Smelly Stuff

Good morning and Happy Thursday!  As we are in the middle of fire inspection season, we want to highlight some questions and provide some guidance, on the stickier issues that we face across the region.  The unfortunate part is that we do live in a gray area from time to time.  When these “gray areas” exist, the responsibility ultimately falls upon the districts when a black and white code, regulation, or standard does not fit nice and neat.  The stickier one we get is the utilization of fragrances, air fresheners, plug-in, diffusers, etc.  The attachments are from the NYS Office of General Services offering guidance on this question and a sample policy, if districts choose to make their schools “fragrance-free,” through the Cleaning for Healthy Schools program.

The following is a summarized email to one of our districts that contains how we approach and excerpts from advisements we have received from the State.  The italicized portion is from the NYSED Fire Desk and the bolded is from NYS DOH as referenced by the Fire Desk:

There are three things to consider with scent diffusers and aromatics but ultimately, it comes down to a school district’s decision if there are no Code Non-conformances or Hazard Communication Plan (PESH) violations by not providing Safety Date Sheets of all chemicals in the workplace:
1.  If it is electrically operated it must be listed and labeled by an approved testing agency, e.g. UL/ETL and if not, then it is unsafe underneath the fire code as an electric hazard.
2.  There needs to be an SDS sheet provided for the chemical that is emitting the fragrance, which are VOCs.  If one is not provided, then this violates your Hazard Communication Plan (PESH) and possibly your District’s Chemical Hygiene Plan.  There are some districts that have something like the attached document on a “fragrance-free classroom policy” to consider as well.
3.  There needs to be strong consideration given to the impacts on indoor air quality which can have direct consequences on other employees’ and students’ health in the form of asthma, allergy, and/or migraine triggers.  This an excerpt from NYSED Fire Desk email, with the DOH referenced, when we have posed this question to them.

Thank you for reaching out with your concerns.  You are not the only person who has asked this question.  The NYS Health Department (NYSDOH) has a site dedicated to school environmental health program topics (Asthma & Air Quality included) here: https://www.health.ny.gov/environmental/indoors/healthy_schools/topics.htm#indoor

 

The main source of concern with aerosol products is in changing the air quality in a space.  These products can become asthma triggers in people who are sensitive to them.  Currently there are not any laws or regulations about having aerosols in schools outside of the green cleaning program.  Schools are required to purchase Green Cleaning Products to help keep the air quality in schools safer (https://www.p12.nysed.gov/facplan/GreenCleaning/greenclean.htm). 

 

Also, schools are required through OSHA/PESH law to maintain a Safety Data Sheet (SDS) on file for all chemicals it purchases/uses on school grounds to maintain the health/safety of staff & students.  SDS’s come from the product manufacturer, and they contain the ingredients in the product along with health/safety, first-aid, disposal, and emergency handling of that product.  Schools are not required to have any chemicals on their grounds without having an SDS on file.  Staff that bring chemical containing items from home are unknowingly violating this law since the school has no idea it is being used.

 

Fire safety can be factor when these products are introduced into the school environment through electrical devices that may not be Underwriter’s Laboratory (UL) approved and could become a fire hazard to the building if they have a failure while in use.

 

Below is information we received in the past from NYSDOH on this topic:

 

Based on our discussion regarding an increase in use of essential oil diffusers in classrooms, I did some research on the topic and how it can potentially affect IAQ and exposure scenarios. Based on that research along with discussions with DOH staff, we offer the following recommendation.

 

Since there are no formal policies on the use of such products at present, and we likewise do not have a policy on their use. However, consistent with our messaging regarding exposure (https://www.health.ny.gov/environmental/about/exposure.htm) and the prevalence of Volatile Organic Compounds (VOCs) in many similar products, (https://www.health.ny.gov/environmental/air_quality/vocs.htm) we recommend not using products that intentionally release VOCs in to the air.  Ultimately, it would be up to the individual school districts to develop such policies.

 

 

Here are additional resources available to schools that include eliminating aerosols like essential oils from schools:

 

NYS Guide for Asthma Management in Schools(pp 7 & 30):

http://www.p12.nysed.gov/sss/documents/NYSguideAsthmaManagementinSchools.pdf

 

American Lung Association (Asthma-Friendly Schools Initiative):

https://www.lung.org/lung-health-diseases/lung-disease-lookup/asthma/health-professionals-educators/asthma-friendly-schools-initiative

Unfortunately, this is often a difficult situation to handle but having a standard approach may help alleviate that confusion.  Stay well and keep warm out there!

Tim Richardson:
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