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My name is Schuyler Jeffries. I am an Architect of over 35 years experience in California and have been involved, as a principal in my own architectural firm, with over $100 million dollars worth of educational facility design and construction in California. I am currently working as a Vice President of GV Custom Modular Construction in California.

More specifically, I am here as a representative of the School Facilities Manufacturing Association, which represents approximately 75% of all modular manufacturers doing educational facility construction in California.

As I understand it, we are here today to address the issue of indoor air quality or IAQ in portable classrooms, the assumption apparently being that IAQ issues are unique to portable classrooms and modular construction.

We believe this assumption is incorrect. No less an authority than the California Department of Health Services supports this position. In recent publications by the DHS, the Saugus Union School District studies and the DHS IAQ assessment, the conclusion reached is the IAQ is a concern common to all educational facilities. In fact, at the Downey hearing Educational and Scientific representatives established there is no significant difference between modular/portable construction and conventional school construction particularly as to IAQ issues.

In sum, I believe that the information presented at Downey permits only one conclusion, that if there is an IAQ problem, as it relates to educational facility design and construction, then State Government, School Districts, Architects, General Contractors, Sub Contractors, Suppliers, and Modular Manufacturers must work together to address this common problem for all schools.

Before I address what I believe to be misconceptions about portable building construction, permit me to detail the construction requirements for factory built school facilities.

As you probably know, ours is a heavily regulated and heavily supervised industry, controlled by the dictates of such agencies as DSA, (Division of State Architect) and OPSC (Office of Public School Construction). Let me briefly highlight the degree of regulations promulgated by these agencies:

1-OPSC issues plans and specifications for State Emergency Classrooms which dictate how the portable classroom is constructed.

2-The OPSC specifications require the use of designated building components including those commonly used in the construction industry for conventional educational construction.

3-For non-OPSC emergency classroom projects, the school district's Architect, referred to as the Architect of Record, develops the design and specifications for the school district prior to letting the project out for bid. We, the manufacturers must adhere to those documents or our bids would be rejected. This is the identical process for conventional construction.

4-State standards dictate that the heating, ventilating and air-conditioning (HVAC) units must meet certain ventilation requirements (A classroom must provide not less than 15 cubic feet per minute of outside air per pupil).

5-Unless DSA reviews and approves the design and construction of each of these portable classrooms or modular facilities, they cannot be purchased or used by the school district.

Not only does the state approve the design of the portable classrooms and modular facilities, DSA has state approved inspectors conduct in-plant inspections and field inspections prior to any final approvals and student occupancy.

These mandated criteria apply equally to factory built or conventional construction. With this in mind, I want to challenge certain misconceptions about portable construction, a number of which were raised at the Downey hearing.

First, the word portable is not synonymous with the word temporary. Portable facilities are factory built buildings, which offer the school district the ability to relocate the units as their needs dictate.

Secondly, an issue was raised that conventional school classrooms can have 2 exterior doors but portables can have only one. The state code does not require 2 exterior doors in a classroom unless the classroom exceeds 1000 sf. If the district wishes to have 2 exterior doors, that is their prerogative. Actually with a portable it is probably easier to provide the second door because most portable classrooms have moment resistant frames, allowing doors and windows in almost any location. In comparison, most conventional school construction requires shear wall construction, which limit the location of exterior doors and windows.

Third, a question of adequate window size and window ventilation was raised. As noted above the portable may have greater flexibility than the conventional construction. The portable can be designed with almost any number of window types, sizes, and operable windows providing natural ventilation. Again, the choice remains that of the school district and its architect.

Another speaker suggested that portables were constructed utilizing different energy standards than conventional construction. This is not true. Portable buildings are subject to the same state energy standards as are conventional schools.

The Downey hearing helped identify the fact that there is no significant difference between modular or portable construction and conventional school construction with respect to IAQ. The absence of construction differences directed focus to the critical issue of how to solve IAQ problems, to the extent these exist. In this regard, we learned that school furnishings are a major source of indoor air contaminants. Accordingly, this IAQ factor can be addressed. Secondly, we were told that ventilation is the definitive cure towards operation, maintenance, and inspection of all facilities. Finally, one conclusion to draw from the hearing discussion is that IAQ guidelines and standards need to be developed and implemented accordingly.

We want your committee to know that we are ready, willing and able to assist you in investigating IAQ issues and will work with any state agency to reach solutions to the problem, beyond what is the obvious immediate response – improving ventilation, which both the DHS and EPA have determined is the key to resolving air quality issues.

In fact, SFMA and CASH are developing a workshop program to include all affected parties. Our target dates for the initial workshops will be in January. There would be follow-up in the February CASH state conference in Sacramento. I will be reviewing the details of the workshops with our SFMA executive committee within the hour. Dave Doomey, President of CASH has indicated his support for these workshops.

We look to your committee to assist our public-private sector initiative by the following:

1-Help identify roles for various existing state agencies. Also, let's not reinvent the wheel by utilizing all available relevant scientific information.

2-Initial suggestion of workshop organization:

a-Standard setting (DHA, EPA, CDE, Toxicologists, Environmental consultants, etc.)

b-Designers (OPSC, CASH architects, etc.)

c-Regulators (DSA, etc.)

d-Builders (SFMA, etc.)

e-Users (CASH maintenance and operations, etc.)

Thank you for listening to our testimony for the second time. I hope, as we said in Downey, that we can work together to assist all school districts in our joint quest for safe schools,