Guidance and Technical Assistance

Under Indoor Air Quality section 37.111.826 of the revised school rules, schools are required to conduct annual indoor air quality assessments, including an inspection of the ventilation systems. Any schools using HVAC systems with air filters, must use air filters with a minimum efficiency reporting value (MERV) of between 8-13. IAQ inspection records must be kept on file for at least three years and these records must be made available to the local health authority or DPHHS upon request. While it is not required, DPHHS recommends that schools switch to at least MERV 13 air filters during time of poor ambient outdoor air quality.

How Can Schools Determine What Filters Can Be Use in Their Current HVAC System?  

Refer to the manufacturer's instructions when installing filters into the HVAC system. An understanding of the entire HVAC system is helpful to ensure that the air filters are properly installed. Proper size and gasketing is imperative to the integrity of the filter system. It is also beneficial to a maintenance program to add a filter log near the filter bank of each HVAC unit or in a computerized data base. This will help to insure that filters are changed on time and that each filter bank is using the proper change out frequency. -   NAFA Filtration Guidelines for Schools

EPA: Air Filtration in Schools
This section of the IAQ Tools for Schools website discusses Air Filtration, Pressure Drop, and Monitoring Pressure in HVAC systems.

Where Can Schools Find Indoor Air Quality Inspection Forms?

School can find air quality inspection forms and checklists on the forms section of the school rules website.

EPA Creating Healthy Indoor Air Quality in Schools

The IAQ Tools for Schools Program is a comprehensive resource to help schools maintain a healthy environment in school buildings by identifying, correcting, and preventing IAQ problems. 

What does this site feature?

• Background on why indoor air quality is important
• On-Demand Professional Training Webinar Series
• Access to the school IAQ Assessment Mobile App
  (This app can be used in place of the hard copy checklist approved by DPHHS)
• Steps to improve IAQ in schools

HEPA Air Purifiers What Schools Need to Know

To speak with someone from DPHHS about indoor air quality in your school, please contact   schoolhealthrules@mt.gov.  

Under subsection 37.111.827 Outdoor Air Quality, Schools must reference the Recommendations for Outdoor Activities Based on Air Quality for School and Child Care Facilities developed by the Montana Department of Public Health and Human Services and the Montana Department of Environmental Quality to determine local air quality conditions and choose to cancel outdoor recess and delay or not delay outdoor school-sponsored events. Schools must also have a written protocol on how to limit the infiltration of outside air into the school during poor air quality conditions.

Recommendations for Outdoor Activities/Events Based on Air Quality

These recommendations for outdoor activities were developed by the Montana Department of Public Health, the Montana Department of Environmental Quality, and the Montana Office of Public Instruction. The activity guidelines are based on the amount of time spent outdoors in different levels of air quality, from good to hazardous. Instructions on how to use the guidelines and read the Today's Air website can be found on the 2nd page of this resource. 
*These are recommendations only. Schools and districts have the ultimate authority when deciding to cancel or hold events during poor outdoor air quality conditions. 

Additional Resources

Montana DPHHS:  Wildfire Smoke & Air Quality website
The DPHHS website features air quality and health resources for the general public and provides links to partner organizations addressing wildfire smoke health impacts in Montana and nationwide. 

Montana DEQ:   Today's Air website
The Today’s Air website provides near-real time fine particulate related air quality information to the public on an hourly basis.Representations of health assessment risks within Today’s Air are provided as a general advisory, and are not substitutes for individual health awareness and the advice of medical professionals. For more information about PM 2.5 and the health impacts associated with exposure, visit the   Airnow particle pollution website.

To speak with a DPHHS representative about schools and air quality, please call (844) MTHLT4U / (844) 684-5848 or email   chronicdiseaseprevention@mt.gov  

Schools containing science labs, industrial arts classrooms or buildings, and art labs that use and store hazardous chemicals must maintain a Chemical Hygiene Plan (CHP) and designate a Chemical Hygiene Officer beginning September 1, 2021. 

