The Michigan Department of Education (MDE) together with the bureau of fire services and the State Fire Marshal in the Michigan Licensing and Regulatory Affairs (LARA) have released joint guidance for schools on conducting statutorily mandated safety drills in light of the challenges posed by the current pandemic. The document offers suggestions for how to adapt drills (primarily fire drills) to accommodate things like social distancing and hybrid learning and covers some general safety considerations for schools. Unfortunately, Michigan's drill laws were not written to accommodate the current situation facing schools and it would require legislative action to provide for things like waivers for schools that are fully virtual, so the guidance document is not a panacea and still leaves a number of questions unanswered. Still, it is more than schools have had to this point.
MASSP and other stakeholders are working jointly with the Department to pursue better options moving forward. In the meantime, here's a quick review of some of the key points in the guidance document:
Staggered release for classrooms and alternative evacuation locations is just fine to help maintain social distancing during an evacuation drill. The guidance acknowledges that " it may take more time to conduct the drill and accommodate the need for social distancing."
For hybrid schedules, drills will need to be conducted with each group of students on their respective days in school, but each drill conducted with a group may count as a separate drill for fulfilling the requirements of the statute. Per the guidance "For example, group A attends in-person instruction on Monday and Tuesday. Group B attends in-person instruction on Thursday and Friday. School administration conducts drills with group A on Tuesday and group B on Thursday. This will count as two drills."
The first set of three fire drills must be conducted before December 1 and, in a hybrid environment, each group must have at least one drill before the designated deadline.
Hand sanitizer is classified as alcohol-based hand rub (ABHR) and is subject to specific rules and regulations when used in schools. Specifically, NFPA 101, Life Safety Code, 2012 Edition is referenced by the school fire safety rules and has specific requirements for use of ABHR as follows:
- Dispensers shall be installed in rooms or spaces separated from corridors and exits and are NOT permitted in corridors
- The maximum individual dispenser fluid capacity shall be as follows:
- 0.32 gal (1.2 L) for dispensers in rooms
- 0.53 gal (2.0 L) for dispensers in suites of rooms
- The dispensers shall be separated from each other by horizontal spacing of not less than 48 inches (1,220 mm)
- The dispensers shall not be installed over, or directly adjacent to, an ignition source such as light switches or receptacles
- Dispensers installed directly over carpeted floors shall be permitted only in sprinklered rooms or spaces
- The storage of ABHR is strictly regulated due to its flammability; storage of more than five gallons is required to meet the following conditions:
- ABHR may not be stored in a basement.
- Quantities of more than five gallons shall be stored in a listed flammable liquids storage cabinet.
- If the above criteria cannot be met, the ABHR should be stored in a separate building from the school and only dispensed as needed.