Health Schools - Trillium Foundation

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Healthy Schools — Healthy Children: Improving the Indoor Environment in Ontario Schools

Acknowledgments

Pollution Probe gratefully acknowledges the funding support provided to this project by the followingsponsors:

THE ONTARIO TRILLIUM FOUNDATIONLAIDLAW FOUNDATION

George Cedric Metcalf Charitable FoundationM. A. Motz Foundation

The Alice and Murray Maitland FoundationThe Canadian Standards Association

Pollution Probe also thanks the following in-kind supporters:

Canadian Institute of Child HealthCanadian Association of Physicians for the Environment

Ontario College of Family PhysiciansOntario Public Health Association

This report was prepared by Jill McDowell, Co-ordinator, Child Health Programme, Pollution Probe.

We recognize and appreciate the work of: Ian Morton and Ken Ogilvie in preparation of this report;Randee Holmes for editing; Natasha Teoli for research; and Krista Friesen for technical and designassistance. We are also pleased to acknowledge the following contributors to specific sections of thereport: Joe Castrilli on Legal Review and Analysis and Edward Hanna on Cost/Benefit AnalysisFramework.

A special thank you to the project advisory committee members who dedicated their time and gaveinvaluable insight and strategic counsel to Pollution Probe:

Gary Gibson and Peer Frederiksen — The Durham District School BoardShirley Thompson and Tim Robins — Toronto Catholic District School BoardBrian Eggleton — Halton District School BoardDr. Monir Taha — City of Toronto, Public HealthGerry Granek — ECE Group Limited (advisor to)Helen Webb — Parents of PeelMaggie Joshi — Parents Environmental NetworkLaurissa Werhun — Ontario Secondary School Teachers’ FederationWanda Bailey — Elementary Teachers’ Federation of OntarioLinda Ivey — Canadian Union of Public EmployeesBruce M. Small — Sustainable SolutionsAllan Fogwill — Union Gas LimitedBob De Grasse — Enbridge Consumers GasPaul Cryne — Rose Technology Group

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Pollution Probe extends its gratitude to the following organizations and individuals who reviewed andcommented on this report (or parts of the report):

Ontario Ministry of Health and Long-Term CareOntario Ministry of the EnvironmentOntario Ministry of EducationOntario Ministry of LabourIntegrated Services for Children (Ontario government)Office of the Minister Responsible for Children (Ontario government)City of Toronto — Public Health DepartmentOntario Public Health Association (Environmental Health Workgroup)Canadian Standards AssociationSandra Schwartz, Canadian Institute of Child HealthDr. Alan Abelsohn, Ontario College of Family PhysiciansGary Gibson, The Durham District School BoardShirley Thompson and Tim Robins, Toronto Catholic District School BoardArnie Wohlgemut and Doug Morris, Waterloo Region District School BoardMargaret Brevik and Graeme Gilday, York Region District School BoardJill Witherspoon, Toronto District School BoardJohn Guevin, U.S. Environmental Protection Agency — Indoor Environments DivisionGerald Muise, Nova Scotia GovernmentSandra Moser and Karen Robinson, Citizens for A Safe Learning Environment, Nova ScotiaNita Chaudhuri, South Riverdale Community Health CentreBob De Grasse, Enbridge Consumers GasHelen Webb, Parents of PeelMaggie Joshi, Parents Environmental Network

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Table of Contents

1.0 Executive Summary ................................................................................... 51.1 Issue Summary ........................................................................................................ 51.2 Recommended Actions............................................................................................ 7

2.0 Background and Introduction ................................................................... 9

3.0 The Need for Action ................................................................................. 113.1 Children’s Susceptibility to Environmental Contaminants ...................................... 113.2 Indoor Contaminants and Children’s Health .......................................................... 123.3 Schools as a Priority Place for Action .................................................................... 13

4.0 Legal Review and Analysis ..................................................................... 154.1 Constitutional Aspects ........................................................................................... 154.2 Common Law Implications ..................................................................................... 16

4.2.1 Negligence .................................................................................................. 164.2.2 Product Liability ........................................................................................... 164.2.3 Obstacles and Opportunities in Indoor Air Pollution Litigation ................... 16

4.3 Legislation.............................................................................................................. 174.3.1 Education Act .............................................................................................. 184.3.2 Health Protection and Promotion Act .......................................................... 184.3.3 Occupational Health and Safety .................................................................. 204.3.4 Building Codes ............................................................................................ 204.3.5 Environmental Legislation ........................................................................... 214.3.6 Human Rights Legislation ........................................................................... 22

5.0 Indoor Environmental Issues Facing Ontario Schools......................... 245.1 Factual Overview .................................................................................................... 245.2 Indoor Environmental Challenges .......................................................................... 255.3 Current Response Mechanisms for Indoor Environmental Problems .................... 265.4 Public Perceptions and Concerns .......................................................................... 28

6.0 Jurisdictional Leadership ........................................................................ 306.1 Government Leadership ........................................................................................ 30

6.1.1 U.S. Environmental Protection Agency ....................................................... 306.1.2 Nova Scotia ................................................................................................. 32

6.2 School Board Leadership ...................................................................................... 346.2.1 Waterloo Region District School Board ....................................................... 346.2.2 Durham District School Board ..................................................................... 36

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7.0 Cost/Benefit Analysis Framework .......................................................... 397.1 Applying a Cost/Benefit Analysis Framework ........................................................ 397.2 Information Gaps and Deficiencies ........................................................................ 407.3 Mitigating Strategies .............................................................................................. 41

8.0 Proposed Framework for an Indoor Environment Management Plan. 438.1 Rationale................................................................................................................ 438.2 Considerations ....................................................................................................... 458.3 Plan Framework ..................................................................................................... 468.4 Participation and Recognition ................................................................................ 47

9.0 Conclusions and Recommendations ..................................................... 49

Appendices

Appendix 1: Healthy Schools Project Advisory CommitteeAppendix 2: Indoor Environmental Contaminants and Potential Health EffectsAppendix 3: Healthy Schools InitiativesAppendix 4: Media Analysis of Indoor Environmental Issues in SchoolsAppendix 5: Cost/Benefit Analysis Framework for Improving Indoor Air Quality in SchoolsAppendix 6: Key Informant Interview Questions and Responses

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1.0 Executive Summary

In January, 1999, Pollution Probe launched aproject to address the state of the indoorenvironment in Ontario schools. This projectwas an outcome of a 1998 conference thatPollution Probe and the Canadian Institute ofChild Health held on children’s health and aircontaminants. Experts at this forum claimed thatchildren are more sensitive to the harmful effectsof environmental pollutants than adults and thatindoor contaminants are among the top risks tothe respiratory health of children (see proceedingsfrom conference — The Air Children Breathe:The Effects on Their Health). A priority actionitem of the conference was to address the stateof indoor environments in the places wherechildren spend their time (i.e., schools,recreational facilities and day cares).

In response, Pollution Probe initiated HealthySchools — Healthy Children, a two-phase projectthat aims to assess the range of indoorenvironmental issues facing Ontario schools, andto develop a cost-effective, proactive indoorenvironment management plan to help schoolboards identify, prevent and remediate indoorenvironmental problems. The purpose of PhaseOne is to provide the baseline information andanalysis needed for Phase Two, enablingPollution Probe and key stakeholders to developsolutions for improving the quality of schoolindoor environments in Ontario. This reportreflects the findings from Phase One of PollutionProbe’s research and addresses the following:

• the state of the indoor environment inOntario schools;

• current legal authority and responsibility forissues related to indoor environmentalquality and children’s health in schools;

• jurisdictional leadership (including casestudies of indoor environmental programmesin schools);

• the economic implications of improvingindoor environments in schools;

• a proposed framework for a voluntary indoorenvironment management plan; and,

• recommendations for action.

1.1 Issue Summary

Poor indoor air quality has been cited by manyexperts internationally as a serious health andenvironmental issue. The Science AdvisoryBoard of the U.S. Environmental ProtectionAgency (EPA) claims that indoor air pollution isone of the top five environmental hazards tohuman health. As well, the EPA states that levelsof pollutants indoors can be two to five timeshigher than levels of pollutants outdoors and, insome instances, can be up to 100 times higher.1

The World Health Organization and the NorthAtlantic Treaty Organization (NATO) alsorecognize poor indoor air quality as a serioushuman health threat.2 These claims aresignificant given that humans spend about 90%of their time indoors.3

Although children may typically spend moretime out-of-doors than do adults, the majority oftheir time is spent in the indoor environment.Elements of an indoor environment that can affecthealth and comfort include: the presence ofchemicals from cleaning, building and renovationproducts, pesticides, perfumes and furnishings;the presence of tobacco smoke, mould, dust andanimal dander; practices associated with building,renovation, maintenance and cleaning; and theamount of air flow in a building. Some healtheffects linked to poor indoor air quality include:eye, nose, and throat irritation, dryness of mucousmembranes and skin, nosebleeds, skin rash, mentalfatigue, headache, cough, hoarseness, wheezing,nausea, and dizziness.4 Indoor air pollution isparticularly problematic for those who haveasthma, allergies or other respiratory problems.5

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Because children are more vulnerable thanadults to the effects of indoor pollutants, specialcare must be taken to optimize theenvironmental quality of the places where theyspend their time.

While more attention needs to be paid to thequality of indoor environments in all buildingcategories, schools deserve special attention forseveral reasons. Schools serve one of the mostimportant functions in our communities – theyprovide generations of children with the academicand social skills that will profoundly affect theway in which they lead our society into the future.The physical condition of a child’s learningspace will affect that child’s health and capacityfor academic development. Schools are publiclyfunded facilities where children are expected togo for their education. Since they have littlechoice but to attend school, it is incumbent uponus to ensure that schools are safe and conduciveto healthy physical, emotional and intellectualdevelopment. Moreover, schools present uniquechallenges for managing indoor environmentalproblems: occupancy rates are high and childrenare in close proximity to one another; schools haveunique pollutant sources including vocationaleducation areas and art and science classes;schools have pest and germ problems that can, insome cases, result in strong chemical use; lack offunds for building renewal and deferredmaintenance have resulted in school buildingsystems being left to deteriorate; and facilitybudgets are tight and often the first to be cutduring difficult fiscal periods.

Although the condition of a school facility mayaffect both the health and academic performance ofa child, there has been little federal or provincialleadership to address indoor environmentalquality in schools. Pollution Probe conducted alegal analysis to determine the potentialconstitutional, common law and legislativeavenues for addressing indoor environmentalissues in schools. Although there are no statutesthat explicitly address indoor air pollution inschools, there is a range of laws and a variety of

ministries, departments and agencies that havesome authority for addressing different aspects ofthe problem. The participation of many playersin this area, with no clear assignment of overallresponsibility, complicates the task of improvingschool indoor environments. The fragmentationof authority prevents Ontario policy-makers fromaddressing indoor environmental issues inschools in a coherent, systematic, and unifiedmanner. Other jurisdictions, however, have hadgreater success in this regard and have shownsignificant leadership on issues related to indoorair quality in schools. In Canada, the provinces ofNova Scotia, New Brunswick and British Columbiahave enacted policies and/or programmes that aimto improve the quality of school indoorenvironments. In the U.S., the EPA and the statesof Texas, Washington, Maryland and Vermonthave developed initiatives that specificallyaddress indoor environmental quality in schools.

While the provincial government has been slowto act on indoor environmental issues pertainingto schools, some Ontario school boards havemade significant efforts to better manage theirindoor environmental problems. For example,the Waterloo Region District School Board hasdeveloped an internationally recognized “ECOclassroom” initiative, which is a programmedesigned to accommodate children with indoorenvironmental sensitivities. However, themechanisms by which school boards addressindoor environmental problems varysignificantly from one board to the next. Someschool boards address problems on a case-by-case basis in response to specific complaints.Others employ proactive strategies to preventproblems from occurring. What seems to belacking is a consistent, proactive, province-widestrategy at the school board level to improveindoor environmental quality in schools. Thedegree to which school boards address indoorenvironmental problems in schools depends onhow aware they are of the issues, their priorities,and the availability of resources. School boardsclaim that resource constraints, in particular,have been a significant barrier to school facility

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improvements. The new provincial fundingformula for education has created financialhardship for some school boards, limiting theirability to invest in improvements to the indoorenvironment. The provincial government,however, claims that its funding provisions areadequate. Since 1998, the province has made$477 million available in grants to school boardsfor renewal projects. In December 1999, theMinister of Education allocated $50 million toschool boards that experienced financialhardship managing mould problems.6

Although school board officials cite cost as oneof their biggest concerns with respect to makingindoor environmental improvements in schools,the potential economic benefits of preventing oraddressing indoor environmental problems arerarely taken into consideration. There are timeswhen the financial benefits of investing in goodequipment or practicing preventativemaintenance have been considered with respectto long-term operating costs. However, thefinancial benefits to society of improved healthof school occupants from better indoor airquality have not been given the attention theydeserve. Making responsible, informed decisionsthat affect indoor air quality in schools requiresconsideration by governments and school boardsof both the costs (i.e., investments required toimprove indoor air quality) and the benefits. Thebenefits include: improved learning andretention of knowledge by students; improvedphysical and mental health of students, teachersand support staff; reduced costs (both direct andindirect) of treating air quality-induced illnesses;and, reduced costs resulting from absenteeismand reduced productivity. The use of cost/benefitanalysis for determining optimum outdoor airquality has gained considerable acceptance overthe past 10 years. The use of cost/benefitanalysis now needs to be broadened to includethe examination of indoor air quality.

1.2 Recommended Actions

The long-term goal of Pollution Probe’s HealthySchools — Healthy Children project is tofacilitate the development of strategies that willhelp optimize indoor environmental quality inschools. Pollution Probe believes that there isenough knowledge about children’s vulnerabilityto pollutants and the related health implicationsof exposure to indoor contaminants to takeaction on a precautionary basis sooner, ratherthan later. While debate continues on the degreeto which indoor pollutants affect children’shealth, childhood asthma and allergies are rising,schools and portable classrooms across thecountry are in need of rehabilitation due to mouldproblems, and tension between parents andschool boards is growing.

Pollution Probe believes that a voluntary indoorenvironment management plan that providesschool boards with cost-effective strategies forpreventing, remediating and resolving indoorenvironmental problems in schools should bedeveloped by interested stakeholders as soon aspossible. Models for consideration couldinclude: activities already underway at someschool boards; an electronic interactive Web-based plan; the U.S. EPA’s Indoor Air QualityTools for Schools Action Kit; an environmentalmanagement system, such as ISO 14001; or anynumber of existing programmes that best suit theneeds of school boards. Public recognition ofactions taken by school boards should be anessential component of any programme; i.e.,participating school boards should beacknowledged through media events, on a Website and/or with awards. In the end, a voluntarystrategy should aim to: optimize the quality ofschool indoor environments; build on existingleadership in this area; raise awareness of indoorenvironmental issues among school occupants;and, improve public relations between schoolboards and parents.

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A voluntary plan can be an effective tool forindoor environmental improvements because itincorporates flexibility and can achieve quickresults. Pollution Probe believes, however, that acomprehensive strategy to protect children’senvironmental health in Ontario will also requiresignificant long-term investments bygovernments and interested stakeholders intoresearch, policy and outreach activities related toindoor environments and children’s health. Tohelp move this agenda forward, Pollution Probeproposes the following recommendations thatrepresent an ideal course of action for optimizingschool indoor environmental quality andenhancing children’s environmental health.

• To advance a consistent, cohesive platformon indoor environmental quality in Ontarioschools, the Government of Ontario shouldrecognize the importance of healthy indoorenvironments and assign one of theministries of education, labour, health orenvironment with the authority and resourcesto take leadership. This has happened inNova Scotia whereby the governmentprovided the Department of Education withthe expertise and resources to beginaddressing school indoor environment issuesmore effectively.

• While one ministry should assumeleadership for these issues, all of theministries that currently have partialjurisdiction should work together moreeffectively to develop a comprehensivestrategy to improve school indoorenvironments. Using Nova Scotia as amodel, an inter-ministerial committee onindoor environments, with representativesfrom the ministries of health, education,labour and environment, should be formedas soon as possible.

• To better protect children from exposure toindoor contaminants in schools, a provincialpolicy/regulatory framework should bedeveloped that acknowledges children’s

unique vulnerability to indoor contaminantsand provides children with protection fromthese hazards in schools. Moreover,governments should endorse, support andpromote the concept of developing avoluntary indoor environment managementplan for Ontario schools and school boards.