Chemical Hygiene Plans

District’s Chemical Hygiene Plan (CHP) describes practices, procedures, equipment and facilities to be used by staff, students, visitors and other personnel working in laboratories where chemicals, flammables and potentially hazardous materials exist. By following the practices and procedures within the CHP, students and adults shall be protected from any chemical exposure that exceeds permissible exposure limits and educated as to the hazardous nature of the chemicals they use.

Purpose of the District’s CHP:

• Provides information to help protect employees, students and others working in school laboratories from health hazards associated with hazardous chemicals in the laboratory.
• Details the processes and precautions intended to minimize chemical exposure.
• Establishes a chain of command to handle specific safety responsibilities within the District and specific school sites.
• Protects the environment from contamination due to hazardous chemicals utilized in the school laboratory.
• Ensures appropriate management of chemicals in the District.

Example Chemical Hygiene Plans

• Example Chemical Hygiene Plan #1
• Example  Chemical Hygiene Plan #2
• Example  Chemical Hygiene Plan #3

Chemical Hygiene Plan Template

• Sample Chemical Hygiene Plan #1

Safety Data Sheets

Chemical manufacturers, distributors, or importers are required by the Occupational Safety and Health Administration (OSHA) to provide an SDS for any potentially hazardous chemical substance.

Additional Resources

Montana Department of Environmental Quality (DEQ)

• Hazardous Waste Section  
• Montana Department of Labor's School Science Lab Safety Guidelines

Environment Protection Agency (EPA)

EPA Toolkit for Safe Chemical Management in K-12 Schools
EPA's web-based tool kit helps schools start chemical management programs that will improve their chemical management practices by:

• Removing inappropriate, outdated, unknown and unnecessary chemicals from schools;
• Preventing future chemical mismanagement issues in schools through training, curriculum and policy change, and long-term management solutions; and
• Raising awareness of chemical issues in schools and promoting sustainable solutions.

EPA Chemical Management Resource Guide for School Administrators
EPA's guide helps schools and administrators reduce the use of dangerous chemicals and install safer chemical management practices and policies to protect against dangerous chemical exposures.

Before construction commences, plans for construction of a new school or an addition to or an alteration of an existing school must be submitted to the department or local health authority for review and approval. 
 

Where can schools submit preconstruction plans for review? 

Preconstruction plans may be submitted to the local health authority or the Department of Public Health and Human Services. 

Contact information for county sanitarians and local county health departments can be found here: https://dphhs.mt.gov/publichealth/FCSS/countytribalhealthdepts

Plans submitted to DPHHS should go to the Food and Consumer Safety Bureau, hhsfcs@mt.gov. 

Plans must include the following where applicable:

(a) location and detail of classrooms used for science or science laboratories, consumer science, art classrooms, art supply rooms, mechanic/carpentry, and industrial arts, including location and ventilation detail of lockable storage area of chemicals and other hazardous products;
(b) location and detail of janitorial facilities;
(c) specifications for the sewage treatment and disposal system to serve the school, except as provided in (2);
(d) specifications for the water supply to serve the school, except as provided in (2);
(e) locations for all emergency eyewash and shower stations, which must meet the American National Standard for Emergency Eyewash and Shower Equipment (ANSI/ISEA Z358.1);
(f) location and detail of laundry facilities including description of equipment and a flow chart indicating the route of laundry through sorting, washing, drying, ironing, folding, and storage;
(g) specifications for the final finishes of floors, walls and ceilings in toilet, locker and shower rooms, laundries, and janitorial closets;
(h) a statement from the designer of the facilities that lighting capable of meeting the minimum requirements of ARM 37.111.830 will be provided;
(i) location and detail of the solid waste storage facilities;
(j) name of DEQ-approved sanitary landfill which will receive solid waste from the school;
(k) specifications for a food service to serve the school unless the food service has been previously approved by the department and/or local health department;
(l) any other information requested by the department or local health authority relating to the health, sanitation, safety, and physical well-being of the teachers, staff, and students;
(m) specifications for any new or modified playground equipment, which must comply with the standards of the United States Consumer Product Safety Commission's Handbook for Public Playground Safety (2010 edition) and the requirements of the 2010 ADA Standards for Accessible Design;
(n) specifications for any new or modified air intakes; and
(o) specifications for any radon-resistant technique used in the building process.

