In recent months our office has received calls from school administrators asking this very question. This question is in regard to the new environmental standard N.J.A.C. 8:50, Indoor Environmental Health Assessment, which was adopted by The New Jersey Department of Health and Senior Services (NJDHSS) on September 8, 2009.

Those of us in the environmental field know that interpreting a new environmental regulation usually results in some initial confusion.  The Indoor Environmental Health Assessment (IEHA) Standard is no exception.

In the past, childcare centers were required, by the Department of Children and Families (DCF) to perform a Preliminary Site Assessment (PA) in order to obtain a license for operation. The preliminary assessment helped to identify if the actual property was contaminated and therefore posed a potential environmental risk.  This assessment was conducted, usually by an environmental consultant, and then submitted to the New Department of Environmental Protection (NJDEP) for review and approval.  Once the NJDEP approved the PA, the DCF would issue the license to the child care center.

With the promulgation of N.J.A.C. 8:50, the NJDHSS requires additional evaluation of buildings used as child care facilities.  The new regulation requires that an IEHA be performed and submitted to the NJDOHSS in order for a school to obtain “A Safe Building Certification.”  The IEHA is an evaluation that is conducted to assess conditions inside of a building which may impact the health of its occupants.   Based on the most recent guidance set forth by the NJDHSS, the standard mandates the following:

1.    An IEHA must NOW be performed by a Licensed Environmental Consulting Firm.

2.    All schools, including public, private and charter schools, not just Childcare Centers are defined as Educational Facilities. Therefore these schools fall within the mandates of the new regulation and based on site specific conditions, and may be required to conduct an IEHA.

3.    An IEHA must be conducted in a building to be used as a child care center or educational facility if:

a)    the building undergoes renovations for use as a child care center or educational facility.

b)    at one time the building was used for industrial purposes, or was a nail salon or gas station.

c)    the building was built prior to 1979, regardless of the building’s present condition or past uses.

d)    the childcare center is a new facility (a brand new business or a facility that has not yet been inspected by the NJDHSS).

As you can see, accurately interpreting the regulation is important and can be confusing.  The above outlined information was compiled after careful review of the standard as well as our most recent conversations with the NJDHSS.  In the final analysis, the need for an IEHA is determined by evaluating site specific information for the educational facility in question.

Does Your School Need an IEHA? As a Licensed Indoor Environmental Consulting Firm, GSE can guide you in understanding the details of the regulation and assist you in evaluating the needs of your school.

Call today for an IEHA consultation.