• To better understand the scope of indoorenvironmental challenges that Ontarioschool boards face, inventories of existingproblems should be conducted and moresystematic indoor air quality testing inschools should occur.

• To better understand the extent to whichschool children are at risk from exposure toindoor air pollution, co-ordinated,systematic, epidemiological and clinicalhealth studies of the impacts of poor indoorair quality on children should be conducted.

• To better understand the net economicbenefits to society of optimizing indoorenvironmental quality in schools, acomprehensive cost/benefit analysis shouldbe undertaken.

• To encourage improvements to the indoorenvironment in schools, the provincialfunding formula should be modified suchthat school boards have access to sufficientresources when modifications to schools arerequired to improve indoor environmentalquality. Alternatively, a special projects fundearmarked specifically for indoor environmentalimprovements should be established andmade available to school boards.

• To provide the public with opportunities foreffective participation in decision-makingprocesses related to school indoorenvironments, there needs to be betteroutreach and education on the range of indoorenvironmental issues that could affectchildren’s health.

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2.0 Background and Introduction

In May 1997 in Ottawa, Pollution Probeparticipated in a national conference on children’shealth and environmental contaminants. Hostedby the Canadian Institute of Child Health (CICH),the conference addressed many of theenvironmental challenges facing our children.The relationship between children’s health andwellness and environmental contaminants is anissue of increasing interest in the health andenvironmental communities. The Ottawaconference was the first in Canada to explore thisrelationship in a meaningful and informativemanner. Through this venue and other researchefforts, the CICH has advanced the dialogue onsome fundamental issues regarding the way weaddress children’s environmental health inCanada.

Building on the work by the CICH, in January1998 Pollution Probe launched its ownprogramme on children’s health andenvironmental contaminants. As a kick-off tothe programme, Pollution Probe and the CICHhosted an Ontario educational forum on theimpacts of air pollution on children’s health.Health professionals, policy-makers, educators,day care providers, and community workerscame together to define the environmental risksfacing children and to develop solutions to theproblems. The forum highlighted several issues:

• children are more susceptible to harm fromenvironmental contaminants than are adults;

• indoor environmental contaminants havesignificant impacts on children’s health;

• we need to pay greater attention to theindoor environments in which childrenspend their time; i.e., schools, recreationalfacilities and day cares;

• Canada is falling behind other jurisdictions,particularly the United States, in its policyand research efforts to protect children fromenvironmental pollutants; and,

• in Ontario, there are no guidelines, policiesor programmes that specifically protectchildren from potential indoor environmentalhazards in schools.

In response, Pollution Probe embarked on aproject to address the state of the indoorenvironment in Ontario schools. In light offindings that indoor air can be significantly morepolluted than outdoor air, the fact that childrenspend about five to six hours a day inside ofschools engaged in important learning activities issignificant. Since children are more susceptiblethan adults to the impacts of environmentalcontaminants, an unhealthy indoor environmentcan cause students to experience short- and long-term health problems.7 In contrast, a healthyindoor school environment can contribute to theproductivity of students, teachers and staff,improve comfort levels, and reduce sickness andabsenteeism.8 While it is difficult for personsother than parents or guardians to protect childrenin their home environments, the public placeswhere children spend their time should be safeand healthy.

Healthy Schools — Healthy Children is a two-phase project that aims to assess the range ofindoor environmental issues facing Ontarioschools, and to develop a cost-effective, proactiveindoor environment management plan to help

Since children are moresusceptible than adults tothe impacts of environmentalcontaminants, an unhealthyindoor environment can causestudents to experienceshort- and long-term healthproblems.

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schools identify, prevent and remediate indoorenvironmental problems. The purpose of PhaseOne is to provide the baseline information andanalysis needed for Phase Two, enablingPollution Probe and key stakeholders to developsolutions for improving the quality of schoolindoor environments in Ontario. This reportreflects the findings from Phase One of PollutionProbe’s research and addresses the following:

• the state of the indoor environment inOntario schools;

• current legal authority and responsibility forissues related to indoor environmentalquality and children’s health;

• existing jurisdictional leadership (includingcase studies of indoor environmentalprogrammes in schools);

• the economic implications of improving theindoor environments in schools;

• a proposed framework for a voluntary indoorenvironment management plan; and

• recommendations for action.

Pollution Probe’s Healthy Schools — HealthyChildren project advisory committee (seeAppendix 1 for a list of committee members)provided the direction for many of the ideasreflected in this report. Other information wasgathered through Internet and library researchand interviews.

Since children are expected to attend school, it isimportant that these public facilities bemaintained at the highest possible standards.Pollution Probe believes that it is incumbentupon caregivers, parents, teachers, school boardofficials, health-care providers and policy-makers to ensure that the school environment forchildren is optimal for learning and is conduciveto healthy physical, academic and emotionaldevelopment.

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3.0 The Need for Action

There is a significant need for action to improveindoor environmental quality in Ontario schools.Three fundamental reasons for moving forwardwith a plan to address indoor environmental issuesin Ontario schools are: 1) children are morevulnerable to the harmful effects ofenvironmental pollutants than are adults; 2)indoor contaminants can have negative healthimpacts on children; and, 3) schools areimportant places where children spend their time,and they present particular challenges formanaging indoor environment problems.

3.1 Children’s Susceptibility toEnvironmental Contaminants

Children are not simply small versions of adults.This has profound implications for how they areaffected by contaminants in the environment.Developmental, physiological, and behaviouraldifferences make children, in many instances,more vulnerable than adults to pollutants.

From the foetal stage through to the end ofadolescence, children are in a dynamic state ofgrowth with cells multiplying and organ systemsdeveloping. At birth, their nervous, respiratory,reproductive and immune systems are not yetfully developed.9 If a contaminant enters thetissues or organs of a child during a critical stageof development, it can interfere with healthymaturation. Disruption of healthy braindevelopment is of particular concern because thebrain undergoes dramatic growth anddevelopment, not only during gestation, but formany years afterwards. The creation of synapses(linkages) between brain neurons is vital;synapses make up the neuronal networks that arethe basis of further development and patterns ofadaptation and behaviour. Timing is critical forsome aspects of brain development; disruptionduring a critical period of development or to

certain cell systems may result in permanentdamage. Some environmental agents are capableof interfering with both the timing andorganization of brain development.10

Children are physiologically different than adults,and this often increases their exposure toenvironmental contaminants. Because theirprotective barriers are still developing, childrenabsorb substances (including pollutants) at amuch higher rate than adults through their skin,gastrointestinal tract and respiratory system. Aswell, because their livers and other metabolicsystems are immature, infants and children areless able than adults to detoxify and excretetoxins.11 As a result, if they are exposed tocontaminants, the impact can be quite significant.The high rate at which children breathe air andconsume water and food per kilogram of bodyweight also puts them at risk. For example, aninfant’s daily water intake per kilogram of bodyweight is almost three times that of an adult.12

Proportionate to body weight, the average one-yearold can eat up to seven times more grapes,bananas, pears, carrots and broccoli than an adult.13

Hence, developing children may receive higherdoses of pollutants from air, water and foodsources than adults.

Children’s behavioural characteristics can alsoserve to increase their exposure to environmentalcontaminants, often placing them in closeproximity to sources of environmental pollutants.As compared to adults, children are physicallycloser to the ground — a place where manybiological and chemical pollutants tend to settle.Infants and young children spend a lot of theirtime crawling and playing on floors, carpets, andgrass, and can therefore suffer prolongedexposure to the contaminants that permeate theseareas. Young children pass through an intense oralphase, ingesting relatively large quantities of“non-edible” products that may contain harmfulsubstances. Similar to adults, children spend agood deal of their time engaged in indooractivities. As a result, they are subjected to a

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range of indoor contaminants, including tobaccosmoke, volatile organic compounds, dust mites,mould, and pesticides.

Because children are more vulnerable than adultsto the effects of environmental pollutants, wemust take special care to minimize their exposurein all circumstances. In particular, we need to paymore attention to indoor environments and theirpotential health implications for children.

3.2 Indoor Contaminants andChildren’s Health

Poor indoor air quality has been cited as a serioushealth and environmental issue by many expertsinternationally. The Science Advisory Board ofthe U.S. EPA claims that indoor air pollution isone of the top five environmental hazards tohuman health. As well, the EPA states thatlevels of pollutants indoors can be two to fivetimes higher than levels of pollutants outdoorsand, in some instances, can be up to 100 timeshigher.14 The World Health Organizationrecognizes poor indoor air quality as a serioushuman health threat.15 A study done by the NorthAtlantic Treaty Organization (NATO) deemedindoor air quality a priority non-military issuefacing NATO nations.16

Many factors affect the quality of an indoorenvironment, including the products used in thebuilding, the practices for maintaining thefacility, the rate of airflow, and the age and/orcondition of the structure. Specific elements of

an indoor environment that can affect the healthand comfort of the occupants include: thepresence of tobacco smoke, mould, dust andanimal dander; the presence of chemicals fromcleaning and renovation products, pesticides,perfumes and furnishings; the use of chemicalsin photocopiers and laminators; the presence ofpolluted outdoor air; and the practices ofrenovation, maintenance and cleaning. Carpetsand fabric upholstery can have a significantimpact on indoor environmental quality as theyact as sinks for bacteria, viruses, pollens,mould, organic chemicals and dust.17 Forexample, the amount of dust found in a squaremetre of old carpet can be up to 400 times thatfound on smooth surface flooring.18

The human health effects from poor indoorenvironmental quality are often similar to thesymptoms of sick building syndrome (SBS).Health effects linked to SBS include eye, nose,and throat irritation, dryness of mucousmembranes and skin, nosebleeds, skin rash,mental fatigue, headache, cough, hoarseness,wheezing, nausea, and dizziness19 (refer toAppendix 2 for more on indoor contaminantsand health effects). Dr. Malcolm Sears ofMcMaster University claims that indoorcontaminants are the most important sources ofrisk to the respiratory health of our children.20 Ina Canadian study undertaken in 30 communities,it was found that in homes with indoor mouldproblems, the increase in asthma was 45%,bronchitis — 32%, chest illness — 52%, wheeze— 58% and cough — 89%.21 According to arecent study by Statistics Canada, the rate ofasthma among children under the age of 15 hasquadrupled in the past 20 years.22 According to a1996-97 Population Health Survey conducted bythe same agency, approximately 11% of Ontario

Dr. Malcolm Sears of McMasterUniversity claims that indoorcontaminants are the mostimportant sources of risk to therespiratory health of our children.

The EPA states that levelsof pollutants indoors can betwo to five times higher thanlevels of pollutants outdoorsand, in some instances, canbe up to 100 times higher.

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children under the age of 19 have asthma.Asthma is the leading chronic childhood diseaseand the primary cause of school absenteeism.23

While respiratory illness is the primary healtheffect associated with poor indoor air quality,there are additional health effects that have beenlinked to indoor contaminants. The presence ofenvironmental (second-hand) tobacco smoke cancause children to develop ear infections, as wellas asthma and other breathing problems.24 Astudy done in Cleveland, Ohio revealed anassociation between infant deaths due to lunghaemorrhage and the presence of Stachybotryschartarum mould in the homes of these infants.25

Dr. Doris Rapp, U.S. Paediatrician, Allergist,and Environmental Medical Specialist, hasdocumented numerous cases of children withchemical and environmental sensitivities whosuffer severe and debilitating health effects afterexposure to mould, dust, perfumes and cleaningproducts.26 Due to varying sensitivity amongindividuals, indoor pollutants can causesignificant health impacts for some children andmild impacts for others.

Determining with certainty the impacts of indoorpollutants on all types of children (i.e., sensitiveand nonsensitive) is a task that could take years ofresearch, especially given the multiplicity ofpollutants that exist in the indoor environmentand the potential synergistic impacts that weknow little about. Waiting until there isdocumented, scientific cause and effect evidencebefore we act could compromise the health of ageneration of children. While the debatecontinues on the degree to which indoorpollutants affect children’s health, childhood

asthma and allergies are rising, schools andportable classrooms across the country are in needof rehabilitation due to mould problems, andtension between parents and school boards isgrowing. We know enough about children’svulnerability to pollutants and the serious impactsof indoor contaminants to take action on aprecautionary basis sooner, rather than later.

3.3 Schools as a Priority Placefor Action

Although children may typically spend moretime out-of-doors than do adults, the majority oftheir time is also spent in the indoorenvironment.27 Children attending school spendabout five to six hours of every weekday in thesefacilities; young children who attend day care in aschool spend even more than that amount of timethere. The time that children spend in schools isextremely important given that they are there toacquire academic and social skills that will,ultimately, affect their future and the future ofour society. Since schools are publicly fundedfacilities where children are expected to go fortheir education, society has the responsibility toprovide these children with the best possibleenvironment in which to learn.

Schools present particular challenges formanaging indoor environmental problems.Approximately four times as many students andteachers occupy a given classroom space as doemployees occupy an office space.28 Yet manyschools have a lower ventilation capacity than atypical office building. Given the rate at whichinfections can spread through a schoolpopulation, highly volatile commercial cleanersare often used to keep germs under control.Schools have other unique pollutant sources,including cafeterias, art and science classes,vocational education areas, pools, rest rooms andlocker rooms.29 Historically, education in theclassroom has been given priority overmaintenance of the educational facility. Hence,

The time that children spend inschools is extremely importantgiven that they are there toacquire academic and socialskills that will, ultimately,affect their future and thefuture of our society.

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maintenance budgets are tight and often the firstto be cut during difficult fiscal periods.30

According to the first national study of schoolfacilities, done in 1993 — Canadian Schoolhousein the Red, Canadian schools have specificproblems related to building deterioration,upgrades, deferred maintenance and indoor airquality.31 Moreover, one in six schools acrossCanada is considered an inadequate place forlearning.32 In 1993 in Ontario, 73% of schoolshad outlived their life expectancy, which istypically 40 years. Forty-three per cent weredeemed in excellent shape, 37% were in faircondition and 20% were in poor condition.33 Thereport states that substandard conditions of manyof the facilities are due to deferred maintenanceand building deterioration. With competingdemands and limited resources, school boardsare often faced with reducing maintenancebudgets. In 1993, Ontario had a deferredmaintenance burden of $396 million. When

maintenance is deferred, building systemsdeteriorate more quickly and indoor air qualityproblems increase.34

Of Ontario school administrators surveyed forCanadian Schoolhouse in the Red, 88% believethat the learning environment is a “key factor” ofor “absolutely critical” to student achievement. A1991 study conducted at Georgetown Universityin Washington confirms these assumptions.35

Fifty-two school facilities in Washington wereassessed by engineers and architects andclassified into three categories: excellent, fair orpoor condition. Factoring out the variables thatcould affect learning, student achievement scoreswere then evaluated in all of the schools. Theresearcher found that the students attendingschools in poor condition were 5.5 percentagepoints behind students attending schools in faircondition, and 11 percentage points behind thoseattending schools in excellent condition. Thisresearch prompted the U.S. government to passthe State Infrastructure Banks for Schools Act of1997 that enacts funding provisions for schoolbuilding and repair.36

Schools clearly should be a priority place forimproving indoor environmental quality. If thepurpose of schools is to educate children, then thefacilities that house children for this importantactivity should be in optimal condition.

Of Ontario school administratorssurveyed for CanadianSchoolhouse in the Red, 88%believe that the learningenvironment is a “key factor” ofor “absolutely critical” tostudent achievement.

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4.0 Legal Review and Analysis

Although the condition of a school facility mayaffect both the health and academic performanceof a child, there is little federal or provincialleadership to address indoor environmentalquality in schools. This section of the reportdraws upon the text that is relevant to schools ofan analysis prepared for Pollution Probe by JoeCastrilli, Barrister and Solicitor, entitled LegalAspects of Indoor Air Quality in Canada.(Please refer to this report for references and amore detailed legal analysis of indoor air qualityissues in general.)

In the review below, Pollution Probe uses Mr.Castrilli’s analysis to examine the potentialconstitutional, common law and legislativeavenues for addressing indoor environmentalquality in schools. Under the Constitution, thefederal spending power could be applied toindoor air quality in schools. The Charter ofRights provides the potential basis for initiatinglitigation to protect the rights of chemicallysensitive groups from discrimination. Undercommon law, students and school boards canimpose liability on an array of defendantsresponsible for creating indoor air pollutionproblems. With respect to legislation, there arefew statutes that explicitly address control ofindoor air pollution, and none that explicitlyprotect children from the potential harmassociated with indoor contaminants in schools.

Moreover, even where legislation addressesproblems of indoor air quality, the standardsthat have been developed cover few chemicalsubstances of concern.

