Dr. Gary Richards approached GOOD Morning Wilton editor Heather Borden Herve at a recent Board of Education meeting, offering to speak on the record about the attention the Miller-Driscoll Indoor Air Quality issue has recently received.
We were eager to speak with him to pose our own questions on the IAQ issues and to ask him to respond to recent complaints parents have made. No question was off the record and he answered everything candidly.
Q: Where are the schools with regard to compliance with the law? It’s been asserted that the school has been out of compliance with the law for two years. Can you address that?
GR: I have the law in front of me, it’s PA 10-220, an “Act Concerning Indoor Air Quality.” One of the things that is absolutely accurate is that we have not been, I believe it has preceded me, for at least 10 years we have not participated in the Tools For Schools program. Tools For Schools is not mentioned under the statute, but we had not been involved with TFS for the time I’ve been in the district. I think one of the reasons is that the district had the wisdom to hire an HVAC technician who is very good, and he’s been with the district as long as I’ve been here. Once he came on board, he took responsibility for the program that we’ve had in the schools.
I went through the list of responsibilities under the law, that the program should include inspection or evaluation of the following:
- heating and ventilation systems—that’s his job description;
- radon levels in the water and air—we did not, as you know, do the retesting that should have been done, so that’s being addressed;
- potential for exposure to microbial airborne particles, including fungus, mold and bacteria—whenever we have a situation where we have wet ceiling tile or leak into a building, we address it, and if there is any mold that’s found, and you can usually see it and smell it, we immediately address it; in that 2012 testing there was one area they mentioned where there was some mold, and it was immediately addressed by the district;
- chemical compounds as concern for indoor air quality—we don’t have volatile organic compounds but I know the science people at the high school are very careful of the management of the chemistry supplies in the chemistry labs;
- degree of pest infestation—if we see any pest infestation, we address it
- degree of pesticide usage—there are very strict guidelines with what you can do with pesticides and we adhere to those
- ventilation systems—this is what Mark Esposito does, he works on our ventilation systems to address any issues
- moisture incursion, overall cleanliness, building structural elements (roofing, basements, slabs)—those are areas that are always under inspection under the normal course of maintaining our buildings
- provision of indoor air quality maintenance training for staff—I think that’s an area where we’re going to do some additional training. That’s what Tools For Schools is. We’re also going to do some advance training for the custodial and maintenance staff as part of the TFS;
- green indoor cleaning—I believe we are a year ahead of the state guidelines on that, making sure we’re using green indoor cleaning products.
That’s what the law says, and we’ve been following that. It’s true that we did not do Tools For Schools, but we’ve addressed that and we will be having the training for our committees for all of the schools later this month.
Q: But in terms of being compliant with the law, it does fall down to that radon testing, about having not followed up on it.
GR: We’ve been very clear with the state, when we realized, that it was brought to our attention that we hadn’t done that, I believe the time that we would have done it we were transitioning from one maintenance director to another. Which is no excuse, but it’s the kind of thing that can happen sometimes. It isn’t something that was part of our thinking as we were getting a new person into the job [Maintenance Supervisor] and the whole Miller-Driscoll project, and all the other things we’ve been working on.
We’ve been very clear with the state, and have talked to people in the Department of Public Health, and with Ken Foscue, the Director of Tools for Schools.
We’ve admitted it, and we’re rectifying that. It’s not something we’re going to be taken off in leg irons and chains. It’s not something I’m proud of. It happens. I think if you checked around, there are probably other districts who have fallen off the Tools For Schools. I think it’s a good program and we’re going to get back on it.
Q: What do the schools have to do to become compliant with Tools For Schools?
GR: First there’s a training program. You have an intensive training program that a committee [at each school] goes through, and I believe they develop check lists and I believe they do periodic tours of the building. And they issue a report that may or may not have action items on it. I think that’s the overview of it. It’s more an education program. You teach people about indoor air quality, the committee helps staff and people who work in the building, as they learn more about it, about things that we need to be careful about.
For example, if you have ventilating units in a classroom, one of the things is you don’t put plants or books on top, you don’t stack things on top. It’s things like that. You don’t turn it off if you’re in a season where you don’t have open windows, so you try to make sure the unit ventilators are working as they’re supposed to work. It’s an educational program.
The key point, it’s important to have staff report something, if they see something, if they see a wet ceiling tile or some moisture from a piece of equipment, that they let someone know about it so it can be addressed. It’s that kind of education.
Q: With regard to the need to retest Miller-Driscoll for radon levels, and the state not accepting the report. Who didn’t follow the correct protocols, was that [the testing company] ATC? How did that happen?
GR: We’ve thought a lot about that. I’m reluctant to, whenever you engage in finger-pointing, what is that old line, when you point a finger at somebody, three or four are pointing back at you. I don’t think finger-pointing is productive.
I think it’s a combination of things. One, we own it. I think it was our lack of familiarity with the protocols.
