Improve Your School's IAQ:
A Guide To Preventing and Resolving Indoor Air Quality Problems [EPA Draft Document, June 1994].

Thank you for giving us the opportunity to comment on this draft document.  We share the agency's concern about the quality of indoor air in the nation's schools, and in general, we support activities that promote good indoor air quality.

Background

HEAL is a national education and information non-profit volunteer organization, founded in 1977 by physicians and citizens concerned about the health effects of environmental exposures.  HEAL pursues its purpose and goals through its publications; through cultivation of relationships with government and private sector agencies and organizations; and through the activities of chapters and regional volunteers that promote HEAL's purpose and goals at the local level.

In recent years HEAL has devoted much of its attention to issues related to low-level chemical exposure and human health effects, including multiple chemical sensitivities (MCS).  Because of this focus, HEAL is very concerned about the impact of low-level chemical exposures on indoor air quality (IAQ), in schools and other buildings.

Schools are of particular concern to HEAL because school occupants represent, or may represent, many subpopulations especially susceptible to adverse health effects from exposure to indoor air contaminants.  These subpopulations include:

1. children
2. the elderly     
3. the poor
4. women of child-bearing age and their fetuses
5. the chronically-ill, including people with:  allergies, chemical sensitivities, asthma and other reactive airway conditions, mental or physical disabilities, including neurological conditions, immune-system abnormalities, including autoimmunity and immune deficiencies, substance abuse problems
6. the malnourished, including people with eating disorders       
7. the elderly
8. people with occupational chemical exposures (pesticides, housekeeping and renovation materials etc.)
9. people undergoing chemotherapy or radiation treatments

We believe that healthful IAQ in schools is of critical importance, given the combination of the presence of many potentially vulnerable subpopulations, and the high overall population density of schools (up to four times the occupant density of office buildings)

Primary Comments and Recommendations

1. We urge the agency to list HEAL in the Resource Appendix (I) under "Environmental/ Health/Consumer Organizations."
2. It is important for school administrators, especially health officers, to be aware of recent developments in the understanding of the biphasic nature of allergic reactions: A school occupant who experiences an acute reaction to a  school-related exposure may ALSO experience a late component of the same reaction 6 to 12 HOURS AFTER  EXPOSURE. This late component reaction can differ in kind from the earlier reaction component, it may be more severe, and it may be very difficult to treat.  THIS  INFORMATION MAY BE  CRITICAL FOR PROTECTING THE ALLERGIC FROM HARMFUL EXPOSURES IN SCHOOLS
   
   Although an allergic episode triggering an acute reaction may be managed adequately with commonly-prescribed drugs in the short term, the delayed reaction will usually not respond to these drugs, and the person experiencing the delayed reaction may require hospitalization and a lengthy recovery.  (See Smith, DL et al., Allergy and Immunology.  Journal of the American Medical Association 271, 21: 1653-54. June 1, 1994.)
   
   THE ONLY WAY TO PREVENT THESE SERIOUS NEGATIVE ALLERGIC INCIDENTS IS TO PREVENT THE INITIAL EXPOSURE THAT PROMPTS THE EARLY REACTION.  Although the more severe component of the reaction may occur off school premises, its origin in school- related exposure is critical to understanding both the importance of good IAQ in schools, and the responsibility of school administrators in the provision of safe school environments for all school occupants
   
   People with sensitivity disorders, including multiple chemical sensitivities (MCS), also run the risk of experiencing exposure-related reactions to school environmental conditions.  These reactions, like allergic reactions, may be acute or delayed, mild or severe. SENSITIVITY DISORDERS OFTEN DO NOT RESPOND TO MEDICATION, AND SO MUST BE MANAGED THROUGH EXPOSURE PREVENTION AND AVOIDANCE.
   
   
3. HEAL is in the process of preparing a guidance document for the provision of accommodation to people with MCS under the terms of the Americans with Disabilities Act 1990.  A draft copy is enclosed.  We encourage the agency to study this document, and to include in its own literature all recommendations included for the protection and accommodation of the chemically-sensitive.  We believe that measures taken to protect the chemically-sensitive from exposure-related adverse effects will also prove to be protective of the well-being of all building occupants.

Additional Comments … Content Of Improve Your School's IAQ

This title implies that there already is a problem with the reader's school -- an implication which the reader may resist and resent.  This may impair the effectiveness of the document in getting school administrators to learn about IAQ and to promote good IAQ practices in their facilities.  The agency may consider using a variant of an earlier EPA document title, and call this document YOUR SCHOOL: THE INSIDE STORY, a Guide to Indoor Air Quality.