4.1 Constitutional Aspects

The Canadian Constitution divides the legalauthority for environmental issues between thefederal and provincial governments. In previouscases dealing with constitutional aspects ofenvironmental legislation, the focus has been onthe “natural” (i.e., outdoor), rather than the “built”(i.e., indoor) environment. Indoor environmentalissues in schools should be considered under boththe division of powers and the Charter of Rightsunder the Constitution.

With respect to division of power, the CanadianConstitution grants spending power to thefederal government that could impact the way inwhich provinces fund education. Under thispower, Parliament may spend or lend funds toany government, institution, or individual forany purpose, and may attach to any grant or loanany condition it chooses, including conditions itcannot directly legislate. Therefore, the federalgovernment has the authority to place conditionsrelated to indoor air quality on funds transferredto the province. In terms of provincial powers, theConstitution gives the Ontario government theauthority to regulate indoor air quality if itchooses to do so.

The Charter of Rights and Freedoms provides thepublic with certain fundamental liberties thatgovernments cannot interfere with, unlessgovernments can demonstrate that suchinterference is justified in a free and democraticsociety. It states, “Every individual is equal beforeand under the law and has the right to the equalprotection and equal benefit of the law withoutdiscrimination based on . . . sex, age or . . .physical disability.” It is possible that federal orprovincial laws, programmes, or activities that

With respect to legislation,there are few statutes thatexplicitly address control ofindoor air pollution, and nonethat explicitly protectchildren from the potentialharm associated with indoorcontaminants in schools.

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protect the “average” Canadian within the contextof the indoor environment, but fail to protectwomen, children, the elderly, or those sufferingfrom special chemical sensitivities might runafoul of the Charter’s equality rights provision.

4.2 Common Law Implications

The common law (law made by a judge) mayprovide compensation for people who have beenharmed as a result of exposure to indoor airpollutants. Specifically, children who have beenharmed as a result of poor indoor air quality inschools could sue under common law principles.Those that may be liable could include owners,architects, contractors and engineers, amongothers. It may, however, be legally difficult toprove that any harm suffered by the child wascaused by the actions or practices of particularindividuals.

Although there have been few reportedjudgements in Canadian courts to date regardingliability for indoor air pollution, tort theories ofliability may be used to address these cases wherethey arise. Tort theories of liability that are mostapplicable to damage suffered by children inschools are negligence and products liability.

4.2.1 Negligence

Negligence is conduct that breaches a standardof care owed to a person who is harmed by theconduct. To prove an action in negligence, theplaintiff must show that: 1) s/he is within a classof people the defendant was obligated to carefor; 2) the defendant’s behaviour fell below thestandard they should be expected to maintain;and 3) the plaintiff suffered damage that wasforeseeable by the defendant.

Since principals and school boards owe a “duty ofcare” to the students, failing to address indoorenvironmental problems could constitutenegligence.

4.2.2 Product Liability

When manufacturers, processors, sellers, orothers produce products that injure people orproperty, they may be liable in negligence. Thenegligence theory of product liability is similar,in principle, to ordinary negligence law.Manufacturers and others have a duty to usereasonable care in producing products. Forexample, if it were shown that failure to takereasonable care in constructing a school resultedin defects that posed a substantial danger to thehealth and safety of school occupants, schoolboards could be liable. As well, since schoolboards are consumers of building materials, theycould sue suppliers if their products were found tobe defective. Although manufacturers arerequired to provide consumers with warningsassociated with the product’s danger, thisobligation does not exonerate them from the dutyto manufacture safe products in the first place.

Overall, product liability provides a potentiallegal basis for imposing liability on an array ofdefendants responsible for creating indoor airpollution problems. However, for this defense tobe successful, complex problems of scientificand medical proof still must be overcome.

4.2.3 Obstacles and Opportunities in Indoor Air Pollution Litigation

Using private litigation for resolving indoorenvironmental problems in schools presentssignificant obstacles for plaintiffs. One of thegreatest challenges for a person suing is to provethat the action or product of the person beingsued caused the problem. The prohibitiveexpense and complexity of civil litigation is

When manufacturers, processors,sellers, or others produceproducts that injure people orproperty, they may be liable innegligence.

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another challenge for plaintiffs. Because indoorenvironmental problems are often complex, theplaintiff may need technical, medical, andscientific expert witnesses in order to prove theircase. Given that indoor environmental problemscan arise from several factors, plaintiffs may berequired to sue more than one party. Moreover, incivil litigation in Ontario, unsuccessful plaintiffsnot only have to pay the costs of their ownlawyers and experts but also a portion of the costsincurred by successful defendants. This can havea chilling effect on the ability and willingness of“victims” to take on such litigation.

Reliance on private litigation, to solve whatseem to be pervasive challenges facing asignificant portion of the nation’s building stock,is not necessarily prudent or effective. Privatelitigation is primarily reactive in nature andavailable only to people who have the time,energy and funds to pursue such an undertaking.As an effective strategy for addressing indoorenvironmental problems, litigation needs to becombined with legislation that is preventive, issystematic, and seeks to achieve long-termplanning goals.

On the other hand, civil litigation may be the onlyway to achieve a remedy where governmentagencies have failed to act, and to heighten theprofile of indoor air quality with the public, thelegislature, and the media. Several provinces,including Ontario, now authorize class actions orproceedings, whereby several people who have acommon interest or injury may jointly sue a

defendant (or defendants) for damages in a singlecase. This measure permits plaintiffs to offset theoften prohibitive costs of lawyers and expertwitnesses associated with civil litigation bycombining resources for a case.

Overall, civil litigation may be used as a tool forredressing injuries sustained from indoor airpollution, filling gaps in the legislative regime,and providing a stimulus for the development ofmore comprehensive legislative schemes.

4.3 Legislation

The range of federal and Ontario legislationpotentially applicable to indoor air quality isenormous. It includes laws pertaining to toxicsubstances, energy conservation, health promotionand protection, human rights, housing, buildingcodes, product safety, radiation protection,occupational health and safety, workers’compensation, pesticides and tobacco control.Due to the diversity of issues that may touch onindoor air quality, a variety of ministries,departments and agencies at all levels ofgovernment may have some authority foraddressing different aspects of the problem. Thisdiversity of authority is understandable, given thenumber of areas involved. However, diversityalso has the potential to create fragmentation ofauthority and result in ineffectiveness. This canoccur if various levels of government and differentministries with a wide variety of, as well aspotentially conflicting mandates, do not co-ordinate their efforts to address indoor air pollutionin a coherent, systematic, and unified manner.

This section reviews the most important piecesof federal and Ontario legislation that arerelevant, or potentially relevant, to the control ofindoor air pollution in schools. Identification ofa statute in this section does not necessarilymean that the statute is actually applicable to theindoor air quality problem; the application maybe more potential or theoretical than actual.

The range of federal and Ontariolegislation potentially applicable toindoor air quality is enormous. Dueto the diversity of issues that maytouch on indoor air quality, avariety of ministries, departmentsand agencies at all levels ofgovernment may have someauthority for addressing differentaspects of the problem.

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4.3.1 Education Act

The Education Act, administered by the OntarioMinistry of Education, is the primary provinciallaw dealing with the establishment andmaintenance of schools in Ontario. As notedabove, the provinces have exclusive jurisdictionto develop laws governing education. Provincialeducation legislation reflects concern for thehealth, safety, and welfare of students, but issilent on the issue of indoor air quality. Provincialstatutes usually impose responsibilities on schoolboards and their employees to supervise pupils,ensure cleanliness, provide ventilation, inspectequipment, and undertake related obligations.These legal responsibilities are in addition tothose existing in common law, primarilyassociated with the law of negligence.

The act authorizes the Minister to makeregulations regarding establishing schools,accommodation and equipment of buildings, andduties to supervisory officers. The Minister alsoallocates funding to school boards based on pupilaccommodation allocation formulas establishedunder the regulations. As well, the act imposesspecific duties on school boards including (1)keeping the school buildings and premises inproper repair and in proper sanitary condition,providing suitable furniture and equipment andkeeping it in good repair, and protecting theproperty of the board, and (2) insuring thebuildings and equipment of the school board aswell as employees. School boards also haveauthority to: erect, add to, or alter buildings fortheir purposes on land owned by the boards;erect school buildings on land leased by the

boards where the terms of the lease, the schoolsite, and the school building plans are approvedby the Minister; and, add to, alter, or improveschool buildings on leased lands with theapproval of the Minister.

The act also imposes duties on school principalsto “give assiduous attention to the health andcomfort of the pupils, to the cleanliness,temperature, and ventilation of the school . . . andto the condition of school buildings” and to“report promptly to the board and to the medicalofficer of health when the principal has reason tosuspect the existence of any communicabledisease in the school, and of the unsanitarycondition of any part of the school building.” Theregulations impart additional obligations onschool principals, including organizing andmanaging the school, and inspecting the schoolpremises at least weekly and reporting to theschool board (1) any repairs to the school that arerequired and (2) any lack of attention on the partof the building maintenance staff of the school.

Overall, the act provides a potential basis foraction on, but no specific guidance with respectto, indoor air quality issues by the Minister,school boards, and principals. Imposed primarilyon school boards and principals, the statutoryduties raise the possibility of potential liabilityfor indoor air quality issues. For example, failureof a school board or principal to deal withindoor environmental problems could result in abreach of statutory obligations, which couldconstitute negligence under common law.

4.3.2 Health Protection and Promotion Act

Health legislation at the federal and provinciallevel is potentially applicable to the problem ofindoor air pollution because of the general focusof such legislation on protection of the public fromhealth risks and hazards. This includes the federalDepartment of Health Act, the Ontario Ministry ofHealth Act and the Ontario Health Protection andPromotion Act. Indeed, some government health

The Education Act imposesduties on school principals to“give assiduous attention tothe health and comfort ofthe pupils, to the cleanliness,temperature, and ventilationof the school . . . and to thecondition of school buildings”.

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departments have developed voluntary, or non-regulatory, indoor air quality programmes.However, in practice, federal and provincial healthlaws are no more specific than most environmentallaws in addressing indoor air quality.

The statute most relevant to a discussion ofOntario schools is the Health Protection andPromotion Act. Administered by the OntarioMinistry of Health and Long-Term Care, thepurpose of this act is to (1) provide for theorganization and delivery of public healthprogrammes and services, (2) prevent the spreadof disease, and (3) promote and protect the healthof the people of Ontario. The act authorizes thecreation of local boards of health to meet theseobjectives. The act defines “health hazard” as acondition of a premises, a substance, thing, plant,or animal other than human, or a solid, liquid,gas, or combination of any of these, that “has or islikely to have an adverse effect on the health ofany person.” Under the statute, the Minister isauthorized to publish guidelines for mandatoryhealth programmes and services with which everyboard of health must comply. However, the actmakes it clear that the guidelines are notregulations and that, in the event of a conflictbetween the two, the regulations prevail.

To ensure community health protection, the actalso requires medical officers of health to conductinspections to prevent, eliminate, and decrease theeffects of health hazards in their jurisdiction. Theymust respond to complaints of health hazardsrelated to occupational or environmental health intheir health unit. The medical officer of health,

alone or in conjunction with other ministries thathave primary authority for the problem, mustinvestigate the complaint to determine whether ahealth hazard exists, and report the results of theinvestigation to the complainant. Medicalofficers of health also must keep themselvesinformed on issues related to occupational andenvironmental health. As well, the medicalofficer of health and public health branch staffprovide research support and technical expertise.The ministries of environment, health and labourare required to provide information requested bymedical health officers.

Where a medical officer of health believes that ahealth hazard exists in his or her health unit, s/hemay issue an order to a person to address thehealth hazard. The order may require the vacating,closing, cleaning, and placarding of the premises,removing or destroying the source of the healthhazard, and prohibiting or regulating themanufacturing, processing, preparation, storage,handling, display, transportation, sale, ordistribution of anything that is the source of thehealth hazard. When mould was found in many ofthe portable classrooms in the region of Halton,for example, the medical officer of health orderedinvasive inspection of all portable classrooms.

The Minister also is authorized to exercise thepowers granted to boards of health and medicalofficers of health under the act, when theMinister is of the opinion that a situation existsanywhere in Ontario that constitutes a risk to thehealth of any person. Actions available to theMinister include investigating, preventing,eliminating, or decreasing the risk.

The act is clearly broad and general enough topermit the ministry, local boards, and medicalofficers of health to address issues relating toindoor air quality in Ontario. However, the act,regulations, and guidelines are not specific to theissue, and provide no special guidance oncontrolling indoor air pollution in schools.

To ensure community healthprotection, the HealthProtection and Promotion Actrequires medical officers ofhealth to conduct inspectionsto prevent, eliminate, anddecrease the effects ofhealth hazards in theirjurisdiction.

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4.3.3 Occupational Health and Safety

At federal and provincial levels in Canada,occupational health and safety legislation isdesigned to address workplace conditions,including aspects of indoor air quality. Withrespect to schools, it applies only to the workersin that environment, and not to the children whooccupy the same premises. The origin of this typeof legislation was the industrial or manufacturingworkplace where there was a focus on certainhazardous air pollutants and their impact on thehealthy male adult worker. While modernoccupational health and safety legislation broadlydefines the workplace environment, the focus ofthe regulations, with some exceptions, still tends tobe related to the industrial setting. The continuingfocus on air pollutants in industrial workplacesmay not be helpful to workers and others in non-industrial workplaces, such as office buildings,schools, and nursing homes.

The provincial Occupational Health and SafetyAct (OHSA), administered by the OntarioMinistry of Labour, imposes responsibilities onemployers to protect and inform workers, andestablish committees to deal with workplacehealth and safety issues. It also provides theMinistry of Labour with the authority to conductinspections and control toxic substances that mayendanger the health of workers. With respect toindoor air quality, the ministry uses, as bestpractices guidelines, the current standards set bythe American Society of Heating, Refrigeratingand Air-conditioning Engineers (ASHRAE) andthe recommendations of the Inter-MinisterialCommittee on Indoor Air Quality.

The OHSA also authorizes the province to makeregulations to protect worker health and safetyand to list any biological, chemical, or physicalagents or combination thereof as designatedsubstances. Regulations made under this authorityhave dealt with such materials as lead andasbestos. Because only one substance isconsidered at a time, only twelve designated

substance regulations have been developed todate. The need to control other workplace toxicsubstances led the province to create a genericregulation for controlling exposure toapproximately 600 biological and chemical agentslisted in the regulation. In addition, as part of thenational programme on hazardous materialsdisclosure and protection of confidential businessinformation, Ontario has developed a regulationon workplace hazardous materials information.

4.3.4 Building Codes

Building codes have the potential to affect indoorair quality in the context of building ventilationand use of building materials. At the federal level,the national building code is a guideline that hasno legal effect unless it is specifically referred toin another federal statute. On the other hand,provincial building codes tend to be developed asregulations under provincial building codelegislation. They have broad legal effect and maybe enforced by provincial and municipalgovernments. Building codes are still evolving interms of whether and, if so, how they specificallyaddress indoor air pollution issues.

The Building Code Act, 1992, administered bythe Ontario Ministry of Municipal Affairs andHousing, provides province-wide standards forconstruction, demolition, and maintenance ofbuildings (including schools). The act makesmunicipal councils responsible for enforcementof the act in their municipality, and requires that

At federal and provincial levelsin Canada, occupational healthand safety legislation is designedto address workplace conditions,including aspects of indoor airquality. With respect toschools, it applies only to theworkers in that environment,and not to the children whooccupy the same premises.

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they appoint chief building officials andinspectors for this purpose. The act and thebuilding code established under it supersede allmunicipal by-laws regarding the construction ordemolition of buildings in Ontario.

There are two aspects of the building code thathave potential application to indoor air qualityproblems. These include standards for heating,ventilating, and air-conditioning (HVAC)systems, and for building materials. Under thecode, HVAC systems must be designed,constructed and installed to conform to “goodengineering practice” as set out in a number ofhandbooks published by ASHRAE. This includesrequirements that HVAC systems be designed tominimize the growth of microorganisms.Additionally, the rate at which outdoor air issupplied to rooms and spaces in buildings byventilation systems must meet certain ASHRAEstandards. Air contaminants released withinbuildings must be removed at their points oforigin and must not be permitted to accumulate inconcentrations greater than the limits establishedby the American Conference of GovernmentalHygienists. The code also specifies that materialsused in air duct systems must be constructed ofcertain materials including “asbestos, cement orsimilar noncombustible material.”

