Dear Commissioner Frieden, Chancellor Klein, and President Greenberger: Given the April 7, 2008 Daily News story revealing that low levels of Polychlorinated biphenyls (PCBs) were detected in the first-floor cafeteria of P.S. 199, located in my State Senate District, I appreciate that an emergency meeting was called at the school that night. I sincerely regret that I was unable to attend, as I was in Albany, but my staff informs me that representatives from all three of your agencies were present and brought in-depth information sought by the community.
In reviewing the Department of Education's (DOE) study, which was distributed at the meeting, I was comforted by the fact that PCBs were either not detected or below EPA standards in the air and on surfaces throughout the tested portions of P.S. 199. However, it is important to note that this study was undertaken weeks after replacement of the schoolfs windows would have disturbed PCBs in the caulking. I was disconcerted to hear that construction workers, custodians, teachers, parents and even students participated in removing the dust that had blanketed classrooms and the cafeteria throughout the replacement project, all without proper warning or safety protocols.
While any exposure to these toxins that may have already occurred cannot be undone, I urge you to honor the requests made by the P.S. 199 Parent Teacher Association (PTA) in its April 3, 2008 and April 9, 2008 letters, and to take the additional steps proposed at the April 7th meeting, many of which will benefit not only P.S. 199 but also schools throughout our City. These include:
Stop all work on P.S. 199's windows and doors until the toxicity of the remaining caulking can be tested and properly addressed. Parents must be made confident that further work will not expose their children to potentially hazardous dust. More stringent protocols and/or better supervision might be necessary to ensure that the dust is managed more effectively.
Test dust wipe samples and core samples of the playground and surrounding soil, respectively. I was disturbed to hear that parents reported seeing the detached windows being dropped and dust flying through vents and spreading to areas where the children are most likely to gather during recess. Again, there must be protocols enacted to prevent these accidents from occurring again.
Test air quality and dust wipe samples in other schools that were constructed while PCB-laden caulk was in use. Schools that are currently undergoing the kind of work that was done at P.S. 199 should be tested first, both to ensure that students of these schools are not in danger and to provide an estimate of the levels of toxicity that were likely present at P.S. 199 during its replacement project.
Share all pertinent information, including safety protocols and test results, not only with the school administration, but also with the PTA. More generally, I urge you to engage the PTA whenever possible.
Notify, in advance, the school administrations and parents of students of all New York City public schools in which construction involving potentially hazardous materials is to occur. At the April 7, 2008 meeting, a representative from the DOE explained that testing of caulk in schools is not done because current School Construction Authority (SCA) protocols start with the assumption that dangerous levels of PCBs are present. Although the agencies and its contractors might have been aware of this assumption, nobody in the P.S. 199 school community was so notified.
The DOE and the Department of Health and Mental Hygiene (DOHMH) should work together to establish contact people and/or other resources for parents who suspect that their children may have been affected by PCB exposure.
Lastly, I urge you to work more closely with the community and its elected representatives. Parents and teachers should have been notified before information was released to the press. Likewise, as a State Senator representing the 29th district, I should not have had to learn about a major health concern at a school in my district in the press when City agencies were aware of the issue days in advance.
I thank you all for your service and dedication to the safety of the children of our great City and I hope that you act expeditiously on these concerns.
Thomas K. Duane
New York State Senate