Front Matter

It would probably be helpful to include a description of GOOD IAQ at the very beginning of the document.  This would give the document user a goal toward which to work.  Although the emphasis on problem identification and solution elsewhere in the document is appropriate, the overall goal of the document is to promote good IAQ in schools.

Page III, "Note to School Officials."

We believe that this section should be revised to include language that will motivate the reader to examine the document further, and to implement its  advice.  In its current version, there seems to be an assumption that the reader shares the agency's interest in school IAQ, and that the reader would want to promote good IAQ if only he or she knew how to do it.  This may not be so.

HEAL's experience has been that school personnel may resist suggestions that their facility change practices that have an impact on IAQ.  We believe that the agency should make the most of this opportunity to show why it is in the interest of school personnel to monitor and, if necessary, improve the quality of indoor air in their facility.

It may be easiest to revise the present document by following the document's own advice at Section 6: 14-20, which lists the document components most likely (in the author's view) to convince administrators to implement IAQ management plans. These components could be revised into a comprehensive introduction to school IAQ for the document user, and placed at the front of the GUIDE.  Alternatively, the existing  front matter of the GUIDE could be revised to include information contained in Sections 2 (Why IAQ is Important to Your School) and 4 (Building Occupants) of this draft.

Section 2, Page 3:25-28

At this early stage in the document, it is probably not a good idea to suggest that complaints about IAQ may not be related to actual IAQ, but rather to other concerns.  We recommend that this statement be omitted from this section and instead be included in Section 11 (Diagnostics).  It seems to us more in keeping with the intent of the document to suggest that IAQ problems be investigated BEFORE suggesting that IAQ- related complaints may arise from other causes.

Section 2, Page 3:48

This language is vague.  The overall goal of the document is to enable schools to provide a positive learning environment for children; the other items listed in this section (page 54:41-54; page 55: 2-11) describe negative impacts on the learning environment.  This section should be restructured to reflect how negative IAQ conditions run counter to the purpose and goals of schools.

Section 3

Role and Functions of the IAQ Coordinator might better be included in Section 5 (What is an IAQ Management Plan?).  It is easier to understand the IAQ Coordinator's activities as described in Section 3 of this draft if they are read in the context of Section 5.

Section 6 (Steps to Activate the IAQ Management Plan)

It is difficult to understand who is supposed to be engaged in activities described in #1.  Does the initiative to start a school IAQ management plan rest only with school administrators, or are staff and parents -- or even students -- also able to initiate the process? This passage should be clarified.

Section 6, #S 4,5, and 6

With regard to suggesting that the reader obtain additional material on radon, lead and integrated pest management: Since good IAQ management is the overall goal of this GUIDE, it does not make sense to place obstacles (like the suggestion to obtain more material) in the path of GUIDE users. The more such obstacles the user faces, the more unsatisfactory the IAQ outcome may be.

The effectiveness of the GUIDE could be increased if the agency's materials regarding radon, lead and integrated pest management were furnished with the GUIDE when it is distributed.  This would require the production of an omnibus package of documents.

If the agency determines that distribution of such an omnibus package is not feasible, Section 6 of this document should be revised and expanded to show the GUIDE user why it is important to obtain this additional information.  For instance, the language at page 17 #3  assumes that the GUIDE user understands why the availability of food and water is relevant to pest control.  In practice, many people do not make this connection.  In our experience, it is not uncommon for the same person to have both food and food residues in the desk/workspace area, AND a can of pesticide spray in a nearby locker or closet.

Section 8

We enthusiastically support the idea of notification of school occupants before initiation of activities that may adversely affect IAQ.  However, we do not believe that notification is itself an activity that protects either IAQ or occupant health and safety.  Rather, we believe that prior notification should include notice of alternative classroom or other accommodations until the "odors and contaminants" resulting from the activity have been purged from the building or otherwise eliminated.

Section 9

We note that there is no checklist included for evaluating existing practices in schools that can have an impact on IAQ.  We believe that, unless such activities are evaluated and corrected, many will continue to take place, even if inconsistent with other recommendations in the GUIDE.  Practices such as pesticide use on demand (or at will), routine use of scented housekeeping products, over-use or misuse of disinfecting products, and provision of unsuitable materials to sensitive school occupants may continue unless specifically searched out and eliminated.  See the attached draft "Guide to Accommodation" for identification of practices which may need to be questioned and discontinued.

