Administrative Procedure 4221 - Employee and Adult Entrance of Student Restrooms, Locker Rooms and Designated Changing Areas

I. Purpose

To establish procedures regarding employee and adult entrance into student restrooms, locker rooms or designated changing areas.

II. Background

Following the comprehensive recommendations from the Student Safety Task Force, the Board of Education and Chief Executive Officer has committed to updating policies, procedures, training and protocols to enhance student safety in the school system.

This procedure implements another of the Task Force’s recommendations by clarifying the prohibition against employee use of student restrooms on PGCPS property. It also provides direction for staff regarding the supervision of locker rooms and designated changing areas by applicable school system personnel.

III. Definitions

1. Applicable School System Personnel: any school system employee assigned to cover athletic events, physical education classes or creative and performing arts events, including athletic coaches or athletic trainers; physical education instructors; substitute teachers; paraprofessionals; school security; and school administrators.
2. Locker Room: the area in the school – usually near the gymnasium - containing lockers for the storage of belongings and private space for students to change for athletic competition, participation in physical education classes or creative and performing arts events.
3. Designated changing area: any area or room in the school other than the locker room that is being designated by the principal for the purpose of providing space for students to change for athletic competition, participation in physical education classes or creative and performing arts events, such as the black box, dance room, or dressing room.
   
   A classroom may never be used as a designated changing area.

IV. Procedures for Student Restrooms

1. Employees and other adults are prohibited from entering or using student restrooms on PGCPS property during the school day, subject to the exceptions below. For purposes of this procedure, “employees” include independent contractors visiting or working on PGCPS property, as well as temporary and substitute employees.
2. School principals or building supervisors shall ensure that all student and adult restrooms in the building are clearly marked with signs that indicate whether the restroom is designated for student or adult use only.
3. Exceptions for Employees:
   1. Employees may enter student restrooms in the event of an emergency or other situation that requires prompt intervention in order to respond to or prevent a health or safety hazard. Employees are strongly encouraged to have at least one other employee present in such circumstances, whenever possible.
   2. School system security staff or school administrators may enter student restrooms during the course of a random safety and security sweep. These sweeps may be conducted in order to foster a safe environment for students and staff, while addressing and discouraging inappropriate conduct from occurring in areas not routinely covered through video surveillance or visible to staff.
      
      To conduct a safety and security sweep, at least two staff members will be present who are of the same gender as the persons using the bathroom. An announcement shall be made before entering the bathroom for the sweep (a) stating the purpose of the staff members’ entrance, and (b) affording persons in the bathroom the opportunity to fully dress.
      
      These preventive measures shall be directed jointly by the Administrative and Security Staff and tracked for frequency, location and results.
   3. Employees who wish to request a special accommodation under the Americans with Disabilities Act (ADA) may contact the Equal Employment Opportunity advisor for additional assistance.

V. Procedures for Locker Rooms and Designated Changing Areas

1. Supervision of Students:
   
   1. To help ensure a safe and secure environment for students, applicable school system personnel shall continuously monitor and supervise the locker room or designated changing area as students dress for athletic activities, physical education classes or creative and performing arts events.
   2. The personnel assigned to monitor the locker room or designated changing area shall be the same gender as the students being monitored – i.e., female personnel monitoring the girls locker room.
   3. The responsibilities for applicable school system personnel include:
      
      1. Monitor the locker room and designated changing area in a safe manner, moving around to cover all areas when students are present.
      2. Create a plan for adequate coverage and supervision of students during both the beginning and ending of practices, classes or events.
      3. Follow the same rules (or exceptions) for entering student restrooms described in Section IV above, unless the student has a disability and requires assistance as outlined in an individualized education plan (IEP).
      4. Establish a set amount of time for students to change before and after athletic events, physical education classes and creative and performing arts events.
   4. In accordance with Administrative Procedure 5132, students shall be prohibited from using portable electronic devices while in the locker room or designated changing area.
2. Monitoring and Compliance:
   
   The principal or his/her designee (typically the athletic director and the physical education department chairperson) shall train all applicable school system personnel regarding locker room supervision.

VI. Related Policies and Procedures

• BP 0126 - Student Safety and Prevention of Child Sexual Abuse
• AP 2815 - Restroom Repairs and Daily Inspections During School Hours
• AP 4216.6 - Volunteer Services
• AP 4218 - Dating and Sexual Relationships Among Students and Employees, Independent Contractors, and Volunteers
• AP 4219 - Inappropriate Interactions Among Students and Employees, Independent Contractors, and Volunteers
• Administrative Procedure 5132 – Portable Electronic Devices

VII. Maintenance and Update of these Procedures

This Administrative Procedure is maintained by the Office of General Counsel and will be updated as needed.

VIII. Cancellations and Supersedures

This procedure cancels and supersedes the version dated August 8, 2017.

IX. Effective Date

Last Revised: August 27, 2018

Documents

• Administrative Procedure 4221 - Employee and Adult Entrance of Student Restrooms, Locker Rooms and Designated Changing Areas.pdf