| Jenefer Youngfield School Construction Inspection Specialist 801-538-7669 801-538-7729 (fax) |
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8. Maintenance and Operation of BuildingsRevised 12 September 2007 The average age of Utah educational facilities today is somewhere between 30 and 50 years. Some buildings date back to the first decade of this century and are from 80 to 95 years old. School boards, district administrators and school-level administrators must take appropriate action to ensure school and district facilities last as long as possible. School district facility maintenance personnel should be provided the resources they need to maintain district buildings in the best possible condition. Top priority should be given to life-safety issues that protect the occupants of the buildings, followed closely by repairs without which the facility or equipment could be severely damaged. The topics listed below are some of the most critical elements of building maintenance to ensure the safety of occupants and longevity of existing facilities. a. Indoor Air Quality The importance of educating and training school district maintenance staff about indoor air quality cannot be overstated. Indoor air quality concerns the safety and welfare of building occupants. Children, teachers and administrators spend over a thousand hours per year in our educational facilities. We must ensure the air they breathe is safe, clean and conducive to a positive learning environment. However it is organized, indoor air quality monitoring and fundamental improvements should be accomplished in an organized and documented response. It is also important to ensure appropriate resources are dedicated to make the needed repairs as necessary. (1) Air Filtration Improvement The one, single task that is the undisputed foundation of any indoor air quality maintenance program is changing air filters. This is where immediate indoor air quality can be achieved, but unfortunately, this is one particular job that is most often overlooked or neglected. Maintenance personnel should first identify where each filter is located in each building and then start and maintain an air filter log to document how long each filter has been in place. Today the bottom line is to cut cost, and understandably, the majority of building owners and maintenance managers still use whatever inexpensive air filter is available. Many times these "cheap" filters are only about 7% efficient, and so 93% of the air contaminants that could have been removed, are just re-circulated throughout the building. The most elementary, the most cost effective and the most worthwhile indoor air quality improvement that can be made in most any building is to use at least a 30% pleated air filter, and change them regularly. School district maintenance personnel can get free local help from their specific air filter professionals. A good contact for information is the National Air Filtration Association at (757) 313-7400. Many local air filtration representatives will be happy to go to schools, look at the different applications, and try to help districts get appropriate filtration systems in place. (2) Outside Fresh Air Intake, HVAC Air Handlers, and Building Exhaust Systems The building Heating Ventilation and Air Conditioning (HVAC) system has a direct relationship to building air quality. It must be clean and operating properly. Many times building owners will try to save energy costs by closing the outside fresh air dampers during cold weather. The building will then be in a negative air pressure status and vehicle exhaust, for example, may be pulled into the building from a loading/unloading area. Sometimes an HVAC unit is wet and moldy inside because of improper condensate removal or a defective rooftop exhaust fan goes unnoticed because a related temperature problem in the building cannot be felt. Maintenance personnel need to check the outside air intake louvers, bird screens, pre-filters, and pre-heat coils for obstructions. In addition, the outside air damper blades, linkage and damper motor need to be checked for proper operation. Also, check for outside air contaminants: is the outside air intake louver near a potential pollution source? Check the building exhaust system: is the fan operating properly (motor, pulleys, bearings, blower wheel)? Any obstructions? (3) Pollution Source Management Indoor air quality maintenance personnel need to recognize sources of indoor air pollution that are happening daily. Many times maintenance personnel who understand potential pollution sources can often prevent, minimize, or eliminate the problem easier than it may seem and sometimes at no additional cost to the school district or charter school. Keep it simple and use common sense to find and correct problems early when it is easiest to control. Areas of potential pollution include: High indoor humidity areas or areas with water damage: • stained ceiling tiles Inadequate exhaust areas: • chemical storage areas Occupant activities: • Food or garbage Being proactive and documenting potential pollution sources can eliminate air pollution before it occurs. (4) Responding to Occupant Complaints It is important to follow a step-by-step written procedure for responding to indoor air quality complaints. Far too often these complaints are side-stepped or ignored because the maintenance department does not have a specific department policy in place. Maintenance personnel are not expected to immediately solve all indoor air quality problems, but the department is expected to respond, to document, and to follow through on each call. Delayed or ignored responses to an indoor air quality complaint can eventually lead to an escalation of problems and additional cost that could have been avoided. To prevent these situations, a simple complaint/response log sheet should be developed. The complaint/response log should contain the following elements: ► Building, area, room Type if indoor air quality problem: ► Comfort-temperature or humidity problem? Check surrounding area: ► Storage rooms Check basic air measurements: ► Temperature Check the basics of the HVAC system ► Is there a control problem? What is the sequence of operation? Check the air distribution system—start at the return; check filters, inside the air handler, make sure no dampers are closed; check fire dampers. ► Is there a defective exhaust fan in the area? Check the outside fresh air intake location—are there any indications of outside pollutant sources being pulled into the building? Keep a record of all related phone calls, dates, meetings, etc. If there is a delay in progress, talk to the concerned person and try to keep them informed. Document the conversations and dates. List the order of events and the specific repairs that eventually took place. It may be possible that the school district or charter school may have to call in an outside industry professional. The work that the district or charter indoor air quality maintenance personnel have done will be valuable to the consultant and the outcome of the solution. An excellent resource for school districts and charters is Indoor Air Quality for Schools as well as the Indoor Air Quality Tools for Schools (IAQ TfS) Action Kit , Building Air Quality Action Plan, and the Indoor Air Quality Design Tools for Schools. Other resources can be found at Environmental Protection Agency (EPA) web site and the National Institute of Occupational Safety and Health (NIOSH) web site. These web pages and resources may be helpful to school districts and charter schools as they develop action plans to deal with indoor air quality. b. Hazardous Waste A waste is any solid, liquid, or contained gaseous material that you no longer use and either recycle, throw away, or store until you have enough to treat or dispose of. School districts and charter schools may generate wastes that can cause serious problems if not handled and disposed of carefully. Such wastes could: (1) Hazardous Waste Laws, Regulations and Rules In 1976, the U.S. Congress passed the Resource Conservation and Recovery Act (RCRA) which directed the Environmental Protection Agency (EPA) and National Institute of Occupational Safety and Health (NIOSH) to develop and implement a program to protect human health and the environment from improper hazardous waste management practices. The program is designed to control the management of hazardous waste from its generation to its ultimate disposal. EPA first focused on large companies, which generate the greatest portion of hazardous waste. Business establishments, school districts, and other agencies and institutions producing less than 2,200 pounds of hazardous waste in a calendar month (known as small quantity generators) were exempted from most of the hazardous waste management regulations published by EPA in May 1980. In recent years, however, public attention