Teacher's Activity Guide

This section includes much valuable information about many practices relevant to IAQ, but does not include some very important ones:

• We believe that the use of disinfectants in the classroom is both fairly common (especially during cold and flu season), and inappropriate.  We believe that teachers should be questioned about this practice, and instructed to discontinue such use. (See attached article, "Disinfectants are pesticides, too.")
• Teacher use of pesticides in the classroom is not uncommon, is also highly inappropriate, and should be forbidden.  We have heard of cases in which pesticides were used preventively" by teachers, as well as cases in which teachers used pesticides for non-pest-related problems such as itching skin.  (See attached article, "Good practice standards.")
• The use of classroom and cloakroom pesticide sprays during outbreaks of headlice is both dangerous to school occupants and ineffective in controlling the pest.  This common practice should be forbidden.  We suggest that schools contact HEAL for information on how to safely control  headlice in school children.
• Classroom use of room deodorizers, air fresheners and other scented products is not uncommon and should be discontinued. The need for such products may indicate a sanitation or ventilation problem in the classroom.  The use of air "freshening" products in the classroom for aesthetic reasons should be forbidden.  We have received many complaints about ill-effects arising from exposures to these products, which may contain allergens, irritants and sensitizers.

Teacher's Activity Guide pages 4-7, 8-10

If the agency has not already done so, consultation with the American Chemical Society about safety standards in school laboratories might be undertaken.  In recent years, ACS has reported that many school laboratories do not conform to minimal safety standards set by industry.  We do not endorse the ACS standard, but simply mention it as a standard that has been set elsewhere for the protection of (presumably healthy adult) laboratory workers.  We emphasize that this standard may not offer adequate protection to vulnerable school occupants, and that it probably represents a minimum, not a maximum, of laboratory safety in schools.

Health Officer's Activity Guide … See Primary Comment and Recommendation.

Ventilation Activity Guide: Outdoor Air Intakes

It has been HEAL's experience that outdoor pesticide applications and other activities may contaminate building air intakes.  Sometimes this problem arises when HVAC maintenance personnel fail to inform pesticide applicators and other outdoor workers about the location of the air intakes and the need to avoid permitting pesticides or other volatile materials in -- or even near -- them.

It may be necessary to temporarily shut down outdoor air intakes during such outdoor activities.  In this event, we believe that affected areas of the building interior should be
evacuated and not reoccupied until the outdoor activity has ceased, vapors have dispersed, and full ventilation has been restored.  We suggest that this information be included in this section.

We suggest that the agency include in this section advice about keeping pollutant sources away from BOTH building mechanical air intakes, AND natural building features such as doors and windows.

Ventilation Activity Guide: System Cleanliness

Although the inspection and filter replacement information included is excellent, no guidance has been offered about what the HVAC maintenance personnel are to do if "visible mold growth," or other contaminants, condensates or soils are found in HVAC systems.

We believe that disinfectants and sanitizers should not be used on or in HVAC equipment by maintenance personnel, and that these products should not be applied by anyone to HVAC components while the building is occupied.  After such products are professionally and properly applied, the building should be fully purged of residual odors and fumes from their application before the building is re-occupied.  Further, we believe that no sanitizing or disinfecting product designed to have lasting residual effects should be used in or on HVAC equipment.

We strongly object to treatments of HVAC ductwork with substances applied "to reduce dust," but that in fact are volatile sticky coatings to which airborne soils can adhere and build up.

We recommend that duct interior fiberglass be removed wherever possible.  Where such removal is not possible, we recommend that it be encapsulated in place with a compound that will cure to a hard durable finish that does not emit vapors into the airstream.  We strongly recommend that fiberglass removal and sealing be performed while the building is unoccupied, and that all compounds used inside the ductwork be permitted to cure fully before the building is reoccupied.

We believe that school administrators should be informed that HVAC duct cleaning is not a regulated activity; that industry standards, where they exist, are voluntary; and that the products and procedures used by HVAC cleaning services need to be closely evaluated for their IAQ impact potential during and after cleaning procedures.

Moreover, we believe that HVAC systems in schools that have experienced water damage should be professionally inspected as soon as feasible after the damage occurs, and professionally serviced before building occupation.

Building Maintenance Activity Guide

This section lacks material about appropriate storage facilities.  Books and supplies to be used in the classroom MUST be stored away from emissions generated by other building activities, in dry conditions that do not foster mold growth, and in facilities secure from both pesticide treatment and contamination.  Not just classroom books and supplies, but all materials in storage, including: sports equipment; uniforms, robes and costumes; theatrical props, supplies and textiles; seasonal decorations; and other seldom-used items must be stored so as not to become contaminated and unfit for use by allergic, asthmatic, sensitive or other vulnerable school occupants.  We recommend that a section regarding these issues be added to this document.