The act establishes a building materialsevaluation commission whose powers and dutiesinclude (1) researching and examining materials,techniques, and building design for construction,(2) authorizing the use of any innovative material,system, or building design, and (3) makingrecommendations to the Minister respectingchanges to the act or building code. While the

code standards for building materials are silenton indoor air quality issues, they do permit theuse of innovative alternatives to those materialsspecified in the code. In general, however, thecode is not overly specific about control ofindoor air pollution.

4.3.5 Environmental Legislation

Environmental legislation at the federal andprovincial levels of government in Canadatends, on the whole, to focus on outdoor airquality. This includes the federal Department ofEnvironment Act, Canadian EnvironmentalProtection Act, and Canadian EnvironmentalAssessment Act, and the provincial OntarioEnvironmental Protection Act, EnvironmentalAssessment Act, and Environmental Bill ofRights. While improving ambient (or outdoor) airquality can provide an indirect benefit to indoorair quality by reducing the concentrations ofpollutants introduced by outdoor air, federal andprovincial environmental legislation is generallynot directly focused on, or designed to address,the specific problems posed by indoor airpollution. The Ontario Environmental AssessmentAct, however, is the exception and does havesome application to indoor air quality.

Ontario’s Environmental Assessment Act(OEAA) has the potential to apply to indoor airquality issues associated with the establishment ofnew projects, or the expansion of existingprojects, that are subject to the act. The definitionof environment is broader than that found underfederal environmental legislation or under theOntario Environmental Protection Act. Underthe OEAA, environment means (1) air, land, orwater, (2) plant and animal life, including humanlife, (3) the social, economic and culturalconditions that influence the life of humans or acommunity, (4) any building, structure, machine,or other device or thing made by humans, (5)any solid, liquid, gas, odour, heat, or radiationresulting directly or indirectly from humanactivities, or (6) any combination thereof.Moreover, the act further defines air to include

There are two aspects of thebuilding code that have potentialapplication to indoor air qualityproblems. These include standardsfor heating, ventilating, and air-conditioning (HVAC) systems, andfor building materials.

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“enclosed air.” As a result of these broader andmore explicit definitions that include referenceto the environment encompassing buildings,enclosed air, and humans, it is arguable thatindoor air quality considerations may be takeninto account in connection with new orexpanded projects that are made subject to theOEAA. This could apply to new schoolconstruction or significant additions to schools.

The OEAA requires proponents of public, anddesignated private-sector undertakings to preparean environmental assessment that outlines thepurpose of, and rationale for, the undertaking. Theenvironmental assessment also may considerpossible alternatives to the undertaking, advantagesand disadvantages to the environment, andmitigating measures. For major projects, approvalsunder the statute may be preceded by quasi-judicialhearings before the Environmental AssessmentBoard, established under the act. The act andguidance documents require a proponent to gothrough an environmental planning process thatcontains five key features: (1) consultation withaffected parties; (2) consideration of reasonablealternatives; (3) consideration of all aspects of theenvironment; (4) systematic evaluation of netenvironmental effects; and (5) provision of clearand complete documentation.

4.3.6 Human Rights Legislation

Human rights legislation at the federal andprovincial levels in Canada aims to prohibitdiscrimination against people with handicaps ordisabilities, and requires employers and others toreasonably accommodate such individuals. Keyto determining the effectiveness of human rightslegislation in addressing indoor air quality inschools is whether a student suffering fromchemical sensitivities could be considereddisabled, and what actions would constitutereasonable accommodation of this person.The Ontario Human Rights Code, administeredby the Ontario Ministry of Citizenship, Culture,and Recreation, contains a number of statementsregarding the need for freedom fromdiscrimination. These include (1) recognition ofthe inherent dignity and equal rights ofindividuals in accordance with the UniversalDeclaration of Human Rights proclaimed by theUnited Nations, (2) declaration that it is publicpolicy in Ontario to recognize the dignity andworth of every person and to provide for equalrights and opportunities without discriminationthat is contrary to law, and (3) confirmation thatit is desirable to “extend the protection of . . .human rights in Ontario.”

The code states that every “handicapped” personhas the right to equal treatment withoutdiscrimination with respect to: services, goods,and facilities; accommodation; contracts; and,employment. “Handicap” is defined as “anydegree of physical disability . . . caused byillness” or a “disability for which benefits were

Key to determining theeffectiveness of human rightslegislation in addressing indoor airquality in schools is whether astudent suffering from chemicalsensitivities could be considereddisabled.

As a result of broad and moreexplicit definitions that includereference to the environmentencompassing buildings, enclosedair, and humans, it is arguablethat indoor air qualityconsiderations may be takeninto account in connection withnew or expanded projects thatare made subject to theOntario EnvironmentalAssessment Act.

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claimed or received under an insurance planestablished under the Workplace Safety andInsurance Act, 1997.” People with handicapsmust be reasonably accommodated, unless thiscannot be achieved without undue hardship onemployers or others responsible for providingthe accommodation, taking into account costfactors, outside opportunities for funding, andhealth and safety requirements.

Although there are no reported cases ofdiscrimination under the code related tochemical sensitivities from indoor air pollution,

there is some recent case law that makes itconceivable that a person with such sensitivitiescould be considered disabled. In one case, aBoard of Inquiry found that alcoholismamounted to a “degree of physical disability . . .caused by illness”, even though nothing in thecode specifically included alcoholism within thedefinition of handicap. If Boards of Inquiry areprepared to find that alcoholism constitutes ahandicap, then it is conceivable that, in futurecases, disability due to chemical sensitivitycould also be included in the definition.

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5.0 Indoor Environmental Issues Facing Ontario Schools

The quality of indoor environments in Ontarioschools is determined by a range of factors atschool boards, including financial resources,priorities and general awareness of indoorenvironmental issues. This section describes theindoor environmental challenges faced by schoolboards, the mechanisms they employ to addressthese challenges and public perception of indoorenvironmental quality in schools. To begin,some basic school statistics are presented toprovide an overview of Ontario’s school system.

5.1 Factual Overview

Day Care in Ontario Schools

• There are approximately 3,000licensed day cares in Ontario withabout 150,000 children in attendance.

• Approximately one-half of all day caresare located in schools.

• Day care programmes with school-aged children can be operated inportable classrooms.

• Children in day care are covered by theDay Nurseries Act, which addressesconditions of the physical plant. Theonly requirement related to air qualityis that children must go outside twice aday.

Source: Kerry McCuaig, Executive Director; Ontario

○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○ ○

Coalition for Better Child Care

Ontario Portable Classrooms

• There are approximately 10,000portables in Ontario (the exact numberis unknown; the Ontario Ministry ofEducation does not have records ofevery portable purchased in theprovince).

• Most portable growth was in the mid-1980s for the purpose ofaccommodating spikes in schoolpopulation.

• The life expectancy for a wood-frameportable is 15 years, depending on themaintenance regime and stability oflocation.

• There are approximately 4,000portables in Ontario that are 15 yearsor older.

Source: Business Services Branch; Ontario Ministryof Education

Ontario Schools

Publicly funded Ontario schools (based on1997-98 data)

• Total enrolment: 2,095,630• Number of schools: 4,751• Number of teachers: 117,007

Privately funded Ontario schools (based on1997-98 data)

• Total enrolment: 92,070• Number of schools: 618• Number of teachers: not available

Estimated number of non-teaching staff inpublicly funded schools (i.e.., support staff,custodians, administrators, etc.): 38,000

Sources: Ontario Ministry of Education Website (www.edu.gov.on.ca/eng/elcome.html)and Linda Ivey, Ontario School BoardCo-ordinating Committee, CUPE.

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5.2 Indoor EnvironmentalChallenges

Anecdotal evidence, media reports and theconclusions reached in Canadian School Housein the Red suggest that Ontario school boards aredealing with a host of challenges related to thecondition of school facilities and indoor airquality. The new provincial funding formulaexacerbates the challenges as it lacks thenecessary provisions for indoor air qualityimprovements.

One of the key indoor environmental issues thatschool boards encounter is inadequate ventilationof schools. The Durham District School Boardclaims that exhaust-only ventilation systems areone of the primary causes of indoor air qualityproblems in their schools.37 This type of systemexhausts air to the outside through fans, generallylocated in ceilings of classroom clothes closets.38

Inside air should be replaced by outside airentering through windows and cracks in thestructure. However, in colder temperatures,windows are not opened; as well, energyconservation efforts have sealed cracks andblocked off pathways for outside air.Approximately 70% of Ontario schools were builtbefore the 1970s with exhaust-only ventilationsystems.39 Another cause of ventilation problemsis poorly designed renovation schemes. In manyschools, rooms have been subdivided toaccommodate more students, programmes andday cares. Often the occupants of the new roomare cut off from the ventilation provided to thelarger room.40 Ventilation provided to rooms thathouse computers and photocopiers is frequentlyinadequate. Older schools were not built toaccommodate newer technologies. As a result,students and staff who study and work in theseareas are more likely to report health problemsassociated with poor ventilation.41

Other indoor environmental factors that requirethe attention of school board officials include

chemicals and biological agents. The formerMetro Toronto School Board dealt withcomplaints related to specific contaminants,such as ozone and formaldehyde, andmicroorganisms, such as dust mites.42 Healtheffects that are commonly reported (often toschool board and union officials) includeheadaches, low energy, sore throat, respiratoryproblems and general flu-type symptoms.43

Recently, school board health and safety officershave been receiving numerous complaintsrelated to indoor air quality in portableclassrooms.44 Recent mould problems in Haltonand Peel region portables have heightenedconcern among parents and school portableoccupants. Portable classrooms were neverdesigned for permanent use. Poor design andconstruction practices have made portables proneto water seepage, which leads to mould growth.45

As well, if they are not aired out regularly, theybecome stuffy, carbon dioxide levels rise andoccupants become tired and less productive.46

Mould has also been a problem in permanentschool structures. Recently, two Ontario schoolstemporarily closed for rehabilitation due to mouldproblems.47 Mould tends to collect in carpets aswell, along with other biological agents such asdust mites, pollen and bacteria.48 In fact, theDurham District School board found over theyears that mould amplifiers are more prevalent incarpets than in portables.49

Through Bill 160, the EducationQuality Improvement Act, theMinistry of Education now assumescontrol over school funding. Thenew funding formula has no specificprovisions for indoor environmentalimprovements and offers noflexibility for dealing with specialconcerns. For many boards, the newfunding formula has meant fewerresources for everything, includingfacilities management.

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Radon, a naturally occurring radioactive gas, isanother substance of concern in schools. TheCanadian Institute for Radiation Safety has foundhigh levels of radon in four Ontario schoolsduring the past six years.50 Two schools in theformer Metro Toronto School Board had readingsat or above the U.S. Action Level of 20 mWL(milli Working Levels). As well, two schools inthe Northumberland Board of Education hadreadings at 25 mWL and 48 mWL. Radon is acarcinogenic substance. Increases in exposure toradon equal increased health risks. Whereas theU.S., the U.K. and Sweden have done extensivetesting, very little radon testing has been done inCanada. In the province of Ontario, only theformer Metro Toronto School Board hasconducted comprehensive radon testing. Moretesting is needed to ascertain the extent to whichradon presents a risk to children’s environmentalhealth in Ontario schools.

While there exists some evidence to suggest thatOntario schools have indoor environmentalproblems, more research is needed to ascertainthe range and extent of the problems and thepotential health impacts on school occupants. Withthe exception of that published in Canadian SchoolHouse in the Red in 1993, there have not been anyformal studies conducted on the state of schoolfacilities in Ontario. Moreover, there have neverexisted any systematic inventories of all indoorenvironmental problems that exist in Ontarioschools. There are gaps also in our knowledge ofthe degree to which school indoor contaminantsare exacerbating the health problems of childrenwith asthma, allergies, immune system deficienciesand other sensitivities. This information needs tobe gathered to better understand the scope of theissues and encourage a co-ordinated response tothe problems.

To assist school boards in responding to indoorenvironmental challenges in a responsible,effective manner, more resources are needed. In1997, the provincial government made significantreforms to Ontario’s education sector through Bill160 — the Education Quality Improvement Act.

One of the major changes made by Bill 160 was anew funding formula for schools. Prior to Bill160, local school boards were responsible forfunding their own facilities. They had the powerto raise funds locally, through property taxes,and could apply to provincial grant programmesfor special projects. With Bill 160, the Ministryof Education now assumes control over schoolfunding. Through several grant programmes, theMinistry provides school boards with funds basedon the number of students and the square footageof the facility. The new funding formula has nospecific provisions for indoor environmentalimprovements and offers little flexibility fordealing with special concerns. The governmentwould argue that the new funding formulaprovides adequate financial resources forfacilities issues; in 1999-2000, it will allocate$1.7 billion to school boards for operation,maintenance and renewal of schools — anamount that government officials believe issufficient.51 However, many boards claim that thenew funding formula has meant fewer resourcesfor everything, including facilities management.For example, the Toronto District School Boardwill have $300 million less in their funding potdue to Bill 160; as well, the majority of the cuts tothis board are in non-classroom categories such asschool operations, maintenance and renewal.52

The provincial funding formula needs to bemodified to allow school boards access tosufficient financial resources wheremodifications to schools are required to improveindoor environmental quality. Alternatively, aspecial projects fund needs to be established forindoor environmental improvements in schools.

5.3 Current ResponseMechanisms for IndoorEnvironmental Problems

Currently, there is no overarching programme,strategy or policy on a province-wide basis toproactively address the quality of school indoorenvironments. Many Ontario school boards have

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acquired extensive experience in dealing withindoor air quality problems and haveimplemented effective approaches to addressingthe issues. However, many also deal with indoorair quality complaints on a case-by-case basis,reacting to and resolving problems as they arise.

While there is much flexibility in the way thatindoor environmental issues are resolved inschools, the general chain of command is asfollows:

• the complaint is made to the principal;

• the principal resolves the problem ordirects complaint to the school board’sHealth and Safety Officer (HSO);

• depending on the nature of the problem,the HSO may consult with school boardofficials responsible for plant operations;

• when a complaint comes from a student orparent, the Public Health department maybecome involved; this could involve anindependent inspection and, in turn, ordersbeing issued by the medical officer of health;

• if necessary, the HSO conducts a siteinspection and orders air quality testing;the Ontario Ministry of Labour may alsoconduct an inspection if a complaint ismade by staff; and

• recommendations are made to the principal.

Some school boards employ proactive measuresto address indoor environmental problems.Some examples include: the Durham DistrictSchool Board has developed a passive air supplysystem to improve ventilation; the former MetroToronto School Board developed a ProductAssessment Matrix for purchasing low emissionproducts; the Waterloo Region District SchoolBoard uses indoor air quality as a criteria forpurchasing products; the Toronto Catholic

District School Board surveys school occupantsfor environmental health symptoms; the HaltonDistrict School Board issues regular bulletins onindoor air quality to teachers and occupants;and, the Lakehead District School Board hasdeveloped an indoor air quality guide (seeAppendix 3 for some examples of healthyschools initiatives; see Section 6.0 for moreDurham and Waterloo initiatives).

While some school boards are clearly takingsteps to improve indoor environmental quality,there is great inconsistency from one schoolboard to the next in the way in which indoorenvironmental problems in schools are handled.The degree to which schools and school boardsaddress indoor environmental challengesdepends on how aware they are of the issues,their priorities, and the availability of resources.In 1998, a Master’s student at the University ofCalgary surveyed 293 school systems acrossCanada on issues related to indoor air quality inschools and found the following:

• a general lack of familiarity with indoorair quality issues;

• insufficient commitment from schooladministration and Departments ofEducation to provide leadership and thenecessary resources (funding, skills,equipment, and technology) to addressindoor air quality effectively;

• lack of communication between the schoolsystem and the public, and between schooladministration and staff;

• inadequate provisions for training staffabout the causes of poor indoor air qualityand the ways their actions might have animpact on air quality;

• limited indoor air quality-relateddocumentation required for evaluationpurposes;

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• lack of a system to measure indoor airquality so that assurance can be providedto stakeholders about the quality of air inschool buildings; and,

• a tendency to rely on the reactive approachwhich often leads to having to deal withemergency situations.53

In Ontario, although school boards haveresponsibility for providing children with a healthylearning environment, they are consumed withfinancial difficulties related to the new fundingformula and with more immediate concerns, suchas school board amalgamation. Indoor air quality islow on the priority list when compared with budgetcuts and amalgamation restructuring. Hence, thedevelopment of a proactive strategy for dealingwith indoor environmental issues in Ontarioschools is not receiving the attention that is needed.An indoor environment management plan wouldaim to make this issue more visible by building onthe current leadership of some school boards andproviding cost-effective, proactive strategies forimproving the indoor environment. Moreover,with growing public concern about theenvironmental safety of schools, a proactive plan toaddress indoor environmental quality would helpto build trust between school boards and parents.

