Frequently Asked Questions: Exterior Waterproofing and Paint Project

The project at Chinese Immersion School De Avila was prioritized because the building walls and windows have been leaking, letting water into the building. To protect the building long-term, the project scope includes removing exterior paint, patching and sealing any damaged areas, replacing windows, and repainting the outside of the building. This is an important investment in the school, and one that needs to happen before winter and the rainy season begins. SFUSD works hard to schedule construction work during school breaks whenever possible, but sometimes it is not possible to complete everything in these limited timeframes. Supply chain delays, contractor availability, weather, school events, and many other factors can all impact the schedule and extend the time it takes to complete a project. This is why some work for the current project at CISDA is extended into the school year.

SFUSD regularly completes major construction projects while schools remain open and occupied. This is a standard part of managing projects to improve our school facilities, and our construction plans and safety protocols are specifically designed to allow students and staff to continue using the campus safely while work is underway. Our project managers are experienced in managing this work at active school sites. SFUSD buildings are schools first, and construction activity is designed to occur around that. We will always prioritize student safety and health as we deliver these upgrades to SFUSD buildings.

Once the project resumes, all work will occur after 6pm on weekdays and Saturdays and Sundays. Work will not happen when students are present.

• Paint removal on the eastern side of building: 4 weeks, after 6pm only
  This work requires ongoing containment, mitigation, and cleaning procedures detailed in Question 4.
• Concrete repairs and sealant repairs: 4-5 weeks, beginning as paint removal is complete in each section
  This work does not require containment, but dust mitigation and window wrapping will continue
• Window replacement: 2-3 weeks, following completion of concrete and sealant repairs. 
  Window replacement in each classroom will take 3-5 days, including testing and cleaning once complete. It will be phased by classroom, and we will coordinate with school leadership on a schedule for moving classrooms out during work. We will also complete as much work as possible over school breaks.
• Wall painting: 3 weeks, occurring after window replacement is complete.
• School sign add-back: about 3 days
• Scaffolding removal: about 5 days at project completion

As the project resumes, the contractor can provide a detailed two-week look ahead on a weekly basis, with more information on the location of work and schedule. Any updates or changes in schedule will be communicated to the school community.

The district complies with strict standards for lead-related construction activities. It contains all work areas with plastic sheet barriers, which help prevent paint chips, dust and debris from spreading outside of the work area. For this project, the contractor is using a chemical stripper to remove paint. In the industrial hygienist’s opinion, this is the best approach because it is a relatively fast and clean method which does not create dust, and provides a workable surface for the waterproofing that will happen next. After the chemical stripper is applied, surfaces will be power-washed, and this cleaning water will be collected and disposed according to State and federal regulations. This water is temporarily stored and secured in approved drums, and subsequently transported off site for disposal. Similarly, the bulk waste material from the paint removal process is collected as it is generated, stored in secured containers and transported off site for disposal.

Below we outline the safety measures we follow for this project:

Before a project begins:

✔ We hire an independent, third-party environmental and industrial hygiene firm to evaluate the site for hazardous materials, and interpret and analyze results. Staff at these firms must be certified at both state and federal levels. Evaluation firms approach each project as its own unique set of conditions; work methods and engineering controls generally exceed the regulatory requirements to ensure safety.  

✔ Once the construction contractor is selected, they prepare a Work Plan to address methods, procedures, regulatory requirements and materials and supplies. The Work Plan is reviewed by the independent, third-party environmental and industrial hygiene firm, and the contractor cannot start work until it is approved.  

✔ Before starting construction, the contractor sets up the site for work. The industrial hygienist inspects the set up and collects baseline data (ie soil sampling). Work can begin after this data and set up are approved.

During a project: 
✔ The consultant reviews the worker sign in sheet (daily) to confirm credentials, etc; Workers enter the outermost designated chamber and put on protective clothing (PPE) before entering the contained work area (this is the “regulated area” where a second type of posted signage exists). They must also follow a strict procedure to remove and dispose of their PPE at the end of their shift, clean and secure their ventilator, wash their hands, and vacuum themselves from head to toe to eliminate any potential contamination. This process is field verified as part of the monitoring task by the 3rd party industrial hygiene consultant.    