has focused on the potential for environmental and health problems that may result from mismanaging even small quantities of hazardous waste. For example, small amounts of hazardous waste dumped on the land may seep into the earth and contaminate underground water that supplies drinking water wells. In November 1984, the Hazardous and Solid Waste Amendments to RCRA were signed into law. With these amendments, Congress directed EPA to establish new requirements that would bring small quantity generators, who generate between 220 and 2,200 pounds of hazardous waste in a calendar month, into the hazardous waste regulatory system. EPA issued final regulations for these small generators of hazardous waste in March 1986. Most of the requirements became effective in September 1986. (2) The Hazardous Waste Regulatory System There are two ways a waste may be brought into the hazardous waste regulator system: listing, and identification through characteristics. (a) "Listed" Wastes School district and charter school waste is considered hazardous if it appears on any one of the four lists of hazardous wastes contained in the federal Resource Conservation and Recovery Act (RCRA) regulations. These wastes have been listed because they either exhibit one of the characteristics described below or contain any number of toxic constituents that have been shown to be harmful to health and the environment. The regulations list over 400 hazardous wastes. Many of the listed hazardous wastes that school districts or charter schools are likely to generate are included below in this resource manual. (b) "Characteristic" Wastes Even if a waste does not appear on one of the EPA lists, it is considered hazardous if it has one or more of the following characteristics: ► It is unstable or undergoes rapid or violent chemical reaction with water or other materials; this is called a reactive waste. Examples are cyanide plating wastes, waste bleaches, and other waste oxidizers. A waste sample is tested and shows Extraction Procedure (EP) toxicity. Wastes are EP toxic if an extract from the waste is tested and found to contain high concentrations of heavy metals (such as mercury, cadmium or lead) or specific pesticides that could be released into the ground water. (3) Material Safety Data Sheets Material safety data sheets, or MSDS sheets are a detailed information bulletin prepared by the manufacturer or importer of a chemical that describes the physical and chemical properties, physical and health hazards, routes of exposure, precautions for safe handling and use, emergency and first-aid procedures, and control measures. Chemical manufacturers and importers must develop an MSDS for each hazardous chemical they produce or import, and must provide the MSDS automatically at the time of the initial shipment of a hazardous chemical to a distributor or user. Distributors also must ensure that downstream employers are similarly provided an MSDS. Each MSDS must be written in English and include information regarding the specific chemical identity of the hazardous material(s) involved and the common names. In addition, information must be provided on the physical and chemical characteristics of the hazardous chemical; known acute and chronic health effects and related health information; exposure limits; whether the chemical is considered to be a carcinogen by the U.S. Occupational Safety and Health Administration (OSHA) and UOSH-Utah Occupational Safety and Health; precautionary measures; emergency and first-aid procedures; and the identification (name, address, and telephone number) of the organization responsible for preparing the MSDS sheet. Copies of the MSDS for hazardous chemicals in a given work site are to be readily accessible to employees in that area. (4) Labeling Chemicals Chemical manufacturers and importers must convey the hazard information they learn from their evaluations to downstream employers by means of labels on containers and material safety data sheets (MSDSs). In the workplace, each container must be properly labeled, tagged, or marked with the identity of hazardous chemicals contained therein, and must show hazard warnings appropriate for employee protection. The hazard warning can be any type of message, words, pictures, or symbols that provide at least general information regarding the hazards of the chemical(s) in the container and the targeted organs affected, if applicable. Labels must be legible, in English and prominently displayed. (5) Categories of Hazardous Waste Generators There are three categories of hazardous waste generators: ► Identify all hazardous waste you generate. 2. Generators of 220 to 2,200 pounds or 25 to under 300 gallons of hazardous waste, and no more than 2.2 pounds of acutely hazardous waste in any month. The federal hazardous waste laws require you to: ► Comply with the 1986 rules for managing hazardous waste, including accumulation, treatment, storage, and disposal requirements. This includes: • Complying with rules pertaining to managing hazardous waste on-site (storage times, quantities, handling requirements and obtaining proper permits, taking adequate precautions to prevent accidents, and being prepared to handle accidents appropriately); 3. Generators of more than 2,200 pounds or 300 gallons or more than 2.2 pounds of acutely hazardous waste in any month. The federal hazardous waste laws require you to comply with all applicable hazardous waste management laws and rules of the Resource Conservation and Recovery Act as amended in November 1984 as well as final regulations effective September 1986. To determine which category of hazardous waste generator your school district falls into—and what requirements you must meet—you must measure or "count" the hazardous wastes your school district or charter school generates in a calendar month. The total weight will determine your generator category. The table below summarizes the kinds of wastes you must count and wastes you do not count when you determine your generator status. Counting Your Hazardous Waste You do count all quantities of "listed" or "characteristic" hazardous wastes that you: ► Accumulate on-site for any period of time prior to subsequent management. ► Generate as still bottoms or sluggers and remove from product storage tanks. You do not have to count wastes that: • Spent lead-acid batteries that will be sent off-site for reclamation. (6) Typical Waste Materials in School Districts and Charter Schools School districts and charter schools typically generate hazardous wastes from applied technology shops, science laboratories and facility and vehicle cleaning and maintenance activities. These areas may generate the following types of hazardous wastes: Acids/Bases Heavy Metals/Inorganics Heavy metals and other inorganic waste materials exhibit the characteristics of EP (extraction procedure) Toxicity and are considered hazardous if the extract from a representative sample of the waste has any of the specific constituent concentrations as shown in 40 CFR 261.24, Table 1. This may include dusts, solutions, wastewater treatment sluggers, paint wastes, waste inks, and other such materials which contain heavy metals/inorganics. The following are some of the more commonly used heavy metals/inorganics found in school districts and charter schools: Arsenic Ignitable wastes include any liquids that have a flash point less than 140 degrees Fahrenheit, any non-liquids that are capable of causing a fire through friction, absorption of moisture, or spontaneous chemical change, or any ignitable compressed gas as described in 49 CFR 173.300 (for a complete description of ignitable wastes, see 40 CFR 261.21, Characteristics of Ignitability). Examples are spent solvents, solvent still bottoms, ignitable paint wastes (paint removers, brush cleaners and stripping agents), epoxy resins and adhesives (epoxies, rubber cements and marine glues), and waste inks containing flammable solvents. The following are some of the more commonly used ignitable wastes found in school districts and charter schools: Acetone Pesticides The pesticides listed below are hazardous. Wastes marked with an asterisk (*) have been designated acutely hazardous. For a more complete listing, see 40 CFR 261.32 and 261.33 for specific listed pesticides, and other wastes, waste waters, sluggers, and by-products from pesticide formulators. The following are some of the more commonly used pesticides found in school districts: *Arsenic Pentoxide Acetic Acid *Endrin Reactives Reactive wastes include reactive materials or mixtures which are unstable, react violently with or form explosive mixtures with water, generate toxic gases or vapors when mixed with water (or when exposed to pH conditions between 2 and 12.5 in the case of cyanide or sulfide bearing wastes), or are capable of detonation or explosive reaction when heated or subjected to shock (for a complete description of reactive wastes, see 40 CFR 261.23, Characteristics of Reactivity). The following are some of the more commonly used reactives found in school districts: Acetyl Chloride Solvents Solvents, spent solvents, solvent mixtures, or solvent still bottoms are often hazardous. This includes solvents used in degreasing and paint brush cleaning and distillation residues from reclamation. See also 40 CFR 261.31 for most listed hazardous waste solvents. The following are some of the more commonly used solvents found in school districts: Benzene