5.4 Public Perceptions andConcerns

This section draws on the conclusions of amedia analysis that Pollution Probe conductedon indoor environmental issues in Ontarioschools (refer to Appendix 4 for full mediareport). The purpose of the media analysis wasto better understand what information the publicreceives on indoor environmental problems andhow the media documents public reaction tothese issues. The analysis was based on 118media clippings gathered from daily newspapersin Ontario during the period 1996−1999.

As the Regional Chair of Halton stated, “It doesn’tmatter if a problem is perceived or whether itexists; what matters is that parents have the peaceof mind that when they send their children toschool, they are as safe as they can be.”54 Sincethe recent emergence of mould-related problemsin portable classrooms, particularly in the Haltonand Peel districts, parental anxiety about thesafety of schools is on the rise. The number ofcases of mould-related illness and portableclassroom closures is growing; a sense of publicfear and urgency is being expressed in themedia. Many factors, including the media, haveinfluenced the way the public perceives thisissue. Public perception is important, as it willinfluence the way in which governments andschool boards deal with the problems.

Although there are several factors that affect thequality of indoor environments in Ontario schools,mould is the issue about which parents arecurrently most concerned. This is due, in part, tothe attention it has received in the media. Thecontroversy and uncertainty of the way thatmould impacts children’s health has helped fuelthe “newsworthiness” of the story. Initially, whenthe issue of mould in portables arose, the lack of adefinitive conclusion on the health effects ofexposure resulted in differing reactions to theissue by the Public Health Units in Ontario. Aswell, the issue involves conflict between parentsand school boards; heated debate among expertson health risk; sick children; and inaction by thegovernment. All of these factors create the kind ofstory that attracts media attention.

As the Regional Chair of Haltonstated, “It doesn’t matter if aproblem is perceived or whetherit exists; what matters is thatparents have the peace of mindthat when they send theirchildren to school, they are assafe as they can be.”

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It is interesting to look at the difference in theway that the media handled the asbestos issueduring the same period. Although asbestos isdeemed a carcinogenic substance by the medicalcommunity, and is still considered a problem inHamilton, Burlington and Oakville schools,fewer articles were written on the subject, thereporting tone was much more even and thehealth factor was less of a feature. Even thoughthe evidence for health risks to children fromasbestos is clearly documented, the stories wereconsidered less newsworthy. Since the issue ofasbestos has been around for more than adecade, there is no debate or controversy in themedical community on the health risks, there areprotocols in place to deal with the substance, andthe government is involved in monitoring its useand disposal. The story has lost its sensationalappeal. In fact, the transparency and openness ofprocess that have developed around the issue ofasbestos have helped to foster trust between thecommunity and the school boards. The Hamilton-Wentworth school board has invested a lot of timeinto their “model” asbestos abatementprogramme, which has helped to shift mediaattention away from school boards in regard toasbestos. Hence, current public distress andoutrage about asbestos are considerably less thanthey are for mould.

The way in which this issue has been reported bythe media, along with the lack of co-ordinatedresponse to the problems, has left parents feelingvulnerable and confused. The provincialgovernment will not take responsibility for theproblem because the science is not clear. Eachschool board is dealing with the situation in a

different manner. Some school boards areconducting invasive testing of portables, whileothers are doing visual inspections. Some schoolboards are decommissioning portables, whileothers are doing renovations. This sends mixedmessages to parents, and reduces their confidencein the decision makers who are responsible forkeeping their children safe. The Ontario Ministryof Health and Long-Term Care made efforts toexamine the controversy surrounding mould byinitiating an Expert Panel on Fungal ContaminationIndoors. This panel developed a framework foraction which, if followed, will result in a moreuniform response by medical officers of health tofuture mould issues.

The public perceives mould as a significant healththreat to children. They will continue to seemould as a problem until there is a co-ordinated,proactive response to the issue. The mould issuehas also opened the door for more discussion anddebate on the variety of indoor contaminants thatexist in a child’s learning environment. As thepublic becomes more informed, proponents willcontinue to advocate for healthier indoorenvironments with determination. As problemsescalate, the media will continue to report thestories that reflect and fuel parent anger. Thishappened in Nova Scotia and led, in part, toprovincial action on indoor environmental issues inschools (see Section 6.1.2 for more on NovaScotia). Parents can greatly influence the actions ofdecision makers in government and schoolboards. Whether it is crisis management later, orproactive programmes now, governments andschool boards will be called upon to address thepublic’s fears about the safety of school facilities.

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6.0 Jurisdictional Leadership

Historically, the Ontario government has takenlittle responsibility for indoor environmentalissues in schools. Recently, the Ministry ofEducation has stated that it will be facilitatingworkshops in the near future to assist schoolboards in mould management; as well, it isplanning to work with the Ministry of Health todevelop indoor air quality guidelines forschools.55 Other jurisdictions have shown moreleadership in this area, and their efforts provide agood framework for Ontario-based action. Forexample, New Brunswick has developed low-emission product purchasing criteria for schools,issues educational newsletters to parents andrequires regular duct cleaning in schools.56 TheWorkers’ Compensation Board of BritishColumbia has recently enacted indoor air qualityparameters within the Occupational Health andSafety Regulation that affect the schoolenvironment.57 The Nova Scotia government isdrafting indoor air quality regulations and hasdedicated staff to help school boards address theirproblems (see Section 6.1.2 for a full discussionon Nova Scotia). In the U.S., the EPA and thestates of Texas, Washington, Maryland andVermont have developed guidelines, programmesand legislation to improve indoor environmentalquality in schools.58

In 1995, the U.S. EPA developeda national voluntary programmeto address indoor air quality inschools. Entitled Indoor AirQuality Tools for Schools ActionKit, this programme has beentouted as one of the bestprogrammes in North America toaddress indoor air qualityproblems in schools.

As mentioned previously in Section 5.3, severalOntario school boards are also showing leadershipin this area. School boards in eastern Canada areparticularly active. The Saint John School BoardDistricts Six and Eight have implemented scent-free, pesticide-free policies, as well as initiativesaddressing ventilation problems.59 The AnnapolisValley Regional School Board in Nova Scotia has acomprehensive preventative maintenanceprogramme and protocols for assessing cleaningproducts.60 The Halifax District School Board hasjust completed a draft scent-free policy for itsschools.61

The level of awareness and action in somejurisdictions is markedly higher than in others.Understanding the reasons behind this will helpto inform a strategy for the Ontario governmentand school boards to take action. It is useful tounderstand what motivates some jurisdictions totake action on indoor environmental issues inschools, what factors influence their decisions,what issues present barriers to progress, and howtheir actions achieve results. The followingsections consider these questions, and others, inrelation to efforts by two governments and twoschool boards. These case studies provideinsight into the factors that encouragejurisdictions to become proactive.

6.1 Government Leadership

6.1.1 U.S. Environmental Protection Agency

In 1995, the U.S EPA developed a nationalvoluntary programme to address indoor airquality in schools. Entitled Indoor Air QualityTools for Schools Action Kit (IAQ Tools forSchools), this programme has been touted as oneof the best programmes in North America toaddress indoor air quality problems in schools.62

As well, the Consumer Research Council, in co-operation with the EPA, has drafted modellegislation on indoor air quality in schools. The

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Consumer Research Council will now beencouraging state and local governments toadopt this legislation.

IAQ Tools for Schools aims to help schooloccupants identify, prevent and remediate indoorair quality problems through step-by-stepinstructions, checklists, an indoor air qualityproblem-solving wheel and a video.63 While theEPA would like to deliver this programme in all110,000 schools in the country, the EPACongressional mandate is to have 16,500 schoolsimplement IAQ Tools for Schools by 2005. Todate, the EPA has invested $485,000 forprogramme development and $1.5 million forimplementation.64

The programme is based on the followingprinciples:

• The expense and effort required to preventmost indoor air quality problems is muchless than the expense and effort requiredto resolve problems after they develop.

• Educating school staff and students aboutthe factors that create them can preventmany indoor air quality problems. Whenindoor air quality problems do arise, theycan often be resolved using skillsavailable in-house.

• If outside assistance is needed to solve anindoor air quality problem, the best resultswill be achieved if school officials areinformed customers.65

The programme requires a dedicated indoor airquality co-ordinator in each school to act asleader for the indoor air quality team. The indoorair quality team consists of teachers, students,parents, administrative staff, facility operators,custodians, health officers, school boards, contractservice providers, and local news media. Theprogramme kit provides each team member withbackground information and easy-to-followactivities that will help them prevent and resolve

indoor air quality problems (see Appendix 3 forsample action list). The kit also provides step-by-step instructions on how to develop amanagement plan, including procedures forassessment and identification, repairs andupgrades, monitoring, indoor air quality policies,education and reporting. As well, the proposedmanagement plan structure is flexible so thatschools can tailor it to their own needs.

The EPA has shown great leadership on indoorair quality in schools and has committed asignificant amount of time and resources todeveloping and implementing IAQ Tools forSchools. The EPA began taking action on thisissue due to the findings of a national schoolfacilities study conducted by the U.S. GeneralAccounting Office (GAO) in February 1995.66

Due to factors such as deferred maintenance andventilation problems, the study claimed that abouthalf of America’s schools experienced poorindoor environmental quality. The public was alsoinstrumental in encouraging government action;the volume of indoor air quality complaints fromparents and school occupants prompted thegovernment to conduct the study, which led to thedevelopment of their programme. The desire toimprove public relations was a significantmotivator for the EPA’s actions on this issue.67 Bytaking steps to address the problems, the U.S.government demonstrated to the public that it wasdoing its best to protect children from the potentialhealth risks associated with poor indoor air quality.

The EPA used health and economic messages topromote the programme and relied heavily onexternal partners for implementation. It focusedon the fact that asthma-related deaths amongchildren aged 5 to 24 had doubled between 1980and 1993, and that indoor contaminants wereprimary culprits in causing and/or exacerbatingasthmatic symptoms. Since most Americanschools experience budgetary constraints, it wasimportant for the EPA to include low- or no-costsolutions in its programme. In addition, the EPAmarketed the programme on the idea thatparticipating schools could prevent expensive

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investigation and remediation, lower heating andcooling costs, and reduce the potential for liability.

The EPA partnered with several organizationsand other government agencies to assist inoutreach and implementation. It held ongoingtrain-the-trainer sessions with the AmericanLung Association, National Education Association,American Association of School Administratorsand the National PTA. As well, it secured anInteragency Agreement with the U.S. Departmentof Agriculture for community educators to assist inpromoting the programme. Three training moduleshave been produced for the participating schoolsand for partner organizations — one full-daypresentation, one half-day presentation, and one45-minute presentation.

The biggest weaknesses with IAQ Tools forSchools are related to monitoring and follow-up.The programme lacks a mechanism by which theEPA can assess the extent to which the schoolsare utilizing the tools. Moreover, the EPA doesnot know how beneficial it has been for schools,or whether indoor air quality has improved. InJanuary 1999, the EPA commissioned theConsumer Federation of America Foundation toconduct focus groups with teachers,administrators and facility managers to betterunderstand the incentives for and barriers toparticipation. Some of the key findings from thestudy included the following:68

• Lack of awareness of indoor air quality wasa significant barrier to implementation.Conflicting awareness was also seen as aproblem; i.e., educators/administrators hadlimited knowledge of indoor air qualityissues but believed they caused healthproblems; facility managers had moreknowledge of the issues but were lesslikely to believe that poor indoor airquality was a health risk.

• Due to competing priorities and lack ofresources, more solid evidence is neededof the link between indoor air quality and

student achievement, attendance, andhealth before indoor air quality will bemoved up the priority list.

• More sectors need to be included toencourage implementation (i.e., PTAs,health and safety committees, maintenanceengineers, and school administrators). Inaddition, parents need to be utilized as thedriving force for the programme.

• Mandating indoor air quality in schoolsmay be more effective than encouragingvoluntary initiatives due to competingpriorities.

To assess the programme’s effectiveness, inSeptember 2000 the EPA will conduct a surveyof 16,500 schools that are participating in theprogramme. This will help to further identifyareas for improvement and to determine futurestrategies for promotion and implementation.

6.1.2 Nova Scotia

Nova Scotia is one of the most active jurisdictions inCanada on issues related to indoor environmentalquality in schools. It is investing resources into thisarea, encouraging voluntary strategies, and draftingindoor air quality regulations for public buildingssuch as schools and libraries.

Below is a list of the government’s past andcurrent efforts in this area:69

• Recently hired an Environmental Health andSafety Co-ordinator who works with schoolboards to address issues related to indoor airquality in schools;

• Developed an indoor air quality complaintresponse protocol for school boards;

• Purchased equipment for each school board(“Indoor Air Quality Detective”) that measuresparticulates as small as .02 microns in size;

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• Currently piloting the EPA’s IAQ Tools forSchools programme in two schools andconsidering it for province-wideimplementation;

• Using the Indoor Air Quality Detective toestablish a baseline of particulate levels inall schools;

• Building new schools in the provinceaccording to “healthy school” guidelines,which include specifications for ventilation,filtration of air and ecological productpurchasing;

• Requiring new schools to undergo anenvironmental preoccupancy review todetermine the environmental safety of theschool;

• Building ECO (environmentally controlledopportunity) classrooms in some schooldistricts as part of a new school constructionproject;

• Advising consultants and designers onindoor air quality considerations for newschool construction; and,

• Drafting indoor air quality regulations fornon-industrial workplaces that address thefollowing: ventilation standards, design anddocumentation, HVAC maintenance andoperation, building maintenance and upgrades,exposure control for airborne hazardoussubstances, communication, complaintprocedure and investigations, and education.

The Nova Scotia government began addressingthe quality of indoor environments in schools as aresult of school closings associated withcontaminants in the school environment.70 Mouldwas the primary problem, due to structuraldeterioration of the facilities and associateddampness. While school closings prompted thegovernment to become more proactive, otherfactors were also influential.71 The media were

critical in holding the government’s attention onthe issues. The policy-makers could not ignore thenumber of news reports on problems associatedwith indoor air quality in schools. As well, externalstakeholders played a key role in encouraginggovernment action. Particularly influential were thelocal non-profit organization — Citizens for aSafe Learning Environment (CASLE), electedschool board members and the teachers’federations. The fact that these groups were wellinformed and had the ability to speak technically(as opposed to emotionally) helped incite thegovernment to action.72

Initially, the government sought scientific,medical evidence of the causal relationshipsbetween indoor contaminants and children’shealth. When they found that the evidence wasunclear, however, this did not prevent them frommoving forward with their programmes. Otherfactors became important in determining theiractions, such as teacher and student complaints,and occupant discomfort in the classroom.73 Aswell, the way in which the Environmental HealthCo-ordinator at the Department of Educationinterprets the Occupational Health and Safety Acthas a bearing on the government’s response to thisissue. The act provides adults with protection fromhazards in the workplace. The EnvironmentalHealth Co-ordinator considers poor indoor airquality as a hazard under the act and addresses itin the same manner as he does any otherworkplace hazard. When poor indoor air quality isacknowledged as a potential hazard, actions aretaken that benefit the health of staff and students.

Nova Scotia is one of the mostactive jurisdictions in Canadaon issues related to indoorenvironmental quality in schools.It is investing resources intothis area, encouraging voluntarystrategies, and drafting indoorair quality regulations for publicbuildings such as schools andlibraries.

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Once Nova Scotia’s draft Indoor Air Qualityregulation becomes law, school occupants willhave more protection from indoor environmentalhazards than they currently have under theOccupational Health and Safety Act.74 While thisregulation is a good effort towards improvingindoor air quality in non-industrial buildings, itdoes not take into consideration the vulnerabilityof children or those with environmentalsensitivities.75 As with the Occupational Healthand Safety Act, this regulation is largely concernedwith workplace conditions for healthy adultemployees. Nonetheless, when passed, it willmark a move forward on improving indoorenvironments in Nova Scotia.

