration. The references in subsection (b) of this section may have this information. For one year, a reasonable approximation is to multiply the 8-hour MRL by 0.14. (2) Most of the MRLs are at a no-observed-adverse-effect-level. They are set below levels that, based on current information, might cause adverse health effects in the people most sensitive to such substance-induced effects. If the indoor levels of contaminants in air exceed the MRL, it does not necessarily indicate a problem, but should trigger a concern for a more in-depth evaluation of the potential health effects or to reduce the concentration below the MRL. Most of the MRLs are based on non-cancer health effects only. (3) The MRLs are expressed in units of parts per million (ppm) for most gases and volatiles, or milligrams per cubic meter (mg/m 3 ) for particles and some volatile organic compounds (VOCs). (4) Table I. Common Indoor Air Conditions/Contaminants in Government Buildings. [See table, form or illustration in printed version]
Texas Statutes Health and Safety Code 341.065. School Buildings and Grounds.
(a) A school building must be located on grounds that are well drained and maintained in a sanitary condition. (b) A school building must be properly ventilated and provided with an adequate supply of drinking water, an approved sewage disposal system, hand-washing facilities, a heating system, and lighting facilities that conform to established Standard of good public health engineering practices.