I think a second variable, we received some mixed messages from some of the people in the State DPH about the protocols. And basically we did not notify the parents in writing that we were going to be testing 14 days in advance. There was some confusion—is it a requirement or is it a guideline? But it is something the state insists upon and needs to be followed.
I think a second protocol that was not followed was the state wants to have the buildings tested while they are occupied. I think the state wants to have what the levels are when you have people in the building. What happened with us one of the days of the testing was Election Day, which was staff development day. We had people in the building but it wasn’t a fully occupied building.
The third thing that happened, as luck would have it, the second day was an unseasonably warm day. We had some windows—again it’s been debated whether it’s 5, 6 or 7 windows—open for a period of time, which could have been a few minutes or it could have been longer. And that’s a violation of the protocol.
So there are three things not done properly. I think there was a misunderstanding, there was miscommunication. I don’t want to put the blame on ATC, the issue we didn’t mention [to them] that one of the days was a staff development day, and they may have assumed that kids were still in school. That could have been an honest mistake. I don’t think it’s important to beat up on them for that.
When we talked to the state supervisor for radon at the state health department, we got the clear understanding for what we needed to do. We worked with ATC and they agreed to retest, and that we would have a much more detailed briefing, and that we would comply scrupulously with the protocols on the retest that will be done, without any additional cost to our taxpayers.
Q: There’s question of testing 10 percent vs. 100 percent of the space in the schools?
GR: We have to do 10 percent, and when we did testing where we had some problems, we chose to do 100 percent. Again, I think there was confusion there. I have to own some responsibility for that. When you test for radon, you only test for the ground floor rooms, not second story rooms. And we have some classrooms that are second story, and those wouldn’t have been tested. We agreed to do 100 percent of the ground floor rooms. And we will do that again when we retest.
Q: And the other three schools?
GR: They will be retested, and we’ll do 10 percent.
Q: For carbon dioxide, there are recommendations from OSHA, and Tools For Schools has recommendations which look different—
GR: That makes all of this a difficult subject. The CT Dept. of Public Health [handout], which is on the Miller-Driscoll website, the first bullet says, “No appropriate standards for indoor air quality…” I think there are some guidelines, and I think the issue about CO2 is, according to hygienists I’ve spoken to and the TFS people, the test is how much fresh air is being circulated; it’s a test for ventilation. It’s really a smell issue—having fresh air in the classroom. One of the thing we are doing in every one of the building projects we’ve done, we’ve looked at putting in new HVAC systems, because the technology changes. You want in schools to have the best exchange of air that you can. That’s why we did a complete renovation of the HVAC at the high school.
It’s not a health issue.
When you get into the OSHA part, and this has been misinterpreted by some, OSHA also includes industrial areas. When you talk about 5,000 parts-per-million, that generally applies to industrial kinds of situations. In our settings, at Miller-Driscoll, all classrooms are of different age and different equipment, as the building was modified over the years. It’s unfortunate that it’s been interpreted that we are complacent about that. We want to see fresh air, we have worked with engineers and continue to do so to make sure we are doing what we can, given the state of the building to make sure we get the exchange of air as best we can.
It is not a health issue. It is not a health issue. I’ve heard this from doctors, from hygienists. It can be a stuffy room, and there are things we can do—we can open windows. Not now at these temperatures, but you can do that periodically, to try to increase the fresh air.
Q: You say it’s not a health issue, I’ve read that it can still impact concentration, learning—
GR: I don’t know how you quantify that. Is it good to, obviously we want to, that’s why we’ve been trying to get a building project through for nine years. But I don’t know how you measure that, the impact it has.
I don’t know how you isolate the variable. I’ve spent my whole life as an educator and teacher, and there are so many variables that affect performance, when you talk about performance. How long did the child get sleep? What kinds of activities are being done? What is the teacher variable in that? Are there other distracters? Obviously it’s hard to pin on one. I think we need to be careful about drawing conclusions that are not testable.
Q: But when you’re getting readings above recommended limits, regardless of whether or not you can measure the impact on learning, shouldn’t there be an effort to keep those numbers as low as possible?
GR: At the high school, the system we have, does a reset if it gets above 1,000 [ppm]. One of the things I’ve learned when you test, the amount of CO2 in a room can build. It might be at 700 or 800 ppm in the morning, and as kids are in and out during the day, there are variations. If you put a testing unit on the carpet when the kids are sitting there you’re going to get a higher reading than in another part. Yes, ideally, you want to shoot for 1,000, but it’s not a health issue per se.
That’s not to say we’re complacent, as we’ve been accused of. It’s not like we’re sitting back and saying, ‘As long as it’s below 5,000, we don’t care.’ No! You want to do the best we can, given that it’s a building that needs a new system as we did in each of the other schools.
Q: Given that the renovation or rebuilding issue hasn’t been put in front of the voters yet; knowing that the district is on the hunt for a new superintendent, should the town look at it as a more immediate priority to revamp or invest something in improving the HVAC system at Miller-Driscoll before the renovation project eventually gets put to the voters?