Taking steps to address indoor environmentalquality in schools has had public relations andeconomic benefits for the government and theschool boards.76 Having programmes and protocolsin place to address indoor air quality complaintshas helped to reduce occupant anxiety and promotegood relations among stakeholders in the schoolcommunity. In some cases, teachers, students andstaff are more patient with government and schoolboard officials than they were previously, knowingthat these officials are committed to the issues anddoing the best that they can. While the healthbenefits are difficult to measure, the governmentattests to the economic benefits associated withtheir efforts. During the school closings severalyears ago, the government experienced significantfinancial losses. Therefore, preventing schoolclosings is one of the key economic benefits. Aswell, the government’s actions have achievedreductions in the costs associated with remedialwork and equipment replacement. It once costthem $97,000 to clean up a spill from a leakingoil tank in a school.77 A more rigorouspreventative maintenance plan would have likelyprevented this crisis.

The Nova Scotia government has takensignificant steps to remediate and prevent indoorenvironmental problems in schools. Witheffective encouragement from external partners,

it now acknowledges poor indoor air quality as ahealth hazard to children and is committingresources to finding solutions. Preventing indoorair quality crises motivates the government tocontinue its efforts.

6.2 School Board Leadership

6.2.1 Waterloo Region District School Board

One of the most well known indoor air qualityinitiatives of the Waterloo Region District SchoolBoard is the environmentally controlledopportunity (ECO) classroom for children withenvironmental sensitivities. The ECO classroomis designed and maintained to minimize studentexposure to indoor contaminants.78 For example,some of the elements of an ECO classroom are:concrete floors, low emission paint, sealed ceilingtiles to minimize dust, white boards with water-based markers, windows that open, cork boardswith low emission adhesives, an independent airmanagement system that includes filtration andair exchange, and solid wood or steel furniture.The cost of building an ECO classroom into anexisting school is approximately $40,000 –$50,000. However, when incorporating an ECOclassroom into a newly built facility, the cost isestimated to be between $10,000 and $20,000.79

The Waterloo Board has implemented four ECOschool programmes at the elementary level andtwo at the secondary level. ECO classrooms arebeing built in new schools when enrolment ishigh and a need is identified in the community.Although no formal studies have been conducted,ECO classroom children appear to do better(based on health, behaviour and academicperformance) in these classrooms than they hadpreviously in regular classrooms.

Beyond the ECO classroom, the Waterloo Boardis taking additional steps to address indoorenvironments in schools. Below are some

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examples of the activities of the PlantOperations department that result in betterindoor environmental quality:80

• Bases building practices, in part, on indoorair quality concerns, complaints andsensitivities;

• Strives to exceed standards set by law andby the manufacturer;

• Practices good maintenance of portablesand school buildings;

• Builds new schools at high standards forindoor air quality (i.e., hard surface flooring,low emission paints and constructionmaterials, windows that open, centralized airmanagement systems with filtration);

• Provides ongoing education, awarenessand training on indoor air quality foroccupants and building operators;

• Actively searches for and tries alternativeproducts that are considered less of aproblem for environmentally sensitivechildren;

• Uses unscented commercial cleaners andhydrogen peroxide-based cleaningproducts when possible;

• Uses a chemical dispensing system foraccurate measuring of cleaning solutions;

• Restricts the use of some chemicals andactivities to times that will result in theleast exposure to students;

• Supplies extra rinse after using chemicalsto eliminate residue (in some cases);

• Will soon use non-treated mops;

• Continues to work with better filteredvacuums;

• Tests and experiments with water-basedproducts;

• Provides good ventilation and air filtration(with hepa filters and activated charcoalcompounds) during renovation;

• Monitors VOC levels during painting;

• Requires roofing contractors to useequipment with an after burner that willdecrease odours and VOCs;

• Monitors construction and renovation sites toensure that codes of practices are followed;

• Puts pressure on suppliers to developproducts that don’t adversely affectchildren with environmental sensitivities;

• Conducts regular in-house testing of CO2

to determine ventilation rates;

• Takes into account indoor air quality inenergy efficiency initiatives;

• Considers new innovations seriously andalways looks for new designs and ways toimprove their facilities; and,

• Upgrades lighting (board wide) fromfluorescent to better quality and energyefficient choices.

While the Waterloo Region District SchoolBoard is one of the most proactive school boardsin Ontario on indoor environmental quality, it has

One of the most well knownindoor air quality school boardinitiatives is the WaterlooRegion District School Board’senvironmentally controlledopportunity (ECO) classroomfor children withenvironmental sensitivities.

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no explicit policies or directives in this area.Consideration for students’ environmental healthseems to be ingrained into the culture at theboard and the way in which it does business.The ECO classroom programme and the outlookthat led to its development have driven thecurrent attitude at the board.81

In the 1980s, a number of children in the WaterlooRegion were unable to attend school due to health-related problems. When away from the schoolenvironment, the children performed better and, asa result, many stayed at home for their schooling.82

In their search for answers to these children’sproblems, the school board held several forumswith doctors and experts from across NorthAmerica on the topic of body chemistry andbehaviour. The presentations helped the board andthe community to understand that certainenvironmental factors could modify body chemistryin some individuals, which could affect anindividual’s health and their ability to think, feel,behave and perceive their environment.83 Alongwith the awareness created by the lectures, otherfactors helped to advance the development ofthe ECO classroom. These included: a deepcommitment by the board to respond to theneeds of school children; open-mindedness onthe part of the board to explore the connectionbetween environment and learning; dedicationand awareness of the school administrators andspecial education staff; and persistence of theparents.84 Today, these factors continue to shapethe attitude of the board and the schoolcommunity at large.

The attitude towards learning and indoorenvironmental quality is particularly evidentwithin the Plant Operations department at theWaterloo Board. The activities listed abovedemonstrate how plant personnel consider theimpacts of their practices. Indoor environmentalquality, however, is only one of many elementsthat drive their codes of practice.85 Cost,durability and the law also determine how plantpersonnel do business. They are constantlybalancing these factors with student exposure to

contaminants. For example, some teachers andparents want the board to clean entire schools (notjust the ECO classrooms) with vinegar and wateror hydrogen peroxide-based cleaners only. Whilevinegar can be effective, a job that takes fiveminutes with a commercial cleaner takes half anhour with vinegar — a significant resourceconsideration. Hydrogen peroxide cleaners donot meet the legal definition of a germicide,which plant personnel believe is necessary forhigh germ areas such as bathrooms. Instead, theyconsider other measures that will reduce studentexposure, such as scheduling maintenance workat times when school occupants are not present,using a chemical dispensing system for accuratemeasuring of cleaning solutions, providing anextra rinse to eliminate residue, and using non-scented commercial cleaners. By actively workingto find solutions, they gain the confidence of theschool occupants, making it easier to do their joband improve indoor environmental quality.

The Plant Operations personnel consider whatthey are doing as “baby steps” in the rightdirection. They claim that good indoor air qualityis often an offshoot of their commitment to long-term planning and life-cycle costing. Investing ingood quality equipment and doing regularmaintenance helps them save money and improveindoor environmental quality. They claim thatbetter technology and products would make iteasier for them to continue their efforts. Supportand encouragement from the board environmentalofficer and ECO classroom co-ordinator helps tokeep their momentum going. It takes time tochange 30 years of ingrained practices and to train500 custodians on environmental health issues.The awareness created by the ECO programme,along with political support from the top, keepsthem moving in the right direction.

6.2.2 Durham District School Board

The Durham District School Board has takenseveral steps to prevent and address some of theproblems it encounters related to the indoorenvironment. In particular, it has been, and

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continues to be, proactive in finding solutions toaddress mould. Below is a list of the board’spast and current efforts in this area.86

• Have conducted routine airborne fungalsampling of classrooms and portables since1991;

• Recently formalized an indoorenvironmental quality procedure, includinga process by which complaints are handledpromptly, responsibilities are clearlyassigned and lines of communication aremaintained;

• Produced a ventilation guide for portables;

• Reviewed products in art supplies andbanned those considered toxic (e.g., ceramicglazes that contain lead), and providededucational workshops to art teachers;

• Developed a passive air supply system toimprove ventilation in older schools (seeAppendix 3);

• Currently developing a guide to recognize andmanage indoor microbiological agents,including the following preventative measures:• limit carpeting in new schools and

additions• remove carpets and replace with vinyl tile

in old schools• inspect portables annually• caulk portables biannually• replace old style exhaust fans in portables

with better ventilation systems;

• Providing training courses for chiefcustodians on mould identification;

• Purchasing new portables (as needed) withdesign features that include wider roofoverhangs and individual ventilation systems;and,

• Communicating all activities andexpectations to school occupants.

Two factors that have been key in advancing theDurham Board’s efforts to improve indoorenvironmental quality are awareness and internalpartnerships.87 Much of what the board does isprecipitated by recognition that poor indoor airquality can affect the health, productivity andcomfort of the students and staff. Health andsafety officers need to understand the issues ofenvironmental health in order to considercomplaints within the context of indoorenvironmental factors; teachers need to know theimpact of indoor contaminants on health to beable to accurately assess a student’s symptoms;facilities people must understand how theirpractices affect occupant health before they canconsider alternative practices; and senioradministrators need to understand the issues inorder to support the efforts of their staff. Whileeducation and awareness have been important,internal partnerships have also been critical forimproving indoor environmental quality. TheHealth and Safety department works closely withFacilities Services to find solutions to theproblems. Facilities Services and Health andSafety have support from the top in order to puttheir ideas into practice. Support from theteachers’ federation and the Joint Health andSafety Committee also help to move theinitiatives forward.

The Durham District School Boardhas long-standing mould protocolswhich have helped them assuage thefears of staff and parents sparkedby the recent media reports onmould. Much of what the boarddoes is precipitated by recognitionthat poor indoor air quality canaffect the health, productivity andcomfort of the students and staff.

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The barriers that the board faces to implementinginitiatives are largely related to time and resourceconstraints. Fostering awareness of environmentalhealth and developing partnerships takes patienceand time. The board begins with small projects(which lead to bigger undertakings), buildsinternal alliances, understands fiscal restraints andis flexible.88 These strategies are evident in thedevelopment of the board’s passive air supplysystem. Occupants of some schools wereexperiencing a significant number of healthsymptoms related to poor indoor air quality.When investigated by the Health and Safetydepartment, it was found that these schools hadhigh CO2 levels and were under negative pressure(not enough air was coming in to replace theoutgoing air). The challenge for the staff was toimprove the ventilation in these older schools,while also considering the fiscal constraints of theboard. Implementing a full mechanical ventilationsystem would have cost anywhere from $100,000to $500,000 for each school, which was financiallyprohibitive. Facilities Services worked withHealth and Safety to resolve the problem. Theflexibility and innovation of the plant supervisor

resulted in the development of the passive airsupply system — an alternative that cost only$5,000 per unit. Complaints were greatly reducedand occupant confidence in the board increased.

While the board has not actively measured theimpact of its actions, school occupants and boardstaff have noted several benefits.89 Teachers arenoticing marked improvements in student healthand attendance in classrooms where carpets havebeen removed. By taking steps to address indoorenvironmental quality, officials in the Health andSafety department and in Facilities Services aregaining credibility in the school community.Credibility enables them to manage indoorenvironmental concerns with simple, quick andeffective solutions in a non-confrontationalmanner. For example, long-standing mouldprotocols have helped them assuage the fears ofstaff and parents sparked by the recent mediareports on mould. In the end, all of the efforts haveled to greater awareness of the issues and increasedconfidence in the board’s ability to prevent andaddress problems.

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7.0 Cost/Benefit Analysis Framework

School board officials cite cost as one of theirbiggest concerns with respect to making indoorenvironmental improvements in schools. However,rarely taken into consideration are the potentialcost benefits of preventing or addressing indoorenvironmental problems. There are times when thefinancial benefits of investing in good equipmentor practicing preventative maintenance areconsidered with respect to long-term operatingcosts. However, the financial benefits to society ofimproved health of school occupants from betterindoor air quality are not being given the attentionthey deserve. The long-term impacts on health andlearning due to indoor air pollution in schools, andthe potential associated health care costs, are poorlyunderstood at the present time. To gain a betterunderstanding of the societal costs and benefits ofimproving indoor environments in schools, acomprehensive cost/benefit analysis is needed.

The use of cost/benefit analysis for determiningoptimum outdoor air quality has gainedconsiderable acceptance over the last 10 years.A cost/benefit analysis done in 1997 for theCanadian Council of Ministers of theEnvironment showed that a 50% reduction inSO2 emissions in eastern Canada and the U.S.could save between $500 million and $5 billionannually in avoided health costs in Canada.90

The acceptance of cost/benefit analysis nowneeds to be broadened to include examinationof indoor air quality problems.

This section describes the basic concepts ofapplying a cost/benefit analysis framework tothe issue of indoor air quality in schools, theinformation gaps and deficiencies that wouldimpact its application, and strategies forovercoming any limitations. The informationpresented below is summarized and excerptedfrom an analysis prepared by Edward Hanna forPollution Probe entitled Cost/Benefit AnalysisFramework: Economic Issues Associated with

Indoor Air Quality in Schools. For a complete,detailed analysis, please refer to Hanna’s report.

7.1 Applying a Cost/BenefitAnalysis Framework

Making responsible, informed decisions thataffect indoor air quality in schools requiresconsideration by governments and school boardsof both the costs (i.e., investments required toimprove indoor air quality) and benefits (i.e.,improved health and learning abilities of schooloccupants) of a particular design, construction,operation, or maintenance option for a school.Ideally, indoor air quality in schools should bemaintained at a level that yields the optimum netbenefits to society. These benefits include:

• improved learning and retention ofknowledge by students;

• improved physical and mental health ofstudents, teachers and support staff;

• reduced costs (both direct and indirect) oftreating air quality-induced illnesses; and,

• reduced costs resulting from absenteeismand reduced productivity.

In concept, determining the optimum indoor airquality for schools is relatively straightforward.Estimate total benefits (of two or more options);subtract costs; make an allowance for risk,uncertainty and fair distribution of benefits andcosts; and, choose the best solution (seeAppendix 5 for an illustration of the cost/benefitframework). While the concept may be relativelystraightforward, putting it into practice is quite adifferent thing. As is often the case with manyenvironmental problems, preventive, mitigativeand/or rehabilitative costs are relatively welldefined, readily available, accurate and precise.Quantification of benefits, on the other hand, is afrequent and often substantial “weak link” in the

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evaluation and resolution of environmentalproblems. This is certainly the case when tryingto assess the net benefits of improved indoor airquality in schools.

The costs of improving indoor air quality inschools can be estimated with reasonableaccuracy and include:

• changes in chemicals and maintenance/cleaning practices;

• changes in building design;

• changes in HVAC systems; and,

• changes in equipment and furnishings.

Such analyses are typically supported by anextensive information and knowledge baserelating to standard engineering cost componentsand data. In many discussions of environmentalproblems, the emphasis is on these types of well-defined costs while benefits become almostsecondary due to their somewhat nebulous,unquantifiable and undervalued nature. Benefitsof improving indoor environmental quality are, infact, cost savings due to reduced health impacts.Estimating benefits requires comparing theindoor air quality-induced health effects costs ofone option vs. another (i.e., comparing the costsof health effects associated with the use of lowemission cleaning products vs. highly volatilecleaning products). The net savings is thepotential benefit society would realize by

implementing one option over another. Toaccurately estimate benefits, it is necessary to beable to forecast the indoor air quality of aparticular option and the concomitant healtheffects on school occupants. These are twoessential aspects of the benefits assessmentframework for which significant informationgaps need to be addressed.

7.2 Information Gaps andDeficiencies

Predicting the indoor air quality that will resultfrom choosing a particular option is complex.This is due to: 1) the number of pollutants ofpotential concern, some of which have highconcentrations in indoor environments; 2) varietyand number of emission sources; 3) variableemission rates and patterns over time; 4) complexpollutant circulation patterns within a building;and 5) variations in the rate of pollutant removal.In addition to these complexities, another majorconsideration is the lack of long-term monitoringdata for virtually all indoor environments. Thislack of data is partly due to the absence of clearlydelegated administrative responsibility within thegovernment for managing indoor air quality. Incontrast to outdoor air quality, no provincial-levelmonitoring network is in place for indoor airquality. Tools for forecasting indoor air quality arenot available for the current range of buildingtypes and the majority of pollutants of concern.Building designers have, in some cases, used cruderelationships, like air exchange rates and thepresence/absence of known sources of indoor airpollutants, as a basis for making gross forecastsof “good” or “bad” indoor air quality. Rectifyingthis deficiency is critical to optimally improveindoor air quality in schools. The informedevaluation of options demands that each optionbe analyzed in terms its associated expectedindoor air quality. Such forecasts are notundertaken at the present time.