Building Maintenance Activity Guide: Supplies

See the comments about disinfectants, deodorizers and air fresheners in the section TEACHERS ACTIVITY GUIDE.  This information should be incorporated in this section of the document as well.

We believe that it is likely that some school maintenance personnel may not be able to read or comprehend written directions, label instructions, and other materials requiring fluency in written English.  The high incidence of functional illiteracy among American adults, and the number of people in the workforce who are not native speakers of English, suggest to us that maintenance personnel should not be relied upon to follow written directives or label instructions.

We suggest instead that all products routinely used by housekeeping personnel should be of as low toxicity and low emission as possible; and that they should be supplied to workers in ready-to-use dilutions, in readily-identifiable containers that can be easily associated with particular tasks.  In addition, we recommend that all housekeeping supplies be stored in rooms separate from all food storage and preparation areas (including worker rest areas).

We also recommend that schools not store materials on school premises that must later be disposed of according to rules governing hazardous waste.  This will automatically reduce the number of toxic materials stored on school premises, and lower the likelihood of accidents and unauthorized uses.  Reduction in the use and storage of such materials will also reduce the administrative burden of managing these materials on site.

We further recommend that no product with an OSHA PEL or NIOSH CIB be routinely used on school premises.  When such products must be used (because of lack of a suitable alternative) the building should be unoccupied and workers should be supplied with appropriate protective gear.  No more of the material than necessary to complete the task at hand should be purchased, and any materials left over should be promptly and properly discarded.

Waste Management Activity Guide: Containers

We recommend that hazardous materials be stored ONLY in appropriately labeled containers that cannot be confused with containers for foods or other non-hazardous materials.  This includes disposal of containers of ready-to-use dilutions prepared from product concentrates: Both the concentrate and the dilution containers should be appropriately labeled.  These containers should never be reused in schools.

We regret that the agency did not include information in this section regarding the critically important role that waste management may play in effective pest control.  Sanitation is a vital component of effective integrated pest management, and the cooperation of everyone within the school is vital.  We recommend that at least a brief reiteration of this concept be included in this section of the document.

Renovation And Repair Activity Guide

We recommend that an addition be made to the "General Activities" section: When schools are to be repaired or renovated, the work must be done so as not to expose building occupants to releases of pesticides, PCBs and other persistent materials.  Releases -- or potential releases -- of these substances must be as conscientiously controlled as are releases of lead dust and asbestos fibers from existing structures.  In the event that records do not indicate if a school has been treated with PCB - containing materials, or with pesticides like chlordane, administrators should assume that treatment has taken place, and precautions must be taken accordingly.

Otherwise, we find that the guidance offered under the heading "General Activities" is useful and appropriate.  We believe that school occupants and parents should receive a copy of these guidelines at the beginning of each school year during which renovations or repairs are planned, together with a schedule outlining when the work is to take place.  Alternative plans for sensitive or allergic staff and children can be made early so as to disrupt the school schedule as little as possible.  Parents and physicians of allergic and sensitive children may be able to offer assistance to administrators in identifying and minimizing troublesome exposures during renovations and repairs.

Roofing

We are aware of cases in which sensitive school personnel and students have become critically ill from exposures suffered during school roof tarring.  We believe that school roofs requiring periodic tarring should be replaced with metal roofs as soon as possible.  In the meantime, when tarring is necessary, it should be done during prolonged periods when the school is unoccupied (i.e. not over weekends during term time), and should be done early enough in the time period to allow the new materials to off-gas before the school is reoccupied.

Painting

We are aware that in some school systems, economic conditions have prompted school officials to obtain paint mixtures from special household waste disposal programs.  It is our understanding that these paints are mixed from discarded paints obtained in unopened cans left over from home renovations, and that the mixtures are supplied to schools, low income housing projects and low income private families and individuals.  These paints are offered by communities free of charge as a "greige" mixture of many colors pre-mixed into generic water-soluble flat and enamel interior and exterior latex, and alkyd interior and exterior mixtures.

Because the contents of this paint cannot be determined, we recommend that when it is used for school renovations, it be handled as if it were the most toxic formula of its type (i.e. most toxic latex, most toxic alkyd).  We recommend that it not be used while the school is occupied, and that it be allowed to thoroughly out-gas before the school is reoccupied.  We do not believe that this type of paint is ever a good choice for use in schools, but we recognize that economic conditions may force its use, and that fully-cured renewed surfaces may pose less of an environmental or health threat than painted surfaces in need of renewal.

