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NATIONAL EDUCATION ASSOCIATION TESTIMONY OF THE NATIONAL EDUCATION ASSOCIATION ON INDOOR AIR QUALITY RULES FOR THE OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION PRESENTED BY JOEL PACKER SENIOR PROFESSIONAL ASSOCIATE DECEMBER 13, 1994 T!023206~8

I would like to thank the Occupational Safety and Health Administration for this opportunity to speak for the National Education Association (NEA) on the Indoor Air Quality Rules. My name is Joel Packer, and I am a Senior Professional Associate for Government Relations for NEA. rm accompanied today by Kara Reed, an NEA member from Jamestown, New York. Also with me today on this paneI are representatives of the American Federation of Teachers (AFT). The NEA represents 2.2 million education employees, both teachers and support staff, from kindergarten through 12th grades, and in higher education. A substantial number of our members are not covered by OSHA, because of their public employee status. Our members who are covered by OSHA rules and regulations are working in environments that are considered among the riskiest for workers. One migfit not immediately think about schools as buildings that have serious indoor air problems, but they are often more dangerous than an average ottice building. On any given day, a school or college building houses any number of activities, including: janitorial work that requires the use ofinduslrial cleaners and disinfectants; research in chemistry labs that contain an array of toxic and other potentially dangerous substances; art work in rooms that contain paints and other chemicals; computer work in classrooms where there are high magnetic fields and ozone and toner dust from the printers; health services in university hospitals, where toxic chemicals are used to disinfect equipment; &flee work that requires the use of machines that emit toxic compounds, custodial and groundskeeping work that involves the use of pesticides; and other activities in woodshops, maintenance garages, and print shops. T102320689

Although there have been no overall comprehensive studies done of indoor air quality in schools, the National Institute for Occupational Safety and Health (NIOSH) reports that 13% of the facilities it investigated through 1988 for indoor air contamination, were schools and colleges. In the proposed rules on Indoor Air Quality, OSHA reports that 284,000 buildings are occupied by students and education employees. In a 1993 report by the New York Department of Education, the number of schools voluntarily reporting indoor air quality problems has steadily increased over the past few years. The report cites indoor air pollutants as a major health threat to individuals with asthma, bronchitis, and other respiratory ailments. Others without specific medical conditions are also at risk of headache, fatigue, dizziness, coughing, and other allergic reactions. Last week, in Silver Spring, Maryland, a teacher, two students, and a custodian were overcome by fumes that erupted when the custodian improperly mixed cleaning fluids. The American Association of School Administrators (AASA), reports that headaches, nausea, and growing absenteeism led to the eventual closing of a Pennsylvania elementary school in 1991 due to a cleaning solvent used in the removal of floor tiles. The group also reports that there have been closings of new schools from New Hampshire to California due to indoor air problems. In response to a recent inquiry,/flEA has received numerous examples of indoor air problems experienced by our members. One teacher responded that his middle school had been found to be contaminated with high levels of asbestos. After a cosily cleanup, the school board found that the business and facilities managers were aware of the asbestos and failed to report it. This teacher also reported a wall in his classroom that had turned "black and furry from mold caused by water damage." The school district removed the board and sprayed fungicide the day before classes started. Many teachers and students are now complaining of severe allergies and sinus infections. 2 T102320690

Other respondents reported sinus infections and migraines traced to high mold content in their school building; mysterious rashes the school thinks are tied to a humidity and ventilation problem; chemical sensitivity reaction to carpet installation; students getting nosebleeds in a room refer~ed to as "the cave," because it has a closed ventilation system and no windows; and a teacher in Virginia reporting a lung bacterial infection that has been traced to mold growing on books, fumittlre and a clock in her classroom. In Indiana, an NEA member reported problems with sinus infections caused by a faulty air filter. In one high school there, the outside air intakes are closed, and a cooling tower in a nearby middle school collects bus exhaust fumes. In addition to the hazards rye atready mentioned, schools and colleges arc unique in other ways. Most of the public schools in this country arc crumbling and in disrepair from age and a lack of money. Nearly 90% of all schools wcrc built before 1980, while 50% wcrc built prior to 1960. Schools that do get the money to undertake construction and renovation usually do so with students and teachers onsitc, while fumes, dust, and other particles settle over them. Elementary schools also rely on portable buildings that arc not designed to service the unique requirements of schools. Children, who arc much more susceptible to toxins and chemicals, arc also crowded together. The typical school has approximately four times as many occupants as office buildings for the same floor space. We also have data about some specific pollutants found in schools. According to the 1992 results of the National School Radon Survey conducted by the Environmental Protection Agency, 19.3 percent ofU. S. schools - nearly one in five - have at least one room with unsafe levels of radon. In total, EPA estimates that 70,000 classrooms in 15,000 schools have elevated radon levels. In as many as 10,000 classrooms, teachers and students are exposed to more radiation from radon (over 10 pCYl) than the average ~vorker is exposed to T102320691