Other Preconstruction Requirements

(2) If the sewage treatment or disposal system or water supply has been previously approved by the department and/or DEQ and is designed to handle any increased load necessitated by the school's use, the applicant need not submit system specifications, but must submit written certification that the owner of the system has agreed to provide service.

(3) Schools must be constructed in locations which present the least risk of exposure to pollutants or other health hazards originating onsite or offsite. If potential environmental concerns are identified during the preconstruction process, and the Local Education Agency (LEA) still desires to consider the site, a more comprehensive environmental review must be performed with the help of the department, the local health authority, or DEQ.

(4) The topography of the site must permit good drainage of surface water away from the school building to eliminate significant areas of standing water and infiltration of surface water into the school building.

(5) All chemical storage areas in new construction must be constructed to maintain negative air pressure to eliminate contamination of the school's indoor air quality by being vented to the outside of the building.

(6) Gas supply lines serving science laboratories, consumer science, industrial arts, and other rooms utilizing multiple outlets must have a master shut-off valve that is readily accessible to the instructor or instructors-in-charge without leaving the classroom or storage area.

(7) Industrial arts classrooms or buildings and other rooms using electrically operated instruction equipment which presents a significant safety hazard to the student utilizing such equipment must be supplied with a master electric switch readily accessible to the instructor or instructors-in-charge without leaving the classroom or storage area.

(8) Janitorial storage spaces must be constructed to meet the following requirements:

(a) must be lockable;
(b) must include a storage area for equipment and chemicals; and
(c) must be vented to the outside of the building.

(9) Hot and cold water must be provided to handwashing sinks and shower facilities. Hot water must not be below 100° F nor exceed a temperature of 120° F.

(10) The department recommends the use of radon prevention strategies in new construction.

37.111.810
INSPECTION

Representatives of the department or local health authority must be permitted to enter any school at any reasonable time for the purpose of making inspections to determine compliance with this subchapter. Annual inspections must be conducted by a school administrator, facility manager, or other staff member approved by the school administration, as well as having a department or local health authority inspection once a year, or as necessary. The department or local health authority may determine that special circumstances or local conditions warrant inspections with greater or less frequency. Upon receiving a complaint, the local health authority may determine if more inspections are necessary.

Please Remember:

• Inspections of school facilities must be done using forms approved by the department.
• Inspection records must be kept on file at the school for at least three years from the time of inspection.
• Following each inspection, representatives of the department or local health authority must give the school administration a copy of an inspection report which notes any deficiencies and sets a time schedule for compliance. The report must document deficiencies.

Inspection Forms

The following forms have been created by the Montana Department of Public Health and Human Services for us by County Sanitarians. 

• School Inspection Report
• School Inspection Report- Fillable

Medication Administration, Storage, & Disposal

Beginning September 1, 2021, the school shall have and follow written policies and procedures regarding the storage, administration, and lawful disposal of prescription, nonprescription, and over-the-counter medication.

Medication Storage
All non-emergency medication must be kept in a locked, non-portable container, stored in its original container with the original prescription label. Epinephrine, naloxone, and student emergency medication may be kept in portable containers and transported by the school nurse or other authorized school personnel.

Food is not allowed to be stored in refrigeration units with medication.