Used lead-acid batteries should be reported on the notification form only if they are not recycled. Used lead-acid batteries that are recycled do not need to be counted in determining the quantity of waste you generate per month, nor do they require a hazardous waste manifest when shipped off your premises. The following are some of the more commonly used lead-battery products found in school districts: Lead Dross (7) Managing Hazardous Waste On-Site The three most important things you should know about managing your hazardous wastes on-site are: (a) Storing Hazardous Waste On-Site You may store no more than 13,200 pounds of hazardous waste on your site for up to 180 days or for up to 270 days if the waste must be shipped to a treatment, storage, or disposal facility that is located over 200 miles away. If you exceed these time or quantity limits, you will be considered a storage facility and you must obtain a storage permit and meet all of the Resource Conservation and Recovery Act (RCRA) storage requirements. You are allowed to store your waste for as long as 180 or 270 days so that you will have time to accumulate enough hazardous waste to ship it off-site for treatment or disposal economically. You can store hazardous waste in 55-gallon drums, tanks, or other containers suitable for the type of waste generated if you follow certain common sense rules that are meant to protect human health and the environment, and reduce the likelihood of damages or injuries caused by leaks or spills of hazardous wastes. If you store your hazardous waste in containers, you must: Clearly mark each container with the words: If you store your waste in tanks, you must follow similar common sense rules: Do not store hazardous waste in a tank if it may cause rupture, leaks, corrosion, or otherwise cause the tank to fail. If your tanks have equipment that allow the waste to flow into them continuously, provide waste feed cutoff or bypass systems to stop the flow in case of problems. Inspect any monitoring or gauging systems on each operating day and inspect the tanks themselves for leaks or corrosion every week. Use the National Fire Protection Association's (NFPA) buffer zone requirements for tanks containing ignitable or reactive wastes. These requirements specify distances considered as safe buffer zones for various liquids based on the characteristics of all combustible and flammable liquids. (b) Preparing for and Preventing Accidents Whenever you generate hazardous waste and store it on-site, you must take the precautions and steps necessary to prevent any sudden or accidental release to the environment. This means that you must carefully operate and maintain your facility to reduce the possibility of fire, explosion, or release of hazardous waste. Your district or charter school facilities must have appropriate types of emergency communication and fire equipment for the kinds of waste handled. You must also attempt to make arrangements with local fire, police, or hospital officials as needed to ensure that they will be able to respond to any potential emergencies that could arise. Some of the steps you may need to take to prepare for emergencies at school district sites may include: Installing and maintaining emergency equipment such as an alarm, a telephone or a two-way radio, fire extinguishers (using water, foam, inert gas, or dry chemicals as appropriate to your waste type). Provide enough room for emergency equipment and response teams to get into any area in your district in the event of an emergency. Emergency phone numbers and locations of emergency equipment must be posted near telephones. Employees must know proper waste handling and emergency procedures. You must appoint an employee to act as an emergency coordinator to ensure that emergency procedures are carried out in the event of an emergency. (c) "Good Housekeeping" and a Safe Environment Good hazardous waste management can be thought of as simply using "good housekeeping" practices such as: using and reusing materials as much as possible; recycling or reclaiming waste; treating waste to reduce its hazards; or reducing the amount of waste you generate. The three most important things you should remember about managing your wastes properly are:
Do not mix nonhazardous wastes with hazardous ones.
Do you have some documentation on the amounts and kinds of hazardous waste you generate and on how you determined that they are hazardous?
(8) When You Need Help If you need help: Call your local fire department, the State Fire Marshal's office: Utah State Fire Marshal State Division of Air Quality: Utah Department of Environmental Quality The Utah state hazardous waste management agency: Utah Department of Environmental Quality U.S. EPA Denver Region office: EPA Region VIII c. Legal Liability in Building Maintenance and Operations All staff who are in any way involved in the operations and maintenance of educational facilities need to be aware that accidents and other mishaps that occur in school buildings, facilities, or on school grounds may result in lawsuits against the school district or charter school. As part of these lawsuits employees may be named as parties to the lawsuits or, at a minimum, they will be involved as witnesses in the lawsuit process. In most of these actions plaintiff's attorney will try to prove that the school district or charter school and it employees were negligent; and through this negligence the client was injured. Throughout this manual you have been told about issues, or problems that affect the operation of schools that can be identified through a self inspection. The concept behind a self inspection is one of identifying potential problems and dealing with them before they injure someone, or create a situation that leads to prolonged litigation. It is important for those involved in the process of self inspection and the maintenance of school property and buildings to understand how the law works in situations involving physical problems with educational facilities and grounds. School districts and charter schools have a basic responsibility to provide a safe location for students and others who visit or otherwise utilize the facilities. If someone is injured while using the facility, and it is determined that their injury is related to or caused by a problem of which school district or charter school personnel were aware or should have been aware of but failed to correct, liability may be imputed to the school district or charter school. "Translated into English" this means if staff are aware of a problem like a trip and fall hazard—such as a piece of pipe sticking up on the playground, or broken glass under a swing set, or a pool of water on a slick floor—and do nothing to correct the problem, the school may be held liable if someone is injured. The courts have established a "knew or reasonably should have known" standard for determining liability. If school personnel knew about the problem, or reasonably should have known, and did nothing to correct the problem then the school district or charter school may be successfully sued. School districts and charter schools will not be held liable for everything that possibly could occur, but they may be held liable for those things that were known and could have been corrected but were not. Facilities staffs have a special duty to find and address these problems before they become legal liabilities for the school and the school district. Self inspection tools provide a handy way of finding problems before they become liabilities. Many of the self inspection documents in use today are designed to point out specific problems that have been identified as potential liabilities. Many of the issues or subjects addressed in the self inspections have been the subject of lawsuits in the past. In addition, many of the issues addressed in the documents are areas or subjects addressed by various federal laws or rules. Occupational Safety and Health Administration (OSHA) requirements, hazardous waste management, and other safety guidelines and rules established by federal and state agencies are also addressed in self inspection documents. When one of these rules is violated and someone is injured, the fact that the agency was in violation of the rules or standard will be used in court to prove guilt. The self inspection