in a nuclear power plant_ Often, elevated radon levels in schools are linked to other indoor air quality problems. Lead-based paint dust is another threat to both school workers and students. Since many schools were built before the use of lead-based paint was banned, thousands of school buildings have hazardous levels of lead present. One study from New York City schools found that 16 percent, or one out of every six, appeared to have an immediate lead hazard. As I have described, schools are unique repositories for an array of contaminants, their maintenance is dependent on public money, children are more susceptible to indoor air pollution, poor air quality is responsible for higher absenteeism rates, which interferes with a schools' ability to function properly, and schools house more people in a given space than most office buildings. It is especially important that OSHA protections find their way to our nations' schools. For this reason, NEA strongly supports the language in the proposed roles on environmental tobacco smoke. Stricter statutory protections against environmental tobacco smoke already apply to schools under the recently enacted Goals 2000: Educate America Act. We strongly support the overall regulation, in particular, the section requiring employers to have a written indoor air quality plan. Such a plan would include having to keep records of employee complaints about indoor air problems, and to provide training to employees who perform work that subjects them to indoor air pollutants. I would like to provide comments on some specific aspects of the proposed indoor air quality regulations: 4 TI02320892

Defitfition of Air Contaminants: NEA suggests that this definition specifically include radon, asbestos fibers, and lead-based paint dust. While all three of these substances may be covered under the proposed definition which includes "particulates", and "outdoor air pollutants," for the sake of clarity, listing these would be preferable. Indeed, schools have concentrated their efforts in the area of indoor air in these three items and EPA has provided extensive guidance to schools on these hazardous materials. Designated Person: NEA strongly supports the requirement of having one "designated person" to coordinate, oversee, and ensure proper implementation and compliance with these indoor air protections. Schools are very familiar with this concept, since under the Asbestos Hazard Emergency Response Act (AHERA), such a designated person is already required for every public school district in the country. In fact, we urged OSHA to suggest that a school's designated person for asbestos be the designated person for this standard. Indoor Air Quality (IAQ) Compliance Program: We strongly urge that employers provide copies of the written IAQ plan to the designated employee union[s] or other employee representatives, and that all employees be informed of the existence of the plan, and their right to see it. In addition, the designated employee representative should have the right to make comments on the proposed IAQ plan, before it is finalized by the employer, and the employer should have to respond in writing to such suggestions. Employee Complaints While we support the requirement that the employer maintain a written record of employee complaints, and what, if any, remedial action was implemented, we recommend this section be sl~engthened by adding a time frame for responding to such complaints. We share the specific views of the American Federation of Teachers that complaints resulting from acute reaction to a renovation be addressed the same day, and all other complaints should be responded to within 10 days. We also support AFT's suggestion 5 T102320693

that a medical removal be required when remediation cannot be accomplished in a timely manner. In closing, the members of the NEA are broadly affected by poor air quality in the schools. Our members are not just teachers, but are office support staff, custodians, maintenance workers, cafeteria workers, bus drivers, and classroom aides. They would benefit from the training and protections that would result from the adoption of these rules. Often, school indoor air problems can be traced to deferred maintenance due to budget cuts. However, schools that defer maintenance and thereby cause indoor air quality problems, will pay more in the long run, in more expensive and extensive repairs and renovations, and in costs associated with loss of productivity from sick days, depressed employee morale, and increased health care costs of employees who suffer illnesses from these indoor air problems. Because OSHA does not uniformly cover public employees, hundreds of thousands of our members will not derive any benefit from these indoor air quality rules. NEA will continue to press Congress to extend OSHA protection to all public employees. We thank the Department of Labor for supporting the expansion of OSHA to all public employees. NEA cooperated with the Environmental Protection Agency in the development of its handbook on indoor air quality, and we will be listed as an endorser of that publication. Working together, we will continue to work for health and safety protections in the workplace. I would now like to turn to Ms. Reed, who ~vill provide a real life example of the horrible health hazards that are caused by indoor air pollution in schools. 6 TI02320694

6o Introduction Comments on Environmental Tobacco Smoke Exposure Comments on the use of Nicotine and Cotinine as Environmental Tobacco Smoke Biomarkers Studies with experimental animals ETS Exposure, Lung Cancer & Heart Disease: The Epidemiologic Evidence Comments on Smoking Status Misclassification Comments Addressing Engineering Alternatives for Environmental Tobacco Smoke Control Conclusion Dr. Chris Coggins Dr. Michael W. Ogden Dr. Paul R. Nelson Dr. Chris Coggins Dr. Sears/Mr. Steichen Dr. Michael Ogden Hoy Bohanon, PE Dr. Chris Coggins T102320695