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Administrative Procedure 3523 - Environmental Issues

I. Purpose

To provide mandatory procedures that must be followed to resolve environmental issues in schools and administrative office buildings

II. Background

As part of ongoing efforts to provide a safe and healthy learning and work environment, the school system established a Division of Supporting Services Environmental Office to oversee environmental issues such as asbestos containing building materials (ACBMs), lead in paint or water, mold spores, air quality, water quality, and pest management. In order to effectively and consistently deal with these issues, all environmental concerns must be under the direct control of the Environmental Office. Therefore, all building environmental issues must be handled in accordance with this Administrative Procedure.

III. Definitions

Environmental Assessment -- Any activity performed within or around a building to determine the presence of potentially irritating or harmful substances. This may consist of, but is not limited to, a visual inspection, on-site monitoring and specific
sampling for Laboratory analysis.

IV. Information

Asbestos Hazard Emergency Response Act (AHERA) requires routine building inspections for asbestos containing building materials. The Code of Maryland Regulations (COMAR) require implementation of Integrated Pest Management (IPM) and the Environmental Protection Agency’s EPA) Safe Water Drinking Act (SWDA) mandates water testing for buildings using well water. The Environmental Office may authorize additional environmental assessments using approved contractors, if necessary, to ensure a safe environment for students and staff.

To ensure that requests regarding environmental issues are properly processed, a work order request form, detailing the specific concern(s) must be submitted to the Division of Supporting Services. Appropriate staff will conduct an initial inspection
of the facility to determine what actions are necessary. To ensure that each facility maintains a safe and healthy environment, observed deficiencies will be addressed accordingly. This may include equipment repair, improved housecleaning practices
and additional testing. The school system maintains an annual contract with an independent, certified consultant to conduct environmental testing; and that firm has the responsibility of disseminating the results, interpreting the data and providing a
list of corrective measures that may be warranted. Therefore, the use of private contractors by building staff shall not be allowed unless specifically authorized by the Environmental Office.

The Division of Supporting Services has an Environmental Officer; this staff person is the first point of contact for any environmental concerns. The Environmental Office has assigned a licensed Environmental Inspector and Pest Control Inspector
to each facility; this staff person is the second point of contact for any environmental concerns. The following are the types of testing currently administered by the Environmental Office:

  1. WATER TESTING:
    1. The Washington Suburban Sanitary Commission (WSSC) supplies water service to the majority of our facilities. If concerns are expressed relative to the water quality of a facility serviced by the WSSC, the Environmental Office will evaluate such and, if warranted, arrange for the provider to conduct water quality testing. The associated analytical report information will be provided to the building administrator.
    2. WELLS:
      1. BACTERIA: Well water is tested quarterly for the presence of bacteria (fecal and total coliform) as mandated by Maryland State Law. Copies of the written analytical reports are mailed to the Maryland Department of the Environment (MDE).
      2. COPPER AND LEAD: Well water is also tested for copper and lead contents. The frequency rate of the test depends on the results obtained, and copies of the written analytical reports are mailed to MDE.
      3. NITRATES: Well water is also tested for the presence of nitrates to determine if runoff from fertilizer, leaking septic tank sewage, and erosion of natural deposits has entered the groundwater system. Copies of the written analytical reports are mailed to the Maryland Department of the Environmental (MDE).
    3. OTHER WATER CONCERNS: Environmental Office personnel investigates other water quality concerns, such as lead, unusual odors, or discoloration, or the presence of sediment. Where action is warranted, the water source provider tests the water and provides a copy of the analytical report to the school system.
  2. ASBESTOS:
    1. Asbestos Hazard Emergency Response Act (AHERA), The Code of Federal Regulations (CFR) 40 Part 763, mandates asbestos re-inspections of all facilities every three years by inspectors assigned to the Environmental Office. Asbestos Management Plans are updated accordingly. Asbestos Management Plans for each building are available to the public.
    2. In accordance with all required regulations, all activities requiring asbestos abatement are completed by individuals specifically qualified to perform such work. The building staff and guardians are notified accordingly.
  3. INDOOR AIR QUALITY TESTING:
    1. EQUIPMENT-RELATED ISSUES: In order to provide the proper air quality, all equipment must be functioning and thermostats properly set. Equipment that is not working properly should be reported to the custodial staff and, if required, a work order repair request should be processed, relative to the need. The proper thermostat settings are listed in Bulletin S-46-96; or locate the Maintenance Department web page on the Prince George's County Schools web site.
    2. UNUSUAL FUMES OR ODORS: Unusual and/or irritating fumes should be reported immediately to the Building Supervisor, who will notify the Department Head or Principal. Staff and students should be temporarily relocated out of the area of concern while it is being investigated.
  4. OTHER ENVIRONMENTAL CONCERNS:

    MOLD: Visual mold growth should be reported to the Building Supervisor, who will investigate its cause and notify the Department Head or Principal. Depending on the severity of the condition, the Department Head or Principal may refer the issue to the Environmental Office who will perform an inspection and determine what steps are necessary to resolve the problem. Steps may include maintenance and/or repair of equipment and cleaning, treating, or sealing surfaces. Environmental Office staff may enlist the contracted vendor to perform additional tests and/or make recommendations.

V. Procedures

The following procedures should be used in initiating environmental testing in any school system building. Students, staff, or parents should report initial concerns to the Department Head or Principal, who will notify the Building Supervisor. The Building Supervisor is to make the preliminary inspection of the area of concern and notify the Department Head or Principal.

  1. Initiating a Request: Department Head or Principal.
    1. Determine what type of environmental concern needs to be addressed and Process accordingly on the proper work order request form, in accordance with the Division of Supporting Services procedures.
    2. Provide as much information as possible to facilitate the repair in an expeditious manner.
    3. Submit Work Order Request: submit online Work Order request.
    4. If the environmental concern poses a potential health concern, the Department Head or Principal will notify staff and students in writing of the concern and give updates in writing of any actions taken to address the situation.
    5. Cases of a more urgent nature should be telephoned to the Division of Supporting Services. The building staff should provide as much information as possible in order to ensure that the concern is properly addressed.
  2. Approval: The Chief of Supporting Services will approve the project.

VI. Related Policies and Procedures

VII. Maintenance and Update of These Procedures

This Administrative Procedure will be reviewed periodically by the Chief of Supporting Services and updates will be made as necessary.

VIII. Cancellations and Supersedures

This Administrative Procedure cancels and supersedes Administrative Procedure 3523, dated May 27, 2003.

IX. Effective Date

July 1, 2013.

About This Procedure

Last Revised: July 1, 2013

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