Predicting the health effects that will result fromexposure to indoor air pollutants is another major

Making responsible, informeddecisions that affect indoor airquality in schools requiresconsideration by governmentsand school boards of both thecosts (i.e., investmentsrequired to improve indoor airquality) and benefits (i.e.,improved health and learningabilities of school occupants).

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component of the benefits assessment thatpresents complexities. Two basic researchmethodologies are commonly used to make suchpredictions — epidemiological methods andclinically controlled tests and studies. Withrespect to indoor air pollution exposure,epidemiological literature relating to healtheffects is virtually nonexistent. Where suchliterature does exist, it generally involves officebuildings and impacts of broad air qualityparameters, such as air exchange rates, on workerproductivity. Nothing comparable exists forschools and the health effects of indoor airpollution on students, teachers and staff. Only byrelying on large samples of individuals cansufficient statistical power be obtained to detectsubtle health effects resulting from poor indoorair quality and the relative contribution ofindividual environmental factors to these effects.

Clinical studies offer some insight intopredicting the potential health responses toindoor air pollution exposure, but they also havetheir drawbacks. Typically, clinical studiesexamine the impact of one pollutant on a smallsample of individuals and track short-termphysiological responses to the exposure. Clinicalstudies generally have difficulty dealing withmultiple risk factors and, in this particular case,dealing with exposure to complex mixtures andconcentrations of pollutants. Nonetheless, forthe clinical studies that do exist, the benefitassessment framework provides a comprehensiveand technically sound context within which toapply the results of these studies. However, evenwhere such results are rigorously and prudentlyapplied, there can remain considerable doubt asto their validity at a population level (as opposedto individual patient level) without corroboratingpopulation-level evidence.

7.3 Mitigating Strategies

In order to implement an ideal cost/benefitanalysis, the information gaps need to beaddressed with respect to forecasting indoor air

quality and estimating health responses. Routinemonitoring of indoor air quality in schools needsto be initiated throughout each school system (orat minimum, a representative group of schools)so that reasonable characterization of indoor airpollutants, their concentrations and variationsdiurnally, weekly and seasonally can be reasonablydetermined. As well, quantitative emission factorsfor key pollutants of concern need to be developedso that reasonable forecasts of indoor air qualitycan be derived based on the design, construction,operation and maintenance features of schoolbuildings. With respect to health responses,systematic epidemiological and clinical healthstudies of the impacts of indoor air contaminantson school occupants should be initiated. As part ofthese studies, primary pollutants of concern andcombinations of pollutants need to be identified.

Addressing the information gaps associated withdoing a comprehensive cost/benefit analysis is achallenging and important undertaking that willrequire a considerable amount of time andresources. Given the importance of cost/benefitanalysis in responsible decision making,consideration should be given to immediatelyconducting a cost/benefit analysis based on thebest available data and the knowledge of healthexperts, architects, engineers and school boardplant managers. The existing provincial stock ofschool buildings could be categorized based onthe key design, construction and maintenancefactors known, or suspected, to strongly affectindoor air quality. For each building category,forecasts of the health and economic benefits ofimproved indoor air quality could be prepared.Forecasts of health responses could be madeusing existing clinical studies. Although theaccuracy of these forecasts will be limited, theywill, nonetheless, be better than what can beexpected in the absence of such a systematicapproach.

The optimum (i.e., most beneficial) level ofindoor air quality in schools is the target towardwhich every school board, as well as theprovincial government, should be striving. A

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cost/benefit analysis of improving indoor airquality in schools could help achieve that targetby providing information that would helpgovernments and school boards make informeddecisions. Cost/benefit analysis should beviewed as an effective decision support tool;responsible decision-making still requires thatjudgment, ethics and insights come into play.

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8.0 Proposed Framework for an Indoor Environment Management Plan

8.1 Rationale

The long-term goal of Pollution Probe’s HealthySchools — Healthy Children project is to developstrategies to help schools and school boardsidentify, prevent and remediate indoorenvironmental problems. This section outlines aproposed framework for a plan that aims to helpoptimize the quality of school indoorenvironments. During the next phase of PollutionProbe’s Healthy Schools — Healthy Childrenproject, school boards and other stakeholders willbe consulted more extensively to build upon theideas presented here.

Moving forward with a proactive, voluntary indoorenvironment management plan for Ontario schoolsis important at this time for several reasons:

• Evidence suggests that indoor pollutants arethe most important source of risk to therespiratory health of children. They can haveserious health effects on children with pre-existing health problems, such as asthma,allergies and environmental sensitivities.

• Children spend approximately 90% of theirtime indoors and about five to six hours ofevery weekday inside of a school. The timethat children spend in schools is importantgiven that they are there to acquire theacademic and social skills that will, ultimately,affect their future and the future of our society.

• Schools present particular challenges formanaging indoor environmental quality,including unique pollutant sources and highoccupancy rates. While many school boards

have developed expertise for dealing withindoor environmental problems, there isgreat inconsistency from one school board tothe next in the way in which problems arehandled. Some school boards have taken aproactive approach to preventing problemsand others respond to problems as they occuron a case-by-case basis.

• Proactive plans to address indoor pollutantsin schools are underway in otherjurisdictions and at some Ontario schoolboards. Hence, this is a good time to buildand expand upon the success of otherinitiatives.

• School board action on this issue through avoluntary management plan will have thegreatest chance of achieving immediateindoor environmental improvements inschools. While provincial action is alsonecessary, a voluntary initiative will likelydeliver results more quickly than agovernment policy or programme. Thecurrent will, knowledge and interest exist atthe school board level. Proactive school boardinitiatives will inform and help stimulategovernment policy and programmedevelopment.

• Momentum on this issue is building amongstakeholders, due, in part, to the recentdiscovery of mould in many Ontario schoolportables. There is a strong group ofcommitted partners, including public healthofficials, school boards, unions, physicians,and parents who are ready to take this planforward.

Improving indoor environmental quality inschools could potentially benefit the entirecommunity. As the chart below outlines, thebenefits are multifaceted and include health,awareness, economic, political and communityoutcomes.

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8.2 Considerations

During a six-month period, Pollution Probeinterviewed experts in the field of children’senvironmental health and indoor air quality.These experts provided insight into the keyissues and made suggestions on potentialcomponents of an indoor environmentmanagement plan (see Appendix 6 for keyinformant interview summary). Pollution Probealso held informal discussions with severalschool board officials, parents, and healthprofessionals on this topic. These discussionshave confirmed the interest in and need fordeveloping a plan to improve indoorenvironmental quality in schools. Some keyconsiderations that arose out of the discussionsincluded the following:

• School boards have restricted budgets; theplan must include low cost solutions.

• Each school board has different issues andneeds; the plan must be simple and provideflexibility.

• Schools need to work with what they have;the plan should focus on pollution preventionand on better management of the facility; e.g.,carpet use and low emission options, cleaningproducts and practices, and dust control.

• Everyone must be involved, including seniorschool board officials, school staff, teachers,parents, students, and administrators. Thesupport of and participation by plantpersonnel, health and safety officers, andprincipals, however, will be key to thesuccess of the programme.

• A hard copy manual or report will likely siton a shelf; the plan should utilize the latestin electronic communication technology, beuniversally acceptable at minimal cost, andbe kept up-to-date with the latest techniquesand solutions.

• The plan must generate immediate benefits;parents are concerned about the health oftheir children in schools.

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Based on these considerations, an effective planwould be one that is voluntary, action-oriented,cost-effective, flexible, and able to complement aschool’s regular operational activities. As well, itwould take advantage of Web-based technology,including mechanisms for reporting andmonitoring. It would also be designed tocomplement other work in this area, such as theOntario government’s Environmental ManagementSystem (ISO 14001) Sector Guide for Schools.

The plan should be designed for use by everyoneinvolved in the school community. Teachers,parents, students, principals, school boardofficials, and custodians should all be able tobenefit from the plan. Health and safety officersand plant personnel will likely be the main usersand implementers of the plan. People involvedin building operations and occupant care are inthe best position to influence the quality of aschool’s indoor environment. Plant personnelhave the knowledge and expertise on ventilationsystems, maintenance activities and products, andrenovations — three important factors thatinfluence the quality of the indoor environment.They are the people charged with theresponsibility for building care and who haveaccess to resources for their activities. Health andsafety officials have the mandate to ensure a safeand healthy working environment for schooloccupants. The plan should provide them withuseful information on environmental health thatcan be applied to their day-to-day activities. Theplan will give users the opportunity to link witheach other and with those outside of the schoolcommunity.

8.3 Plan Framework

Given the growing interest in electroniccommunication, the plan could be housed ininteractive, Web-based database technology.This format provides the following advantages:

• allows participants to access currentinformation as new developments occur inthe indoor environment field;

• provides a mechanism for school boards toshare information and trade experiences andbest practices;

• enables participants to harness informationfrom multiple sources;

• ensures openness by providing the publicwith access to school activities; and,

• enables world-wide participation andfeedback from others, enhancing the scopeof solutions that may be available.

A Web-based plan would consist of twocomponents:

• an object-oriented database repository ofinformation; and,

• a user interface for interactive communication.

An object-oriented database to the Web wouldprovide a repository for diverse forms of usefulinformation for the user. This could include:instruction sheets, case studies, names andaddresses of useful contacts, written conferenceextracts, Web addresses of relevant sites,photographs of indoor environmental problemsand solutions, audio and video extracts fromconferences or instructional tapes, descriptionsof problems by users, helpful experience frompeople who have encountered and solved indoorenvironmental problems, listings of resourcessuch as books, manuals, videos, and audio tapes,and conceivably many more forms of

An indoor environmentmanagement plan will provideusers with a menu ofopportunities for indoorenvironmental improvementsfrom which they can design astrategy to address theunique issues facing theirschool or school board.

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information. Building a solution that allowstransfer of text, audio, video, photographs,graphics, animation, presentation slides andother diverse forms of “data” will provide aricher resource than a static text-based Webpresence.

A user interface could consist of dynamic Webpages that respond to a user’s needs, interests andspecific queries. The dynamic pages would allowa “window” into the database and allow the userto extract those specific items that are relevant tohim or her. Unlike most databases, this one wouldbe highly interactive. Issues related to the indoorenvironment are dynamic; people dealing with itneed to interact on a regular basis with othersfacing the same problems. The best solutions willcome from the users who have begun to tacklespecific indoor environmental problems in theirown schools. Ideally, their information will bereadily available to others through the samedatabase. The user interface will also provideinstructions and easy routes for others to log theirinformation into the database. Having schoolsprovide information and activity updates to thedatabase will be important for monitoring andevaluating the success of the programme. Someof the topics to be considered for the databasecould include:

Operation and Maintenance of HeatingVentilation and Air Conditioning (HVAC)Systems

Building MaintenanceCustodial CareMaterials and Product SelectionConstruction, Renovation and RepairNew School Design, Construction and

AccommodationEnergy ManagementDetecting and Remediating MouldTemperature and HumidityAir Pressure Control and Air FiltrationDetecting and Monitoring Indoor Environmental

ProblemsBuilding Assessment and Management Systems

for Indoor Air Quality

Indoor Air Quality Complaint ProtocolsLegal Requirements for Indoor Air QualityClassroom and Art SuppliesRadon, Lead, AsbestosPest ControlFurnishings and FlooringLightingOffice Supplies and EquipmentFragrance ChemicalsIndoor Contaminants and Children’s HealthEnvironmental SensitivitiesIndoor Air Quality TestingExposure AssessmentsCommunication and Education

For each subject area, the plan will provideaccess to information, actions, and strategies toaddress specific concerns. Links to public orprivate sector programmes that could support theimplementation of an action will also be listed.As well, visual presentations successfully usedby school boards to facilitate discussion anddecision-making on this topic will also beavailable to users. In essence, the plan willprovide the participant with a menu ofopportunities for indoor environmentalimprovements from which they can design astrategy to address the unique issues facing theirschool or board.

8.4 Participation and Recognition

School boards participating in the programmecould strive to achieve a series of principles orgoals. Examples might include the following:

• Prevent indoor environmental problems.

• Remediate existing indoor environmentalproblems.

• Resolve indoor environmental problems asthey occur.

• Share experiences of problems and solutionswith others.

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A Web-based indoor environment managementplan would help participating schools and schoolboards achieve these goals. As well, once a schoolboard committed to the programme, key personnel(such as facilities staff) would be offered a seminaron the reasons and strategies for improving indoorenvironmental quality. Information would beprovided so that board staff could then repeat theseminar internally. This would help to promote theplan and encourage participation.

Gaining participation in any voluntary initiativerequires extensive outreach and marketing. Thispresents particular challenges, given that schoolboards are consumed with amalgamationchallenges, budget cuts and new programmes,such as teacher testing. The plan must be well-crafted and uniquely branded in order to interestschool boards. Piquing interest in the programme

would involve outreach through media articles,press events and presentations to school boardofficials, school administrators, joint health andsafety committees, board trustees and parents.Having some school boards endorse the planearly on would be crucial for creating momentumand increasing participation across the province.

School boards that sign on to the plan would beacknowledged for their efforts with some formof award. They would also be commendedregularly through media events and on the Website. Pollution Probe would be able to assess thelevel of participation at each school andacknowledge the sites that are showingleadership. In the end, schools would berewarded for their achievements, which wouldenhance their public image and encourage futureparticipation.

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9.0 Conclusions and Recommendations

Pollution Probe believes that a comprehensive strategy to protect children’s environmental health inOntario will require significant long-term investments by governments and interested stakeholders intoresearch, policy and outreach activities related to indoor environments and children’s health. To helpmove this agenda forward, Pollution Probe has, below, summarized key conclusions of this report andproposed recommendations which represent an ideal course of action for optimizing school indoorenvironmental quality and enhancing children’s environmental health.

1. There is no clearly assigned government responsibility for the quality of indoorenvironments in schools. A wide variety of government ministries, departments, and agencies havepartial responsibility for some aspect of the indoor environment, but none have a clear mandate to preserveand enhance indoor environmental quality in schools. The diversity of participants in this area createsfragmentation of authority and reduces effectiveness with respect to improving school indoor environments.

Recommended Action:

••••• Assign lead responsibility for the quality of school indoor environments to aprovincial ministry. In order to advance effective programmes and strategies to improve indoorenvironmental quality in schools, a single ministry must be responsible and accountable for thisissue. The government of Ontario should recognize the importance of healthy indoor environmentsand assign one of the ministries of education, labour, health or environment with the authority andresources to take leadership. This has happened in Nova Scotia whereby the government providedthe Department of Education with the expertise and resources to begin addressing school indoorenvironment issues more effectively.

Lead Agency: Government of Ontario.

••••• Develop a more co-ordinated provincial approach to addressing indoorenvironmental issues and children’s environmental health in schools. While oneministry should assume leadership for these issues, all of the ministries that currently have partialjurisdiction should work together more effectively to develop a comprehensive strategy to improveschool indoor environments. Using Nova Scotia as a model, an inter-ministerial committee onindoor environments, with representatives from the ministries of health, education, labour andenvironment, should be formed as soon as possible.

Lead Agencies: Ontario ministries of health, education, labour and environment.

2a. Poor indoor environmental quality in Ontario schools has negative health andlearning implications for children. Health experts claim that children are more vulnerable to theharmful effects of environmental contaminants than are adults, and that indoor contaminants are amongthe most important sources of risk to the respiratory health of children. According to a study done by aGeorgetown University researcher, students attending schools that were in poor condition were 5.5percentage points behind students attending schools that were in fair condition and 11 percentage pointsbehind those attending schools that were in excellent condition. In a 1993 survey of Ontario school

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facilities, it was found that most school administrators believe that the learning environment is“absolutely critical” to student achievement.

2b. The current legislative framework does not specifically identify children’s uniquevulnerabilities to indoor contaminants and guarantee for children a healthy learningenvironment. A healthy learning environment is one that provides children with optimal opportunityfor healthy physical, social, emotional and intellectual development. Components of that environmentinclude proper nutrition, emotional support, academic instruction and a healthy space in which to learn.There is currently no legislation that specifically requires that children be protected from the potentialharm associated with poor indoor environmental quality in schools. On the other hand, adults whowork in schools are protected from indoor hazards, to some degree, through the Occupational Healthand Safety Act.

Recommended Action:

••••• The Ontario Minister of Health should develop a provincial policy and regulatoryframework that ensures that children have a healthy learning environment. Theminister responsible for health should ensure that children in schools have the best possible indoorenvironment for healthy development. A provincial policy/regulatory framework should bedeveloped that acknowledges children’s unique vulnerability to indoor contaminants and protectschildren from these hazards in schools.

