by Roger Francoeur
Every summer I receive a number of emergency calls because of renovation projects that have fallen into tailspin as a result of environmental health & safety (EH&S) issues. Usually these “surprises” translate at the least into delayed schedules, confusion, cost overruns, and premiums for expediting work. Even more serious consequences include worker or public injury, exposure to hazardous materials, bad publicity and legal liabilities. Basic construction safety standards and procedures are fairly well known, especially among the mid – to larger-sized firms; however, many involved still do not possess a clear understanding of other issues such as asbestos, mold, indoor air quality, chemical exposures, PCBs, mercury and lead paint. Too often it is an afterthought, under-appreciated, or in some cases, a needless knee-jerk overreaction. With K-12 schools, there often is even more care required, heightened regulations, and more severe repercussions for inadequate planning and response to EH&S issues.
Most building professionals have at least a vague awareness of the more common culprits, such as asbestos-containing building material (ACBM) and lead paint. Asbestos inspections are required prior to renovation or demolition, and if ACBM is identified and is to be disturbed by the work, it must be properly abated. For K-12 schools, there are additional requirements pursuant to the EPA Asbestos Hazard Emergency Response Act (AHERA) for more stringent abatement design, independent oversight, testing, and recordkeeping.
Most schools already have had some level of inspection and reporting for asbestos. What is lesser known is that the AHERA reports often are not sufficient for the more current construction rules. In particular, the AHERA reports do not sufficiently address hidden or concealed ACBM nor do they address most exterior suspect building materials. Supplemental pre-renovation/demolition surveys must be completed.
Another little known fact is that even if a school building was constructed in the late 1980’s, 1990’s or even 2000’s there still is the requirement for a pre-renovation/demolition survey. We have found many ‘newer’ school buildings with asbestos present. Some asbestos building materials are still produced and can be purchased today. For new school construction, be sure to provide an architect or engineer statement certifying that no asbestos was used in the new construction and to differentiate if some older buildings may still be present with ACBM or suspect ACBM following completion of the work.
Lead-based paint is also present in many buildings constructed prior to 1978. Many schools are now impacted by the recent EPA Lead Paint Renovation and Repair (RRP) rule bringing more widespread requirements for renovation of older buildings. PCB caulking has also become an issue over recent years requiring hazardous waste disposal, coordination with the EPA for remediation planning, costly handling procedures and possibly in place management plans.
In addition, general indoor air quality (IAQ) must be considered especially if work is taking place in conjunction with occupancy by school staff and kids. Some level of testing should be performed prior to the start of work such that if complaints or concerns arise during the job, there are some baseline readings to use as comparison. This is particularly true in the case of contaminants with little or no regulatory standards for indoor air quality, for example, mold and ultrafine particles. Other IAQ components frequently considered include carbon dioxide, carbon monoxide, thermal and relative humidity and volatile organic compounds.
All of these potential hazards and concerns are best handled proactively. Have an EH&S expert on the project design team and be sure to consult with the school’s asbestos program manager. Be sure that a recent, thorough pre-construction survey has been completed by a certified firm. These considerations are well worth the effort for you, your employees and your customers.
Roger Francoeur is president of RPF Environmental, Inc. in Northwood, NH.