The guidance included in RENOVATION AND REPAIR (pp.4-5) is insufficient to protect sensitive school occupants from vapors associated with painting and other surface renewal activities. Moreover, we find that this guidance, plus the sample painting protocol (at APPENDIX D-2-3), together suggest that the recommended measures are protective of both IAQ during surface renewal and curing, and of occupant health and safety.  We disagree.

Although the protocol indicates that the school principal may reserve the right not to reoccupy newly-painted areas until convinced that occupancy will not present a hazard, we are not convinced that school administrators are already aware of hazards associated with exposures to freshly-painted but apparently "dry" interiors.  We believe that one purpose of this document is to inform administrators of these hazards.

The protocol (at D-2) indicates that "overnight drying" is sufficient for any treated area.  We believe that all surface renewal guidance included in this document should specify that setting, drying and curing are different processes, and that surface renewal products that have set and appear to be dry can still be emission sources.  We also believe that school administrators may not realize that the most protective duration of classroom vacancy during and after painting is highly dependent on the paint used, the manner in which it is applied, the surface on which it is used, and prevailing temperature, humidity, and ventilation conditions.
We are particularly concerned about the implications of painting cafeteria, restroom and other building common spaces during periods of continuous building occupation.  We believe that these areas should be treated only during long vacations, while the building is vacant.  We believe that sufficient time should be allowed to elapse between the end of surface renewal treatment and the reoccupation of the building, to allow all newly-treated surfaces to cure fully, and the building to be fully purged of surface-renewal emissions.

We are also concerned about the lack of guidance regarding protection of the HVAC system during interior surface renewals. Merely vacating spaces being treated will not protect building occupants from exposure to project emissions, if these emissions are permitted to circulate throughout the building's ventilation system.  We suggest that the document user be reminded of this fact, and of the fact that high emission intensities cannot be adequately handled by HVAC filtration systems designed to remove low-level emissions.  Activated charcoal filters, in particular, may become quickly saturated by emissions associated with surface renewals, and if not promptly changed, will discharge emissions back into the building air supply.

Carpet And Flooring

We favor the use of smooth, inert flooring surfaces in all public buildings, including schools. They do not act as a sink for biological and chemical emissions; they do not require high-emission, intensive upkeep; and they do not require frequent replacement and repairs.  Thus we do not favor the use of carpets in schools.

However, we understand that carpets are in use in some schools.  We question the agency's advice in suggesting that school administrators rely on information supplied by carpet manufacturers regarding carpet VOC emissions, since some have called the reliability of this information into question.  We suggest instead that the agency develop guidance for selecting, installing and treating carpets installed in schools that will offer the most protection to building occupants from carpet- related emissions.  The information included in this section is helpful, but incomplete as it stands.

As a bare minimum, we suggest that this section include the same guidance regarding protection of building occupants during carpeting removal and installation as we suggested in the section on painting and other surface renewals.  We urge the agency to suggest that carpets, where used, should be removed and installed only during long vacations, and given ample time after installation to out-gas before the building is occupied.  We also urge the agency to include language in this section about protecting the HVAC system from emissions associated with carpet removal and replacement (see comments above, on painting).

Appendix A: Hiring Professional Assistance

Two items should be added to the guidance offered in this section:

1. The diagnostic work performed by the consultant firm should not place building occupants at risk.  Diagnostic procedures requiring the use of volatile materials should be performed when the building is unoccupied, and the building should be fully aired and the volatile materials dispersed before re-occupation.
2. Remedies suggested by the consultant firm and contracted for by the school should not themselves have lasting negative impacts on building IAQ.  Transient negative IAQ conditions resulting from remedial treatments should be fully purged from the building before reoccupation.  (We are aware that some firms recommend HVAC and duct cleaning and maintenance treatments that involve the use of volatile chemicals that may act as irritants and sensitizers, and that some of them can have lasting harmful effects.  We believe that these are inappropriate "remedies" for schools seeking to improve IAQ.)

Appendix D: Developing Indoor Air Policies

We believe that school IAQ policy development would greatly benefit from the participation of concerned parents and physicians, local community leaders, and others who have an interest in IAQ-related issues, and who have specialized insights and knowledge about such issues.  We believe that their early involvement in identification of IAQ issues that need to be addressed by school IAQ policies will save school administrators and other personnel much time and effort.