Lead Agency: Ontario Ministry of Health and Long-Term Care.

3. The full extent of indoor environmental problems in Ontario schools and their impacton the children who attend school need to be better understood. With the exception of theinformation published in Canadian School House in the Red in 1993, no formal studies have beenconducted on the state of school facilities in Ontario. As well, the potential for significant healthproblems, including long-term effects on learning and skill development, due to indoor air pollution inschools is poorly understood. According to a 1996−97 Population Health Survey conducted byStatistics Canada, approximately 11% of Ontario children under the age of 19 have asthma; based onthese statistics, there could be up to 245,022 asthmatic children attending Ontario schools who arehighly sensitive to the conditions of indoor environments.

Recommended Action:

••••• Conduct routine indoor air quality monitoring and prepare an inventory of existingindoor environmental problems in Ontario schools. To get a better understanding of thescope of indoor environmental challenges Ontario school boards are facing, a record of their day-to-day problems and a more systematic protocol for measuring indoor air quality is necessary. Theconclusions reached in the 1993 school facilities survey, along with significant anecdotal evidenceof indoor air quality challenges in schools, point to the need for further investigation. A morecomprehensive picture of the state of the indoor environment in Ontario schools will assist decisionmakers in designing long-term strategies for improving indoor environmental quality in schools.

Lead Agency: Ontario Ministry of Labour in collaboration with Ontario school boards.

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••••• Initiate co-ordinated, systematic epidemiological and clinical health studies of theimpacts of poor indoor air quality on children. More research is needed to clarify anddetermine the health and learning outcomes for children exposed to indoor pollutants. As part of thesestudies, primary pollutants of concern and combinations of pollutants need to be identified andassessed. The federal government should assume a lead role in addressing health effects researchneeds. The results of such research should be generically applicable and beneficial to all provinces.

Lead Agency: Health Canada in collaboration with the Ontario Ministry of Health and Long-TermCare, universities and teaching public health units.

4. A comprehensive analysis of the costs and benefits of improving indoorenvironmental quality in schools in Ontario has not been undertaken. The use of cost/benefit analyses for determining optimal air quality conditions has gained considerable acceptance overthe last 10 years with respect to outdoor air quality. This acceptance now needs to be broadened toinclude examination of indoor air quality problems. Large health costs to society may be accumulatingdue to the health impacts from poor indoor environmental quality in schools. The results of a cost/benefit analysis would lead to more informed decisions that will advance the public interest withrespect to indoor environmental quality in schools.

Recommended Action:

••••• Conduct a cost/benefit analysis of improving indoor environmental quality inOntario schools. A comprehensive analysis should be undertaken to determine: a) the capital,operating and maintenance costs of improving indoor environmental quality in schools with respectto building materials, furnishings, ventilation, and chemicals/consumables, and b) the benefits ofimproving indoor environmental quality in schools associated with potentially avoided health costs.In order to conduct an ideal cost/benefit analysis, the gaps and deficiencies in information,particularly with respect to indoor air quality conditions and concomitant health effects on schooloccupants, need to be addressed. In the meantime, however, consideration should be given toundertaking immediately a cost/benefit analysis based on the best available data and the knowledgeof health experts, architects, engineers and school board plant managers.

Lead Agency: Health Canada in collaboration with Environment Canada and the Ontario Ministry ofHealth and Long-Term Care.

5a. Schools present unique challenges for managing indoor environmental problems.Seventy-three per cent of Ontario schools and almost half of Ontario’s portable classrooms haveoutlived their normal life expectancy. Lack of funds for building renewal and deferred maintenancehave resulted in school building systems being left to deteriorate. Poorly maintained facilities can leadto structural and ventilation problems that affect the quality of school indoor environments. Schools aredensely populated with unique pollutant sources that cause indoor environmental challenges. Alongwith the more typical indoor contaminants, such as biological and chemical agents, schools also containpollutants from cafeterias, arts and science supplies, furnace areas, rest rooms and locker areas.

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5b. Restricted budgets limit Ontario school boards’ abilities to identify, prevent andremediate indoor environmental problems in schools. With the new funding formula under Bill160, school boards no longer have access to provincial grant programmes for special projects and havelost their power to raise funds locally through property taxes. The restrictive nature of the new fundingregime will make it more difficult for some school boards to improve indoor environmental quality.

Recommended Action:

••••• Provide school boards with support and resources for improving indoorenvironmental quality in schools. The provincial funding formula needs to be modified suchthat school boards have access to sufficient financial resources when modifications to schools arerequired to improve indoor environmental quality. Alternatively, a special projects fund earmarkedspecifically for indoor environmental improvements needs to be established and made available toschool boards. Resources to school boards are also needed for: technical support; monitoring andforecasting indoor air quality; training for key personnel and service providers; preventativemaintenance; and, awareness and education programmes.

Lead Agency: Government of Ontario.

6. Healthy Schools initiatives are gaining momentum in North America and establishingthe basis for leadership on indoor environmental issues. Creating healthy indoor schoolenvironments for children is beginning to take hold in some Ontario school boards and in otherjurisdictions. The U.S. EPA and the province of Nova Scotia have shown significant leadership in thisregard. Although indoor environmental problems in Ontario schools are generally dealt with on a case-by-case basis, some school boards are making advances in healthy school development. The WaterlooRegion District School Board’s ECO classroom programme, which has been studied internationally, hashelped to inform a new building approach for new school construction in the region. These initiativesprovide a good starting point for province-wide school board leadership on creating healthy schools.

Recommended Action:

• Explore the use of a voluntary indoor environment management plan to helpimprove indoor environmental quality in schools. A voluntary indoor environmentmanagement plan that provides school boards with cost-effective strategies for preventing,remediating and resolving indoor environmental problems in schools should be explored as soon aspossible. Models for consideration should focus on pollution prevention and could include:activities underway at some boards; the U.S. EPA’s Indoor Air Quality Tools for Schools Action Kit;environmental management systems, such as ISO14001; an electronic interactive Web-based plan;or any number of existing programmes that best suit the needs of school boards. Indoorenvironmental policies should also be examined as a potential tool for inciting action on indoorenvironmental issues in schools.

Lead Agency: Ontario school boards in collaboration with interested stakeholders.

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••••• Endorse, support and promote the concept of developing a voluntary indoorenvironment management plan for Ontario schools and school boards. Governmentsshould work with Ontario school boards and interested stakeholders to help develop and promotean effective indoor environment management plan to assist school boards to improve indoorenvironmental quality in schools.

Lead Agency: Ontario Ministry of Education in collaboration with the Ontario ministries of health,labour and environment; and local public health departments.

7. Parents are concerned about the safety of Ontario schools with respect to indoorenvironmental quality. Since the recent emergence of mould-related concerns in portables,particularly in the Halton and Peel districts, parent anxiety about the safety of schools has been on therise. Reported cases of mould-related illness and portable classroom closures have drawn a lot ofattention, and a sense of public fear and urgency is being expressed through the media.

Recommended Action:

••••• Provide the public with the best available information on indoor contaminants andtheir impact on children’s health. It is important to provide the public with concise, credibleinformation on the range of indoor environmental issues that could affect children’s health. Therecent conflict among experts on the health outcomes from mould in schools has caused confusionand fear in many communities. For effective participation in decision-making processes, the publicneeds to be well-informed on the full scope of the issue, including potential problems and possiblesolutions.

Lead Agency: Health Canada in collaboration with the Ontario Ministry of Health and Long-TermCare and other agencies working in this area: Canadian Institute of Child Health, Ontario Public HealthAssociation, Pollution Probe and The Lung Association.

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End Notes

1 U.S. Environmental Protection Agency. 1998. Indoor air quality basics for schools. http://www.epa.gov/iaq/schools/scholkit.html

2 Karen A. Beaulieu. 1998. Management of indoor air quality in Canadian schools. Master’sthesis, University of Calgary, 26, 27.

3 U.S. Environmental Protection Agency. 1995. Indoor air quality tools for schools: Co-ordinator’sguide. Washington. EPA, 3.

4 U.S. Department of Labour, Occupational Safety and Health Administration. 1994. FederalRegister April 5, 1994, 29 CFP Parts 1910, 1915, 1926, and 1928. Indoor Air Quality: ProposedRule. Washington, D.C.: U.S. Department of Labour, 16005–16006.

5 Pollution Probe. 1998. The air children breathe: The effects on their health. Toronto: PollutionProbe, Section 5.

6 Ontario Ministry of Education, Business Services Branch. Personal communication, 3 March 2000.

7 U. S. Environmental Protection Agency. Indoor air quality tools, 3.

8 Ibid.

9 Children’s Environmental Health Network. (Undated). Resource guide on children’senvironmental health. Emeryville, CA: California Public Health Foundation.

10 G. Chance and E. Harmsen. 1998. Children are different: Environmental contaminants andchildren’s health. Canadian Journal of Public Health. 8/9, Supp.1, May/June.

11 Children’s Environmental Health Network.

12 Ibid.

13 Ibid.

14 U.S. Environmental Protection Agency. Indoor air quality tools, 3.

15 Beaulieu. Management of indoor air, 27.

16 Ibid., 26.

17 Maryland State Department of Education, Division of Business Services. 1993. Technical bulletin— Carpet and indoor air quality in schools. Baltimore, MD: Department of Education, 2-8.

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18 John W. Roberts and Philip Dickey. 1995. Exposure of children to pollutants in house dust andindoor air. Reviews of Environmental Contamination and Toxicology. 143: 61.

19 U.S. Department of Labour, Occupational Safety and Health Administration. 1994. FederalRegister April 5, 1994, 29 CFP Parts 1910, 1915, 1926, and 1928. Indoor Air Quality: ProposedRule. Washington, D.C.: U.S. Department of Labour, 16005–16006.

20 Pollution Probe. The air children breathe, 40.

21 Ibid., 41.

22 Dennis Beuckert. 1999. The Toronto Star. 13 January, A20.

23 Canadian Institute of Child Health. 1998. Fact sheet — Childhood asthma and air quality.Ottawa: CICH.


25 Ruth Etzel et al. 1998. Acute pulmonary haemorrhage in infants associated with exposure toStachybotrys atra and other fungi. Arch Pediatric Adolescent Medicine. 152: 757.

26 Doris J. Rapp. Personal communication, 28 April 1999.


28 U.S. Environmental Protection Agency. Indoor air quality, 4.

29 Washington State Department of Health. 1995. Why manage school IAQ? School indoor airquality best management practices manual. Olympia, WA: Washington State Department ofHealth, Section 2.

30 U.S. Environmental Protection Agency. Indoor air quality, 4.

31 Shirley J. Hansen. 1993. Canadian schoolhouse in the red. Ottawa: Canadian AutomatedBuildings Association, 10.

32 Ibid., 3.

33 Ibid., 20.

34 Ibid., 10.


36 Ibid.

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37 Gary Gibson (Health and Safety Officer, Durham District School Board and member of Healthand Safety Subcommittee of the Ontario Association of School Board Officials). Personalcommunication, 17 February 1999.

38 Ibid.

39 Hansen. Canadian schoolhouse, 20.

40 Beatriz Milner (Day Care Supervisor, St. Stephens Community House Day Care, King EdwardPublic School). Personal communication, 23 February 1999.

41 Bill Butcher (Co-Chair, Joint Health and Safety Committee, Elementary Teachers’ Federation,Durham Branch). Personal communication, 25 February 1999.

42 Jill Witherspoon (Energy Conservation Officer, Toronto District School Board). Personalcommunication, 27 January 1999.

43 Larry Sparks (Health and Safety Officer, Upper Canada District School Board). Personalcommunication, 26 February 1999; Butcher. Personal communication, 25 February 1999;Wanda Bailey (Health and Safety Officer, Elementary Teachers’ Federation). Personalcommunication, 17 February 1999; Gibson. Personal communication, 3 January 1999.

44 Gibson. Personal communication, 3 January 1999.

45 Ontario Ministry of Health. July 1999. Expert Panel on Fungal Contamination Indoors. Toronto:Ontario Ministry of Health, Public Health Branch: Appendix, 2.

46 Pat Bruvelaitis (Health and Safety Specialist, London District Catholic School Board). Personalcommunication, 3 February 1999.

47 Harold Levy. 1998. The Toronto Star. 17 May, A1.

48 Norma L. Miller. 1995. The healthy school handbook. Washington, D.C.: National EducationAssociation, 186.

49 Gibson. Personal communication, 5 May 1999.

50 Canadian Institute for Radiation Safety. 1990. Radon in schools: Questions and answers.Toronto: Canadian Institute for Radiation Safety.


52 CBC Radio News Report quoting Gayle Nyberg (Chair of Toronto District School Board). 1March 1999; and Gayle Nyberg (Chair of the Toronto District School Board). Personalcommunication, 10 January 2000.

57



54 Bob Mitchell. 1998. The Toronto Star. 23 April, E5.


56 Ron Breau (Director, Educational Facilities, New Brunswick Government). Personalcommunication, 17 June 1999.

57 Karen Bartlett (Ph.D. Candidate, University of British Columbia). Personal communication, 7July 1999.

58 These initiatives include: U.S. Environmental Protection Agency. Indoor air quality; TexasDepartment of Health. 1998. Voluntary indoor air quality guidelines for public schools. Austin,TX: Texas Department of Health; Washington State Department of Health. School indoor air;Maryland State Department of Education. 1987. Indoor air quality — Maryland public schools.Baltimore, MD: Office of Administration and Finance; Vermont State legislation — An ActRelating to Toxic Materials and Indoor Air Quality in Vermont Public Schools. Passed March2000. See www.leg.state.vt.us/docs/2000/bills/house/H-192.htm.

59 Patty Donavon (Parent, Quispamsis, New Brunswick). Personal communication, 1 September1998.

60 Dr. James Gunn (Superintendent of Schools/CEO, Annapolis Valley Regional School Board,Nova Scotia). Personal communication, 30 April 1999.

61 Sandra Moser (Researcher, Citizens for a Safe Learning Environment, Nova Scotia). Personalcommunication, 12 July 1999.

62 John Guevin (Team Leader, Tools for Schools, Indoor Environment Division, U.S. EPA).Personal communication, 6 May 1999.


64 Guevin. Personal communication, 6 May 1999.


66 U.S. General Accounting Office. 1995. School facilities: Condition of America’s schools.Washington, D.C.

67 Guevin. Personal communication, 6 May 1999.

68 Indoor Environment Review. 1999. Advanced workshop: EPA’s ‘Tools for Schools’ —Implementation and case studies. Indoor environment: The state of the industry. Presentationsfrom the 7th annual indoor environment conference. Bethesda, MD: IAQ Publications, 49.

58


69 Gerald Muise (Co-ordinator, Environmental Health and Safety, Department of Education andCulture, Facilities Planning and Operations, Nova Scotia Government). Personal communication,29 April 1999.

70 Ibid.

71 Ibid.

72 Ibid.

73 Ibid.

74 Nova Scotia Department of Labour. 1997. Draft indoor air quality regulation. Halifax, NS:Nova Scotia Department of Labour.

75 Moser. Personal communication, 3 May 1999.

76 Muise. Personal communication, 29 April 1999; Gunn. Personal communication, 30 April 1999.

77 Muise. Personal communication, 29 April 1999.

78 Doug Morris (Special Education Consultant, Waterloo Region District School Board). Personalcommunication, 30 April 1999.

79 Ibid.

80 Arnie Wohlgemut (Supervisor, Structural Services, Plant Maintenance and Construction,Waterloo Region District School Board). Personal communication, 8 June 1999; Gerry Mills(Manger of Plant Operations, Waterloo Region District School Board). Personalcommunication, 8 June 1999; Craig Hynd (Environmental Officer, Plant Maintenance andConstruction, Waterloo Region District School Board). Personal communication, 8 June 1999.

81 Wohlegemut. Personal communication, 8 June 1999; Mills. Personal communication, 8 June1999.

82 Morris. Personal communication, 30 April 1999.

83 Waterloo County Board of Education. 1998. Body chemistry (environmental sensitivities) andbehaviour: Basic information package. Waterloo, ON: Waterloo County Board of Education, 3.

84 Rapp. Personal communication, 28 April 1999.

85 Mills. Personal communication, 8 June 1999.

86 Gibson. Personal communication, 3 June 1999.

59


87 Ibid.

88 Ibid.

89 Ibid.

90 The Acidifying Emissions Task Group. 1997. Towards a national acid rain strategy. Ottawa:Environment Canada, 98.

60


Documents

Health Schools - Trillium Foundation