process allows schools to find or anticipate problems before they become liability issues. If properly used, self inspection documents provide a list of problems that can be prioritized and then addressed in a logical order. By using the self inspection process school districts and charter schools are able to show that they are interested in providing a safe location for their patrons. Once the inspections are done however, the school district or charter school must act to address the problems. This must be done in a timely and proper manner. Doing self inspections and then addressing the identified problems is one of the ways schools can avoid legal liability. For more information, contact State Risk Management at (801) 538-9560. d. Graffiti Removal and Prevention Graffiti on school facilities lessens the educational climate and attracts more graffiti and vandalism. Graffiti should be removed completely and as soon as possible when it occurs. Removing graffiti quickly and completely sends a message to the individuals who created the "art work" or "tag" on the buildings, signs, asphalt/concrete surfaces, or whatever object at the facility that this school will not tolerate such behavior and will take swift action to remove it completely. The converse is also true; if graffiti is not removed quickly and completely, it attracts additional graffiti—much like one or two broken windows in a building invites more windows to be broken and more vandalism. Inaction sends the message "we don't care about this facility." School personnel should also take photographs of all graffiti "tags" and share the photos with district security personnel as well as local police. This may help in locating the perpetrators or to document a pattern that could lead law enforcement personnel to those who committed the crime. A combination of physical scrubbing, pressure and power washing with chemical solvents can usually remove most graffiti. Specialized graffiti cleaning solvents and washers are available from commercial suppliers. Care must be taken to protect maintenance employees when using chemical and mechanical cleaning methods. Personal protection equipment is required. Follow the instructions provided by the manufacturer of the solvent and washer. Chemicals that are organic or biodegradable are preferred. e. Radon Gas Radon is a natural radioactive gas formed by the decay of uranium in the earth's soil. It is tasteless, odorless and invisible. Eventually it works its way to the surface through cracks in the earth's surface and through porous soil. Diluted into the outdoor atmosphere, radon gas poses little danger because of the high ratio of air to radon. (1) Health Risks of Radon Radon seeps through gaps in the foundation or insulation and is trapped in the confined areas of a building. Long term exposure to radon under these conditions has been associated with an increased risk of lung cancer. The U.S. Environmental Protection Agency (EPA) estimates that radon is responsible for up to 15,000 deaths annually. (2) Radon Detection Because radon gas is odorless, tasteless and invisible, nonscientific equipment is needed for detection. There are two basic detectors for measurements: A charcoal device and, A charcoal device can be placed in a section of a school building for three to four days. It is then returned to the manufacturer for analysis. An alpha-track detector is placed in the building from two weeks to three months (or longer), before being returned to a laboratory for examination. Long-term testing averages the exposure to radon gas levels over a period of time. This gives a more conclusive test result. There are other techniques requiring operation by trained personnel which can be used to measure radon levels. Call State Risk Management at (801) 538-9578 for assistance. (3) Reducing High Levels of Radon Corrective actions can often be quick and inexpensive. In some cases, the following steps will help to lower dangerous levels of radon gas or prevent it from entering school facilities: Ventilate the school buildings. Contact State Risk Management at (801) 538-9578 for more detailed information on radon and radon abatement procedures. f. Asbestos Removal/Containment The word "asbestos" is derived from the Greek language. The Greeks admired the "miracle mineral" because of its softness and flexibility and its ability to withstand heat. The Greeks used asbestos much like cotton, spinning and weaving it into cloth. Asbestos was not widely available anywhere in the world until the late 1800's, when major deposits were found in Canada. Thereafter, asbestos was used to make thermal insulation for boilers, pipes, and other high-temperature applications, and was also used as a fireproofing and reinforcement material. During World Wars I and II, the military used asbestos extensively in ships and other applications. Commercial usages of asbestos in buildings increased thereafter, but growing concerns about the health risks associated with asbestos exposure resulted in a voluntary reduction in the use of asbestos beginning in the 1970's. (1) Characteristics of Asbestos Asbestos is comprised of a group of natural minerals. Unlike other minerals, however, the crystals of asbestos form long, thin fibers. Asbestos deposits are found throughout the world, but the primary sites of commercial asbestos production are Canada, Russia, and South Africa. Commercial mining of asbestos in the United States was halted in the 1980's. Once extracted from the earth, asbestos-containing rock is crushed, and grated. This produces long, thread-like fibers of material. What appears to the naked eye as a single fiber is actually a bundle of hundreds or thousands of fibers, each of which can be divided even further into tiny fibers (fibrils), invisible without the aid of a microscope. The amphibole group contains five types of asbestos. Amorite, the second most common type of asbestos found in buildings in the United States, is often referred to as "brown asbestos" for the color of the natural mineral. Crocidolite, or "blue asbestos" has been used in high-temperature insulation products and on chemical resistant surfaces, such as laboratory tables for chemistry and biology classes (upon occasion, the custodial staff will drill holes in table tops for new fixtures without realizing that the material may contain crocidolite. The remaining three types of asbestos in the amphibole group are Anthophyllite, Tremolite, and Actinolite—and are rare and have little commercial value. They are occasionally found as contaminants or minor constituents in asbestos-containing materials. (2) Uses of Asbestos Asbestos has been used in thousands of products, largely because it is plentiful, readily available, cheap, and strong, does not burn, conducts heat and electricity poorly, and is resistant to chemical corrosion. Products made with asbestos are often referred to as Asbestos-Containing Materials (ACM). Asbestos has proved particularly useful in the construction industry. Building materials that contain asbestos are referred to as Asbestos-Containing Building materials (ACBM). Commercial usage of asbestos products in the construction industry was most common from about 1945 to 1980. Some of the most common uses of ACBM include: Fire proofing material—usually spray-applied to steel beams used in construction of multi-story buildings to prevent structural members from warping or collapsing in the event of fire. Insulation material—usually spray-applied, trowel-applied, or manually installed after being preformed to fit surfaces such as pipes for thermal insulation and condensation control. Acoustical or Soundproofing material—trowel- or spray-applied. This asbestos may also be used for decoration. Asbestos was mixed with other materials and sprayed onto ceilings and walls to produce a soft, textured look. Miscellaneous materials—asbestos has been added to asphalt, vinyl, cement and other materials to make products like roofing felts, exterior siding and roofing shingles, wallboard, pipes for water supply, combustion vents, and flues for waste gases and heat. Fibers in asbestos cement, asphalt, and vinyl materials are usually firmly bound into materials in good condition and typically will be released only if the material is damaged mechanically—for example through drilling, cutting, grinding, or sanding. In addition, asbestos in roofing shingles and siding exposed to weathering may slowly deteriorate and has the potential to release fibers. Examples of the more common ACBM found in schools are flooring, vinyl base, mastic, roofing materials, gaskets in heating and air-conditioning equipment, ceiling panels and tiles, wallboard, joint compound, plaster, pipe and boiler insulation, duct-wrap insulation, duct joint tape, duct vibration dampening cloth, fireproofing on structural members, fire brick for boilers, fire doors, acoustical spray-on, cement pipes, and panels. (3) Friable vs. Non-Friable ACBM Friable ACBM will release fibers into the air more readily than non-friable ACBM. Therefore, the Asbestos Hazardous Emergency Response Act (AHERA) Rule differentiates between friable and non-friable ACBM. The regulations define friable ACBM as material that may be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friable ACBM also includes previously non-friable material when it becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure. Undamaged non-friable ACBM should be treated as friable if any action performed on the material will make it friable. (4) Categories of Asbestos-Containing Building Materials EPA identifies three categories of ACBM:
(5) Summary Key Points about Asbestos These are some important terms used in the AHERA Rule. The designated AHERA person at each school district or charter school should be especially familiar with the following: Asbestos-Containing Material (ACM) — any material or product that contains more than one percent asbestos. Asbestos-Containing Building Material (ACBM)—Surfacing ACM, thermal system insulation ACM, or miscellaneous ACM that is found in or on interior structural members or other parts of a school building. Friable ACBM—Material that may be crumbled, pulverized, or reduced to powder by hand pressure when dry. Friable ACBM also includes previously non-friable material when it becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure. Non-friable ACBM—Material that, when dry, may not be crumbled, pulverized, or reduced to powder by hand pressure. Surfacing ACM—Interior ACM that has been sprayed on, troweled on, or otherwise applied to surfaces (structural members, walls, ceilings, etc.) for acoustical, decorative, fireproofing, or other purposes. Thermal System ACM—Insulation used to control heat transfer or prevent condensation on pipes and pipe fittings, boilers, breeching, tanks, ducts, and other parts of hot and cold water systems; heating, ventilation, and air-conditioning (HVAC) systems; or other mechanical systems. Miscellaneous ACM—Other, mostly non-friable, products and materials (found on structural components, structural members or fixtures) such as floor tile, ceiling tile, construction mastic for floor and ceiling materials, sheet flooring, fire doors, asbestos cement pipe and board, wallboard, acoustical wall tile, and vibration damping cloth. Undamaged non-friable ACBM should be treated as friable if any action performed would render these materials friable. When previously non-friable ACBM becomes damaged to the extent that when dry it may be crumbled, pulverized, or reduced to powder by hand pressure, it should be treated as friable. (6) Asbestos Health Risks The health effects associated with asbestos exposure have been studied for many years. Results of these studies show that inhalation (breathing in) of asbestos fibers leads to increased risk of developing several diseases. Exactly why some people develop these diseases remains a mystery, but it has been well demonstrated that most asbestos-related illnesses are dose-response related—that is, the greater the exposure to airborne asbestos fibers, the greater the risk of developing an illness. (a) Relative Hazards of Asbestos Exposure Almost daily, we are exposed to some prevailing level of asbestos fibers in buildings or experience some existing level in the outdoor air. Some fibers that are inhaled remain in the lungs. Brief "bursts" of exposure, when added to the background level, increase the potential to cause or trigger the development of an asbestos-related disease. These brief bursts of exposure occur in many ways. For example, when a carpenter drills a hole in an asbestos fire door without taking any precautions, an increased amount of asbestos may be released into the air. The more often these bursts of exposure occur, the greater the risk of breathing asbestos fibers. People most at-risk for this additional exposure are maintenance and construction workers who work on and disturb asbestos in buildings. This clearly demonstrates the need for an active asbestos policy and an ongoing operations and plan for buildings that contain ACBM. It is important to recognize that the majority of people who have developed diseases because of asbestos exposures are former asbestos workers. These workers were frequently exposed to high levels of asbestos fibers each working day, with little or no protection. Today's asbestos maintenance workers and AHERA-trained asbestos abatement workers are trained to follow specific work practices and wear appropriate protection, including respirators, to minimize the risk of exposure. However, increased risk may occur when a worker who does not use a respirator or follow specific work practices disturbs any ACBM. (b) The Respiratory System The effects of asbestos exposure most often involve the lungs. Air breathed into the body passes through the mouth and nose, continuing into the windpipe. The windpipe divides into smaller and smaller tubes that end up in the lungs as air sacs called alveoli. It is in these air sacs that respiration occurs. Oxygen is absorbed into tiny blood vessels (or capillaries), and waste gases—such as carbon dioxide—pass out of the blood and are exhaled. The body has several mechanisms to "filter" the air it breathes. First, large particles are removed in the nose and mouth. Many smaller particles are caught on the mucus-coated walls of the airway tubes. These airways have "hairy" linings (ciliate cells) that constantly propel mucus upward. Particles caught in the mucus are swept up into the back of the mouth. From here they are swallowed or expelled (spit out). Unfortunately, cigarette smoking temporarily paralyzes these hair-like cells, disabling one of the body's natural defenses against unwanted dust or fibers. Despite natural bodily defenses, some dust particles inevitably reach the tiny air sacs in the lungs. When this occurs the human immune system dispatches large cells called macrophages to engulf the particles and "digest" them. These cells deposit a coating on the particles and may begin forming scar tissue around them. This is just another natural defense mechanism the body uses against unwanted debris in the lungs. (7) Asbestos-Related Diseases If the body's defenses fail to control or remove asbestos fibers that enter the lungs, the risk of developing an asbestos-related disease increases. Asbestos-related diseases include asbestosis, lung cancer, mesothelioma, and other cancers. (a) Asbestosis Asbestosis is a disease characterized by lung scarring. It reduces lung elasticity— the ability to inhale and exhale in response to muscular contractions of the diaphragm— and makes breathing very difficult. Asbestosis is most common among workers who have been exposed to large amounts of asbestos fibers over a long period of time. It is a serious disease and, in those persons exposed to high levels of asbestos, can eventually lead to disability or death. All forms of asbestos are suspected to have the potential to cause asbestosis. Like all diseases associated with asbestos exposure, it may take many years for the disease to show up. The typical latency period for asbestosis is 15 to 30 years. Available data indicate that the frequency of occurrence of asbestosis rises and the disease worsens with increasing dust exposure. The Occupational Safety and Health Administration (OSHA) Asbestos Standards were developed to minimize the incidence of asbestosis among asbestos workers by reducing their exposure to asbestos. (b) Lung Cancer As with asbestosis, there appears to be a dose-response relationship between asbestos exposure and lung cancer. In addition, lung cancer arising from asbestos exposure also has a latency period before development—typically 30 years or longer. The risk of contracting lung cancer as a result of exposure to asbestos increases if the worker is a cigarette smoker. Cigarette smokers who are exposed to asbestos are over 50 times more likely to develop lung cancer than the normal, non-smoking population. As a result, a program to help workers stop smoking and an asbestos operations and maintenance program will help reduce the risk of lung cancer among asbestos workers. (c) Esthetical Esthetical is a cancer that occurs in the chest cavity lining or in the abdominal (stomach) lining. This type of cancer spreads rapidly and is always fatal. Cases of esthetical have been found in people who have had a limited exposure to asbestos. The onset of this disease appears to be independent of smoking behavior but related to dose and to time from first known asbestos exposure. Mesothelioma tends to have a long latency period—usually 30 to 40 years. (d) Other Diseases Several other diseases seem to occur more frequently among people who have been exposed to asbestos. These include cancer of the esophagus, stomach, colon, and pancreas; pleural (fibrous) plaques; pleural thickening; and pleural effusion. The risks of contracting any of these diseases make it extremely important that asbestos maintenance workers utilize proper work practices and respiratory protection. (8) EPA Policy for Asbestos Control in Schools EPA bases its policy for asbestos control in schools on the following premises: Based upon available data, the average airborne asbestos levels in buildings seem to be very low. Accordingly, the health risk to most building occupants also appears to be very low. Removal is often not a building owner's best course of action to reduce asbestos exposure. In fact, an improper removal can create a dangerous situation where none previously existed. EPA only requires asbestos removal to prevent significant public exposure to airborne asbestos fibers during building demolition or renovation activities. Asbestos that has been identified will pose little risk if it is well maintained under an operations and maintenance program. Improper operations and maintenance also can cause dangerous situations. Therefore, EPA requires a pro-active, in-place management program whenever ACBM is discovered and is not removed. (9) Local Education Agency (School District and Charter School) Responsibilities The school district and charter school must have an accredited inspector conduct inspections of each school building under its authority. The State Department of Environmental Quality, Division of Air Quality—(801) 536-4000; 150 North 1950 West, Salt Lake City, Utah 84116—provides this service. A reinspection of all friable and non-friable known or assumed ACBM in each school building must be conducted at least once every three years that a management plan is in effect. A management planner must review all three-year inspection reports. For each inspection and re-inspection, an accredited inspector must provide a written assessment of all friable known or assumed ACBM in the school building. The school district must have an accredited management planner review the results of the inspection/re-inspection and the assessment and make written recommendations on appropriate response actions. The accredited management planner also prepares the asbestos management plan for each school under its authority. The school district must select the appropriate response actions consistent with the assessment of the ACBM and the recommendations of the management planner. The school district must implement an Operations and Maintenance (O&M) program whenever any friable ACBM is present or assumed to be present in a building under its authority. Here is a link to the EPA publication How to Manage Asbestos in School Buildings Building inspectors, management planners, project designers, contractors/ supervisors, and asbestos workers must complete EPA or state-approved courses and receive accreditation before they can perform any asbestos- related activities. The AHERA Rule also specifies training requirements for school district and charter school designated persons and custodial and maintenance workers, although these individuals are not required to complete any EPA-approved courses or receive accreditation. The school district or charter school must conduct periodic surveillance in each building under its authority at least once every six months after a management plan is in effect. The school district or charter school must comply with the requirements to provide notification about asbestos activities to workers, students, parents, teachers and short-term workers. The school district and charter school must maintain records in accordance with the AHERA regulations. The school district and charter school must attach a warning label immediately adjacent to any friable and non-friable ACBM and assumed ACBM located in routine maintenance areas (such as boiler rooms) at each school building. The AHERA Designated Person must provide a statement that the Local Education Agency has met (or will meet) the responsibilities listed below. All references are to specific provisions to the AHERA regulations (under § 763.94). The AHERA Designated Person should be able to answer a "yes" to each statement below: The activities of any persons who perform 'inspections, re-inspections, and periodic surveillance, develop and update management plans, and develop and implement response actions, including operations mid maintenance, are carried out in accordance with 40 CFR Part 763, Subpart E. All custodial and maintenance employees are properly trained as required in 40 CFR Part 763, Subpart E and all other applicable federal and/or state regulations of the Occupational Safety and Health Administration Asbestos Standard for Construction, the EPA Worker Protection Rule, and applicable state regulations. All workers and building occupants, or their legal guardians, are informed at least once each school year about inspections, response actions, post-response action activities, including periodic re-inspections and surveillance activities, that are planned or in progress. All short-term workers (i.e., telephone repair workers, utility workers, etc.) who may come in contact with asbestos in schools are provided information regarding the locations of ACBM and assumed ACBM. All warning labels are posted in accordance with § 763.95. All management plans are available for inspection, and notification of this availability has been provided in accordance with § 763.93(g). The person designated by the school district according to § 763.84(g) (1) has received adequate training as required by § 763.84(g) (2). The school district and charter school has and will consider whether any conflict of interest may arise from the inter-relationship between the accredited person and whether this potential conflict might not influence the selection of certified personnel to perform activities under 40 CFR parts 763, Subpart E (10) AHERA Inspections Summary Key Points about AHERA Inspections: An AHERA inspection must be conducted by an accredited inspector. The inspector must identify all homogeneous areas of material that are suspected of containing asbestos. Homogeneous areas contain asbestos that is uniform (alike) in color and texture. All material suspected of being ACBM must be assumed to be ACBM unless the homogeneous area is sampled, and the analysis of the samples shows them to be non-asbestos. Adequate number of samples must be taken or the area will be considered to be ACBM regardless of the results of the analysis. Once the inspector has identified all ACBM in a building, he or she must perform a physical assessment of all non-friable and friable ACBM. This involves categorizing the material into one of seven Physical Assessment Classifications. The results of an AHERA inspection and the assessment must be documented in an inspection report. This report will be used by the management planner to make written recommendations on appropriate response actions. (11) The Management Plan The management plan is a site-specific guidance document that the school district or charter school Designated Person must follow in managing the ACBM present in a school building. The management plan must be prepared by an accredited management planner and must be updated in a timely manner. The management plan must also include the documentation required under § 763.87 of the AHERA Rule for each laboratory performing a bulk sample analysis and the results of each analysis. In the management plan, the management planner must recommend an appropriate response action (operations and maintenance, repair, encapsulation, enclosure, or removal) for all areas of friable ACBM (including ACBM which has the potential of becoming friable). All of the initial response actions implemented to control friable asbestos require a project design specifying how to conduct the abatement project. Final air clearance of a functional space after a response action to remove, encapsulates, or encloses ACBM involves a visual inspection and the collection and analysis of air samples. Final air sampling must be done using the Transmission Electron Microscopy (TEM) method, unless the project involves no more than 160 square feet or 260 linear feet, in which case phase contrast microscopy (PCM) may be used. The school district or charter school Designated Person is responsible for ensuring that the activities related to the management plan are implemented and that the management plan is updated in a timely manner. (12) Re-inspections and Periodic Surveillance As long as any ACBM remains in a school building, the building must be re-inspected at least once every three years. The re-inspection and assessments/reassessments must be conducted by an accredited inspector. The results of the inspection must be submitted to the Designated Person within 30 days to include into the management plan. The management planner must: ► Review the results