We therefore recommend that "General Considerations" include guidance on how (and when) to invite the participation of concerned individuals outside the school administrative hierarchy.

D4-5: Integrated Pest Management

We have identified two potential problems with implementing integrated pest management in public buildings: the lack of a definition of IPM that is descriptive of acceptable pest control activities; and the availability of commercial IPM programs of various types, qualities and acceptability.

We believe that, without some guidance from the agency, school administrators may simply contract for IPM pest control services, under the mistaken impression that such services are "all alike," and that only the program costs vary.  In order to prevent this from happening, we strongly urge the agency to formulate a model IPM policy along the lines of the General Services Administration's capital region IPM program, adapted for school use.

We believe that the agency should develop a definition of IPM  for use in schools that specifies the use of the least-toxic effective means of pest control; the use of pest-control chemicals only when and where pests actually present a threat to health or property; and a commitment to ongoing pest management through effective housekeeping, maintenance, sanitation and other controls.

NOTE: We are aware that the agency has prepared an IPM manual for school use.  However, we believe it likely that some schools may simply contract for "IPM" services without studying agency materials other than the GUIDE.  Therefore we believe that the agency should include appropriate guidance about selecting IPM services in this document, to prevent schools from inadvertently selecting inappropriate pest-control services.

NOTE: We urge the agency to at least mention that new or renovated school construction can and should be designed to be resistant to structural and other pests.  Materials and design selection for new or renovated structures should be governed, at least in part, by a goal of reduced risk from pests, and a reduced need for pest control chemicals.

Appendix I: Resources

Please include HEAL as a resource listed under Environment/ Health/Consumer Organizations (I-8).

We note with surprise that this draft does not list EPA's own BUILDING AIR QUALITY: A GUIDE FOR BUILDING OWNERS AND FACILITY MANAGERS (DECEMBER 1991).  We believe that this publication should be listed under "General Information" or under "Building Management" or both.

We suggest the following documents be listed under "General Information:" "SELECTED BIBLIOGRAPHY: CHEMICALS AND HEALTH (1993)" and "SELECTED BIBLIOGRAPHY: PERSPECTIVES ON PESTICIDES AND HUMAN HEALTH 1983-1993."  Both documents are available from HEAL, P.O. BOX 29629, Atlanta, GA 30359.

Additional Comments: Format of Improve Your School's IAQ

Detailed comments on the format of this document would be inappropriate, since it is clear that this draft is not in final form for distribution.  We therefore confine our comments to general concerns about the presentation of the material contained in this draft.

In general, we urge the agency to make any changes in the GUIDE's format that will facilitate initiation and implementation of school IAQ management programs.  We do not find the present format and design to be particularly "user-friendly," and encourage the agency to seek advice on how to improve the presentation of the information included in the GUIDE.

We have a general concern that the approach taken in this draft emphasizes bureaucratic matters (e.g. getting the right papers to the right personnel, and getting the papers back in a timely fashion).  Although building IAQ management programs cannot be effective without a bureaucratic information system, this system itself should not be the primary concern of the GUIDE.

We believe that many of the bureaucratic issues addressed in this draft could best be taken care of by organizing the materials into complete packets for duplication and distribution to school occupants and personnel.  This would entail some repetition of printed materials in the finished document, but it would save school administrators time and trouble in initiating and implementing IAQ management programs.  It would also probably prevent incomplete information from being circulated to school occupants and personnel, and thus increase the chances for implementation of effective IAQ management programs.

We recommend that GUIDE pages to be duplicated for distribution be perforated for easy removal from the document binding, to reduce the risk of poorly-duplicated copies.

We believe that the information contained in the GUIDE would be made much more accessible to the intended users if it were supplemented by information offered in other formats.  We suggest that the agency consider offering school IAQ workshops for school administrators, maintenance workers and housekeeping personnel.

If this is not feasible, we suggest that the agency make available videotapes illustrating how a complete, well-run IAQ management program operates in a school.  These videotapes could be viewed by administrators and others concerned with IAQ-related activities.  If possible, these videotapes could be made available dubbed in languages other than English, for improved comprehension by workers who are non-native English speakers.

The agency may wish to investigate the availability and appropriateness of videotapes already in production that are concerned with special topics in IAQ.  These videotapes may provide good resources for school administrators and other personnel involved with IAQ.  A list of available videotapes could be included in APPENDIX I: RESOURCES.

Sincerely,
The Governing Board of the
Human Ecology Action League, Inc. (HEAL)