• This does not apply to food used exclusively for medication purposes.
• As an alternative to purchasing separate refrigerators, schools may purchase a medication lock box which can fit in an existing refrigerator.
  • Lockable Medication Box Refrigerator Mount
  • Small Locking Refrigerator Storage Box
  • Refrigerator Medical Lock Box
  • Refrigerator Narcotics Box

Medication Administration 

• Montana School Nurse Delegation Decision Tree

Medication Disposal

• RX Dropbox Locations
  The Department of Justice maintains a list of over 50 permanent prescription drug drop locations from Browning to Baker and points in between.
• How to Safely Dispose of Old Medicines (American Academy of Pediatrics)

Breast Feeding Accommodations

The school must provide reasonable accommodations for students and staff on the school campus to express breast milk, breastfeed an infant child, or address other needs related to breastfeeding. Reasonable accommodations include, but are not limited to:

• access to a place, that is shielded from view and free from intrusion from the public, students, and other staff, to express breast milk or breastfeed an infant child;
• permission to bring onto a school campus a breast pump and any other equipment used to express breast milk;
• access to a power source for a breast pump or any other equipment used to express breast milk; and
• access to a place to store expressed breast milk safely.

Support

Montana State Breastfeeding Coalition (MSBC)
The MSBC supports, promotes and protects breastfeeding for a healthier Montana. Each year the MSBC offers educational breastfeeding scholarships and local coalition building grants. The MSBC also supports breastfeeding policy and lactation accommodation worksite initiatives.
https://www.mtbreastfeedingcoalition.com/

Livestock & Poultry in Classrooms

To reduce the spread of animal-borne diseases, livestock and poultry must be located more than 50 feet from food service areas, offices, or classrooms except those offices and classrooms associated with animal husbandry activities or other demonstrations as approved by the school administration. In classrooms, offices, or food service areas where livestock and poultry are approved by the administrator, animals must not have contact with eating or serving surfaces.

Playground Safety & Inspections

Playground and school yards must be inspected every month by the facility manager or other school personnel and the inspection must be recorded and records kept on the school site. Inspections must be conducted using a playground safety checklist approved by the department . Playground equipment must be maintained in a safe condition. Playground inspection results must be made available for review by the local health authority or the department upon request. Periodic maintenance and repair must be performed on playground equipment according to the manufacturer's specifications. Repairs, not including the leveling of fall protection material, must be documented.

Resources

• National Program for Playground Safety
  • Public Playground Safety Handbook
  • Guidelines, Standards, and Best Practices
  • Maintenance Plans

Training Videos/Webinars

National Recreation and Park Association: The ABC's of Playground Safety

School, Community, and Youth Programs Online Inspector Course from the National Program for Playground Safety
Through this self-paced, four-week course, you’ll become a Certified Outdoor Play Inspector, enabling you to inspect outdoor play areas in school, community, and youth program settings for children ages 5 to 12 years.
Cost: $550
*This course is not required, but it is recommended by DPHHS.

First Aid Kits & AEDs

First aid kits and AEDs must be provided and stored in accessible locations that are easily identifiable to staff and trained personnel.

Communicable Disease Reporting

If a student or a staff member develops symptoms of any reportable communicable or infectious illness as defined by ARM 37.114.203 while at school, the responsible school officials shall do the following:

• if the individual is a student, inform the parent or guardian as soon as possible about the illness and request him or her to pick up the student; and
• consult with a physician, other qualified medical professional, or the local county health department to determine if the case should be reported to the local health officer pursuant to 37-2-301, MCA.

New Lead Testing Requirements

Among other long standing requirements in the Water Supply System section of the school rule, language was added which requires schools to test all human consumption fixtures for lead.

Schools must sample all water fountains and sinks used for food preparation.All other potential human consumption fixtures (HCF) must be sampled, unless the school or school district submits a testing plan to the DEQ to test a representative sample of potential HCFs in the school. Proposed testing plans will be approved or denied by the DEQ. Initial samples must be taken by December 31, 2021. All samples must be analyzed by a Montana certified lab using EPA-approved standard drinking water methods for the detection and quantification of lead.