of the re-inspection; At least once every six months after a management plan is in effect, the school district and charter school must conduct periodic surveillance in each building that contains ACBM or is assumed to contain ACBM. (13) The Operations and Maintenance Program An Operations and Maintenance (O&M) program must be implemented whenever any friable ACBM is present or assumed to be present in a school building or whenever any non-friable ACBM or assumed non-friable ACBM is about to become friable as a result of activities performed in the school building. Unless the building has been cleaned using methods described at § 763.91(c) of the AHERA Rule within the previous six months, all areas of a building where friable ACBM, friable suspected ACBM, assumed to be ACBM, or significantly damaged ACBM is present must be cleaned at least once after the completion of the AHERA inspection and before the initiation of any response action, other than O&M activities or repair. Specialized work practices and procedures must be followed for any O&M activities disturbing friable ACBM. When a fiber release episode occurs, the work practices that must be followed depend on whether the episode is minor or major in nature. A minor fiber release episode consists of the falling or dislodging of three square or linear feet or less of friable ACBM. A major fiber release episode consists of the falling or dislodging of more than three square or linear feet of friable ACBM. Once ACBM is identified or assumed to be present, the school district or charter school should start a notification and warning program to alert affected parties to a potential hazard in the building and to provide basic information on how to avoid the hazard. The school district or charter school is required to attach a warning label immediately adjacent to any friable and non-friable ACBM and suspected ACBM that is assumed to be ACBM that is located in routine maintenance areas. Where employees work in areas where fiber levels exceed permissible exposure limits or are required to wear pressure respirators, the school district or charter school must establish a medical surveillance and respiratory protection program. A school district or charter school Designated Person can minimize accidental disturbances of ACBM during maintenance and renovation activities by establishing a permit system that calls for all work orders and requests to be processed through the designated person. The specific work practices that must be followed when routine maintenance activities are being conducted depend on the likelihood that the activities will disturb the ACBM and cause fibers to be released. (14) Handling and Disposing of Asbestos Waste The amount and type of asbestos present both determine whether a school district or charter school must notify the State Division of Air Quality and what procedures that the school district or charter must follow to control asbestos emissions. If the amount exceeds the regulatory threshold, then a written notification must be submitted ten working days prior to any asbestos stripping or removal operation or demolition operation. EPA regulations (along with state and local requirements) provide detailed instructions on the handling, transport, and disposal of asbestos materials. This includes emission control methods (such as wetting and leak proof wrapping), labels on the containers, record keeping and a trained representative on-site. Waste must be disposed of at a site meeting federal, state and local requirements. For a site in your area, contact the local public health department. (15) Training and Accreditation AHERA requires that LEA's employ accredited persons to perform most of the activities associated with asbestos management. Building inspectors, management planners, project designers, contractors/supervisors, and asbestos workers must all complete EPA or state-approved courses that result in accreditation. The AHERA Rule also details specific training requirements for school district and charter school Designated Persons and maintenance and custodial workers, although these individuals are not required to complete any EPA-approved courses or receive accreditation. (a) Designated Person Training AHERA requires that the AHERA Designated Person be adequately trained to carry out his or her responsibilities. Due to the differing needs of school districts and charter schools based on the size of the district and the amount and condition of the ACBM, AHERA does not list a specific training course or specific number of hours of training for the Designated Person. Further, AHERA does not require the Designated Person to be accredited. Specifically, the regulations note the training must include the following topics: Health effects of asbestos; The training completed by the school district or charter school Designated Person must be documented by course name, dates, and hours of training. This must be kept as a permanent part of the management plan. (b) Training for Maintenance and Custodial Workers The school district or charter school must ensure that all maintenance and custodial staff who work in a building that contains ACBM receive a minimum of two hours awareness training, whether or not they are required to work with ACBM. New custodial and maintenance employees must be trained within 60 days after the commencement of employment. The awareness training must include, but is not limited to: Information regarding asbestos and its various uses and forms; Staff that could disturb ACBM must receive an additional 14 hours of training. Once this additional training is completed, attendees will be adequately trained to conduct small scale, short-duration activities and/or minor fiber release episode cleanup and repair procedures. The additional training must include, but is not limited to: Descriptions of the proper methods for handling ACBM; (16) Accredited Personnel Under AHERA, LEA's may employ the following individuals only if they have completed EPA- or State-approved training courses, passed the exams, and received accreditation. Building Inspectors—Building inspectors must complete a minimum of three days (24 hours) of training. Training course information covers technical information needed to identify and describe ACBM and information needed to write an inspection report. Management Planners—Management planners must complete a two-day (16 hours) course after they have completed and passed the exam for the building inspector training described above. This course is an extension of the building inspector training and teaches how to develop a schedule (or plan) for implementation of response actions for hazards or potential hazards identified in the inspection report, how to develop an O&M-plan, and how to prepare and update a management plan. Project Designers—Project designers must complete a three-day (24 hours) abatement project designer training course. The project designer course teaches how to design response actions and abatement projects. It also covers basic concepts of architectural design, engineering controls and proper work practices as required by the regulation. Contractors/Supervisors—Contractors/supervisors must complete a minimum of five days (40 hours) of training. The course teaches proper work practices and procedures and covers contractor issues such as legal liability, contract specifications, insurance and bonding, and air monitoring. The course fulfills the OSHA "competent person" training requirement and the National Emission Standards for Hazardous Air Pollutants (NESHAP) "trained representative" requirement. Asbestos Workers—An asbestos worker must complete a minimum of four days (32 hours) of training. The course covers work practices and procedures, personal protective equipment, health effects of asbestos exposure, and other information critical to individuals who work in an abatement area with hazardous materials. Update Training is required for all levels of accredited personnel on a yearly basis. (17) Record Keeping Each school district and charter school must maintain a copy of its management plan in its administrative office, and the plan must be available to persons for inspection without cost or restriction. Each school must maintain a copy of the management plan for that school in its administrative office, and the plan must be available to persons for inspection without cost or restriction. The school district and charter school must also maintain records of events that occur after submission of the management plan. These records include training information, periodic surveillance information, cleaning information, small-scale, short duration 0 & M activity information, information on 0 & M activities other than small-scale, short-duration, information on fiber release episodes, information on response actions and preventive measures, and air sampling