GR: I’ve thought about that. It’s a time-consuming process, and the building committee is being very thoughtful about this. But I don’t think it makes sense until you know what the extent of the project is going to be, you can’t address it piecemeal like that. There are so many inter-related variables, when you look at wiring, roofing structures, the kinds of units. I think that’s a very good question for the building committee co-chairs.
I think you do what you can, and we are looking to see what steps we can take to improve exchange of air, to get better levels.
We are doing some sampling testing, and there are some rooms that look a little higher and you look at what you can do with the unit ventilator in that room. Do parts need to be replaced in it? I think we’re trying to adopt an approach that’s intelligent. And I think we’ve learned that some of the teachers were turning units off in their classrooms, because of the noise. That’s not a new problem, and we have to figure out how to work around that, given the equipment.
Q: Is this an issue to get a fire lit to get something passed by the voters?
GR: I think the building committee has done a very thoughtful job of developing a statement of requirements for the project. They’re putting together a Frequently Asked Questions to educate the public about the needs of the building and the status of the project. And I think air quality is certainly a key component. We hope we can do a good job of educating the public so when it gets in front of the voters people can say it’s time and they support the project.
Q: What do you think about the vote that took place at the Dec. 13 PTA meeting, calling for additional CO2 testing at M-D?
GR: We have been doing some testing. We have a hygienist we’re working with who is looking at all of the reports and making recommendations. If he sees anything he’ll give us recommendations we can consider as to what next steps will be. We’ve also been doing spot testing to get more data to see where we are with ventilation in various rooms. That’s ongoing.
Q: Full disclosure, I voted to support that call for testing at the PTA meeting.
GR: I understand that. We know we have 40 year old equipment in those rooms. We know that there are more efficient systems that have been developed in the last 40 years. We’re addressing it. But I don’t want to convey that we’re going to spend all our time running around hour by hour, testing for CO2. We will continue to monitor and if there is equipment that is either malfunctioning or not being used properly, we will address it.
Q: I want to give you the opportunity to respond, since you’ve been challenged by parents, accused of violating policy and law. How do you respond to the contentiousness that’s built up about this?
GR: I’m not in the business and not in my career have I made a practice of saying I am going to violate policy or violate law. I think I’ve been pretty clear that although we did not have the Tools for Schools program, that we have in fact complied with the intent of the law. I don’t think that there are sanctions for the mistake that we made with the regard for TFS. I think I’ve tried to make the point of what we have done to fulfill the spirit of the regulations regarding indoor quality.
Q: I guess I’m asking in a personal way, about being challenged or accused?
GR: I’ve spent my lifetime trying to protect kids and staff, safety is first and foremost in my thinking. I’ve spent a lot of my career trying to insure people in our schools are safe, whether it be on school buses, or whether it be in the buildings or whether it be at extracurricular activities. I take that very seriously.
This is my 27th year of being a superintendent, and it comes with the territory. There are times when I think the criticism is deserved and there are times when it’s not. I’ve always strived to do the best I can and if I’ve made mistakes to learn from them, and to hopefully avoid them the next time the issue arises. But it’s a difficult part of the job, and we serve the public, and we’re fair game.
Q: There’s been a request for more public discussion on air quality. I don’t think the PTA is the right venue—
GR: No it’s not.
Q: I think it’s something that the Board of Ed should—
GR: I agree.
Q: —spearhead. More transparency is better, and benefits everyone. Has there been a call for more open discussion?
GR: I think those kinds of discussions in that [PTA] venue were not helpful. I think that the Board [of Education] is well aware of this issue, and I think that there will be more discussion in that venue about this in the months ahead. And I will do what I can to be more transparent about where we are on the journey. I think that’s the appropriate venue for that. I think it will be important to educate the public about these issues. That’s why I think working with physicians, with hygienists and with the state will help promote and disseminate information that will reassure parents that we are doing the best we can to address the air quality issues.
Q: Will there be more focus on communication with parents?
GR: I think we need to make sure that the communication we put out, there may be some who want to parse every sentence that we say. I don’t find that particularly helpful. But I think it’s important for us to figure out a way of disseminating information in a way that’s understood and that’s clear. We’re committed to doing that and we will do that.
Q: How do we know the air quality in the schools is safe today?
GR: At some point, I noticed in the information from the Department of Public Health, it said, “It’s difficult to interpret the results of air testing. This can add to the confusion and create an air of mistrust between the stakeholders and the administration that ordered the testing.” Obviously Wilton is not the first community to have experienced accusations that we are covering up things or that we are not being fully transparent.
I think that we will continue to work with the hygienists. We will communicate the results of the Tools For Schools, and studies that they come up with. We will act on recommendations. It’s our responsibility and we take it very seriously to make sure that our schools are safe. I believe they’re safe. The staff, the administration at Miller-Driscoll work in that building and spend a lot more hours than the students spend in the building, and I think they have a self-interest as well as a larger interest of making sure our kids and everybody in the building are safe.
There’s been no evidence that we have that the building is not safe. If we find anything that needs to be addressed, we will do so. I think the biggest thing we can do is get this building project through.