37.111.832 WATER SUPPLY SYSTEM
(Complete Section)

DEQ
Lead Testing in Schools: Drinking Water Program

The Department of Environmental Quality is partnering with the DPHHS to provide technical assistance and guidance around lead testing in schools. Please visit DEQ's Lead Testing in Schools Drinking Water Program website for all you need to know about lead testing.

These rules remain largely unchanged. New addition require to school districts to establish and maintain a policy on how to safely clean up bodily fluids and dispose of the use cleaning supplies. Cleaning supplies need to have EPA registration number and use by dates and must be stored out of the reach of students. Safety data sheets must be kept with hazardous cleaning supplies. DPHHS is recommending that schools use "green cleaning products". The definition of solid waste also now includes recycling material. 

Solid Waste, Laundry Facilities, and Cleaning and Maintenance Rules
-View Complete Section-

Green Cleaning

Cleaning products are important for maintaining a sanitary environment in schools. However, chemicals in cleaning products may be hazardous to the environment and to the health of students, maintenance workers, and other school staff. "Green cleaning” reduces environmental and health risks by selecting alternative, environmentally-sensitive products, by applying these products properly, and by implementing maintenance practices that minimize exposure to cleaning products. Over the past several years, many school districts have begun to adopt green cleaning programs and practices.

Definition:
"Green products" means products and services that have a lesser or reduced negative effect on human health and the environment when compared with competing products or services that serve the same purpose. This comparison applies to raw materials, manufacturing, packaging, distribution, use, reuse, operation, maintenance, and disposal. These products have a "Green Approval Stamp" certified by at least one of the following organizations: Green Seal, UL ECOLOGO®, the EPA Safer Choice, and the USDA Bio-Preferred.

Resources

• Healthy Green Schools and Colleges
  Healthy Green Schools & Colleges provides school facility leaders with resources to transform the health and sustainability of school and university environments without making major capital investments. The multifaceted program includes education; a network to accelerate the adoption of best practices; certification standards and implementation guidelines, and public recognition of the leaders who achieve success.  
  
  
• Healthy School Campaign
  Healthy Schools Campaign (HSC), a national nonprofit organization, works to ensure that schools can provide students with healthy environments, nutritious food, health services and opportunities for physical activity.
   
• National Center for Education Statistics
  This site conveys strategies for planning and implementing “best practices” for maintaining facilities and grounds. 
   
• The Center for Green Schools 
  The Center for Green Schools at the U.S. Green Building Council believes that all students deserve to attend sustainable schools that enhance their health and prepare them for 21st century careers. To support high-quality education for sustainability, the Center for Green Schools created and maintains Learning Lab, which offers over 500 lessons in English and Spanish from a dozen partners, all aligned with curriculum standards.
   
• Healthy Sustainable Schools: Guide for Change 
  This guide from the Minnesota Pollution Control Agency is designed to provide parents and school officials with resources to help them create healthy sustainable schools. In addition to protecting the health and improving the performance of building occupants, the actions outlined in this guide can also save schools money in the long run. 

Additional Resources

Recycle Montana
Recycle Montana is a statewide non-profit, member based organization which serves as a resource for local governments, businesses and individuals seeking education, technical expertise and networking opportunities to increase recycling in their communities.  The organization consists of a resourceful group of dedicated people and organizations that collectively work together to improve and grow recycling in Montana.

Integrated Pest Management

New language was added to the school rules requiring schools to develop and implement an integrate pest management (IPM) program beginning September 1, 2021. The school IPM program must include strategies to prevent the spread of pests and whenever practical, the school must ensure the use of non chemical methods to control pests, including proper sanitation practices, structural repair, and window screens. The rules include specific instructions for notifying guardians and the public when pesticides are used.

Example IPM Programs

• Generic School IPM Template

Model IPM Policies & Plans

• Sample Plan #1
• Sample Plan #2

Pesticide Use Reporting

• Reporting Requirements
• Pesticide Application Notification
• Example letters to parents/guardians
  • Example letter #1
  • Example letter #2
• Signage templates
• Pesticide Application Log