information. These records should be included in the management plans in a timely manner. For each homogeneous area where all ACBM has been removed, the school district and charter school must retain the records of events for three years after the next reinspection, or for an equivalent period. It is the responsibility of the school district and charter school Designated Person to ensure that complete and up-to-date records are maintained and included in the management plans. (18) Related Regulations Although AHERA and its implementing regulations, the AHERA Rule, set out many of the responsibilities of the school district, there are several other federal regulations that the school district and charter school should be aware of when implementing an asbestos management program. These regulations include: National Emission Standards for Hazardous Air Pollutants (NESHAP) Department of Transportation (DOT) regulations governing the transport and disposal of asbestos-containing materials (49 CFR Parts 171 and 172) g. The Americans with Disabilities Act (ADA) As a government entity providing programs and services to the public, school programs and services must be accessible to persons with disabilities. A transition plan indicating which facilities need to be upgraded and the construction schedule for such work was developed by each school district in 1991. In general, all new construction and altered facilities must be fully accessible to persons with disabilities. In addition, all paths of travel must be accessible to persons with disabilities. Both the International Building Code (IBC) and the American National Standards Institute - ANSI (ANSI) have accessibility standards that School District Building Officials (SDBOs) and Charter School Building Administrators must comply with. Quoting the purpose section from the American National Standard: The specifications in this standard make buildings and facilities accessible to and usable by people with such physical disabilities as the inability to walk, difficulty walking, reliance on walking aids, blindness and visual impairment, deafness and hearing impairment, incoordination, reaching and manipulation disabilities, lack of stamina, difficulty interpreting and reacting to sensory information, and extremes of physical size based generally upon adult dimensions. Accessibility and usability allow a person with a physical disability to independently get to, enter and use a building or facility. This standard provides specifications for elements that are used in making functional spaces accessible. For example, it specifies technical requirements for making doors, routes, seating, and other elements accessible. These accessible elements are used to design accessible functional spaces such as classrooms, hotel rooms, lobbies, or offices. School districts (and charter schools) must follow all local, state, and federal accessibility codes and guidelines. Under the Americans with Disabilities Act, the most stringent (accessible) code applies. In cases of conflict, federal ADA accessibility standards prevail over conflicting local or state law, administrative rules or regulations. All new or altered facilities must be accessible to and useable by individuals with disabilities. Shown below are ADA accessibility requirements for existing facilities and new construction or alteration/remodel projects: ADA Accessibility Requirements Title II Programs must be readily accessible when viewed in their entirety—unless to do so would cause a fundamental alteration in the nature of the program, undue financial or administrative burden (these "legal defenses" for not doing so must be fully documented and have legal review). Facilities must be fully accessible under Americans with Disabilities Act Accessibility Guidelines (ADAAG) or Uniform Federal Accessibility Standards (UFAS)—if construction commenced after January 26, 1992. NOTE: ADAAG should be used wherever possible. The Department of Justice plans to roll UFAS into ADAAG in the near future. Consultation help on issues relating to the Americans with Disabilities Act and Section 504 of the Rehabilitation Act may be obtained from the Disability and Technical Assistance Center (DBTAC) in Colorado—toll-free telephone number: 1-800-949-4232. The Utah State Division of Risk Management reviews new construction, addition, and remodel plans for ADA/Section 504 compliance. These agencies need to review any deviation from accessibility as defined above. Contact State Risk Management at (801) 538-9560 for more information. h. Roof Inspection Management and Maintenance A roof membrane is a consumable building element. Every day part of the useful life of the roof is being consumed by wind, snow, hail, rain, and ultraviolet rays from the sun, as well as foot traffic and various forms of abuse—even vandalism. While other elements of a building (for example, the paint finish) are more visible, and thus tend to be maintained on a regular basis, the roof membrane is usually hidden, not readily accessible, and often overlooked until it is leaking. At this point, extensive and costly damage may already have occurred. The most important reason for establishing a roof inspection management and maintenance program is to protect the capital investment of new and existing roofs. A properly functioning roof maintenance program will not only add years to the life of a roof, but will detect minor problems before major damage to the roof is done and interior building damage occur. (1) Establishing a Roof Inspection Management and Maintenance Program Step One—Establishing roof information files. Each building should have a roof plan to show all roof areas: Original building roof area, reroof areas, and building addition roof areas. Information contained in the file is essential to any roof inspection. The record files should contain the following sections: Original Building Roof Design Sections: ► Project records, roof drawings, specifications, and applicable addendums— Installation Section: ► Field reports related to the roofing installation. Warranty Section: ► Roof guarantees from the roof installer and/or manufacturer with telephone numbers and addresses for contacting in case of problems. Inspection Maintenance Section: These items are filed chronologically. Step Two—Implementing a roof inspection program with periodic inspections. Generally, roof inspections should be made twice each year, once in the spring and once in the fall. Additional roof inspections should be made after major storms, when vandalism relating to the roof is suspected, or after any rooftop equipment service or installation. Prior to any roof inspection an inspection checklist should be developed. It is recommended that a standard checklist be developed for various roofing systems (i.e., build-up roof, single-ply membrane, singles, tiles, etc.). Standard checklists help to develop a continuity of reports and a consistency that allows statistical analysis when longitudinal data has been gathered. With the inspection checklist and the roof plan, roof problems can be marked on the roof plan itself and notes made on the checklist. When problems are identified, the roof record file can be consulted and options for repairs can be pinpointed. Each inspection checklist should be returned to the master roofing record file to be reviewed prior to the next inspection. Over time, the roof record file becomes the primary resource to log problems and subsequent repairs. Step Three—Maintenance scheduling and implementation. Scheduling is usually done based on the following criteria: Long-term costs of repairs are estimated prior to actual maintenance implementation. Cost comparisons of projected maintenance by roof type and roof age allow maintenance personnel to determine whether it is better to replace a roof or continue to repair it. (2) Methods of Program Development An effective roof management program may be developed in several ways: The first method is for the school district or charter school to develop a complete in-house program to perform all steps within the district's/charter’s organization. In this method, the first two steps (1: Establishing roof information files and 2: Implementing a roof inspection program with periodic inspections) are performed by the same group of personnel. This method has the advantage of total in-house control. However, this in-house capability can also be a disadvantage in that a large technical staff may be required or it may not be possible for some school districts or charters schools to hire such specialized personnel. In addition, this method may also require extensive specialized capital equipment investment. The second method is for the school district or charter school to contract with outside professional roofing consultants. The first two steps (1: Establishing roof information files and 2: Implementing a roof inspe |