Using School Health Regulations for School Health Policy and Environmental Change

 

The Rules and Regulations for School Health Programs are jointly promulgated by the Rhode Island Departments of Health and Education.  These regulations have the power of law and have been used to bring about policy and environmental change in many areas of school health.  Three examples are provided here:

§        Playground safety:  All school playground surfaces and equipment must comply with the most recent version of the Handbook for Public Playground Safety issued by the U.S. Consumer Product Safety Commission.

§        Chemical safety:  A list of over 500 chemicals with toxic, explosive, carcinogenic or other unsafe effects have been banned from schools, effective August 31, 2005.  These products may not be purchased or stored on school property.

§        Diabetes care:  Schools must have policies in place that allow students with diabetes to self-manage their symptoms in the classroom or in any other spaces in the school, including self-testing, snacks, water, etc.

 

The intended outcomes in these three areas are:

§        Playgrounds:  to ensure that all school playgrounds meet the US Consumer Product Safety Commission guidelines to reduce risks of injury.  Playgrounds were to meet guidelines by July 1, 2002.

§        Chemical safety:  to ensure that high risk chemicals (explosives, carcinogens, toxins, etc.) were permanently removed from all RI schools to reduce incidences of injury or disease caused by these chemicals.  No purchasing of banned chemicals by October 2003; no banned chemicals in schools by August 31, 2005.

§        Diabetes care:  to ensure consistent policies across districts and schools within districts that promoted self-management of diabetes to allow for tight control of symptoms to reduce long-term health effects and acute episodes in school.  Policies to be in place by August 31, 2005.

 

Policy/Environmental Change Initiation

 

Playgrounds - CDC-funded an injury prevention project that assessed all school playgrounds and produced a report summarizing the findings that demonstrated high risks in many of RI’s school playgrounds.

 

Chemical safety - A multi-agency, public-private partnership was aware of high risk situations in science laboratories in schools.  Members included the Department of Health, Department of Education, Department of Environmental Management, Department of Labor (OSHA unit), Brown University, Community College of Rhode Island, Rhode Island Committee on Occupational Safety and Health, as well as private industry, and others.

 

Diabetes care - Grassroots efforts of parents with children with diabetes, along with multiple requests for clarification of policy by school nurses and administrators necessitated the need of a systemic approach to diabetes care management in schools.

 

Public Health Agency Roles

 

The Rhode Island Department of Health worked collaboratively with the Department of Education to:

§        Convene stakeholder groups;

§        Provide technical and content expertise;

§        Provide testimony at hearings;

§        Organize and facilitate hearings;

§        Disseminate information;

§        Facilitate or participate in training and professional development;

§        Provide regulatory language;

§        Provide legal review;

§        Maintain regulations on website.

 

Major Partners

 

In addition to the Department of Health the following were major partners in this effort:

§        Rhode Island Department of Education for all sections of the regulations.

§        Other state departments, community based organizations, advocacy groups, professional associations, etc., as appropriate to content.

 

Official Support

 

The major public officials who supported this effort were the Commissioner of Education, Director of Health, Board of Regents, select legislators, and Directors of other state agencies as appropriate to content.

 

Results from the Policy/Environmental Change

 

There is an Annual School Health Report filed by districts reporting on compliance with regulations and statutes.  This allows State level tracking on self-reported compliance.  The Departments of Health and Education also track compliance by monitoring the level of complaints or questions of clarification regarding these policies and their impact on students, families and schools.

 

Opposition

 

1. Playgrounds - The opposition was from School Committees who knew that achieving compliance would cost money.  Support was secured when a two year compliance period, was added from the time of implementation of the regulation to the date it became effective.  Some schools felt they should raze the playground and not build another one, rather than pay for compliance. There is no data on which schools razed the playground, paid for compliance and or built a new playground.

 

2.   Chemical safety - Some science teachers were concerned about the list of prohibited chemicals because they used these items in instructive units and would have to change their experiments.  Everyone was concerned about the cost of the clean out, cost of doing the inventory, clean out and legally disposing of chemicals.  There was also concern that districts did not know enough about chemical disposal to do the job safely and didn't have funds to contract it out.  State and private partnerships provided funding and technical assistance to all school districts to ensure compliance

 

3.  Diabetes - No real opposition was experienced. There was a need to come to consensus on wording.

 

Lessons Learned

 

Key stakeholders from a broad range of constituencies must be involved from the early stages of policy or environmental change to surface concerns, to reach compromises, and to develop buy-in from stakeholders to support and implement changes.

 

Submitted By

 

Rosemary Reilly-Chammat                 

Manager, Coordinated School Health Program                

Rhode Island Department of Health

3 Capitol Hill

Providence, RI  02908

401-222-5922

401-222-1442 FAX

rosemary.reilly-chammat@health.ri.gov