✔ As part of the paint removal process, a paste-like compound is applied to the paint using a hudson-style airless sprayer.  Once complete, a layer of poly sheeting is applied to the compound to facilitate breakdown and softening of the paint. This sits for ~24 hrs.  During paint removal, the softened paint is scraped off the substrate and is bagged within the contained area, then bagged again in the changing chamber. It is placed in designated trash drums outside of the work area, and is then disposed of as a regulated waste material and is picked up by a specialized transport crew.

✔ At the end of every work day, workers HEPA vacuum all areas and an independent environmental inspector (hired by MECA) does a visual inspection to check if the work area is properly cleaned.

✔ After all paint is removed, the wall is power washed or cleaned to remove any chemical residues on the surfaces that would negatively impact the new coating required to waterproof walls. The ground/floor is protected and lined to collect residual rinsate, and then this waste water is bagged and disposed of in the same manner as paint scrapings. 

✔ Throughout this phase, the air inside the containment area is filtered using HEPA and charcoal filters on air scrubbers and the vacuums are also HEPA filtered.Each device is tested on-site by an independent 3rd party prior to use. 

After the Project

✔ Once the project is substantially complete, the containment is visually inspected for final clearance.  CDPH Certified Inspector/Risk Assessor performs a visual inspection and soil sampling for exterior construction-based projects, and clearance wipe sampling on interior projects before re-occupancy.

SFUSD complies with the relevant requirements of many agencies including:

• Cal/OSHA (8 CCR 1532.1) - Lead in Construction
• Title 8, California Code of Regulations (CCR), Section 5198 - Lead in General Industry;, Title 17, California Code of Regulations (CCR), Division 1, Chapter 8 (Sections 35001 – 36100) - Accreditation, Certification, and Work Practices for Lead-Based Paint and Lead Hazards."  
• Title 40, Code of Federal Regulations (CFR), Part 745, Subpart E (40 CFR § 745.80 – § 745.92) - Environmental Protection Agency's (EPA) Renovation, Repair, and Painting (RRP); 
• HUD - Child-Occupied Facilities, U.S. Department of Housing and Urban Development (HUD) - Title 24 of the Code of Federal Regulations (CFR), Part 35; 
• Title 8, California Code of Regulations (CCR), Section 1529  - Asbestos Construction; Title 8, California Code of Regulations (CCR), Section 5208 (8 CCR § 5208) - Lead in General Industry;   
• BAAQMD Regulation 11, Rule 2 (Rule 11-2): Asbestos Demolition, Renovation and Manufacturing; 
• Asbestos Hazard Emergency Response Act (AHERA) - Title 40, Code of Federal Regulations (CFR), Part 763, Subpart E (40 CFR § 763.80 – § 763.99); 
• US EPA: Resource Conservation and Recovery Act (RCRA), Title 40 of the Code of Federal Regulations (CFR), Parts 260 through 279; 
• CA DTSC Title 22, California Code of Regulations (CCR), Division 4.5 (Specifically: 22 CCR §§ 66260.1 – 67900.12)   

For a more detailed comparison of SFUSD’s regulatory compliance related to lead paint, please see here.

Lead is a common environmental contaminant because in the past, lead was widely used as an ingredient of house paint and, until 1995, was in gasoline for motor vehicles. Also, lead cannot biodegrade. The Environmental Protection Agency states that natural levels of lead in soil range from 50 and 400 parts per million. While we do not know if any level of lead is “safe” for a human, we also know that none of us live in a lead-free environment.   

The presence of lead or other regulated building materials does not itself make a building unsafe to occupy. These materials are common in older buildings throughout San Francisco and around the country. The concern arises when certain materials are disturbed without appropriate controls—which is exactly what the District's hazardous materials procedures are designed to prevent.  Also see California Department of Health lead FAQ.

The District has obligations for ongoing identification and monitoring of hazardous materials, and also has specific requirements for capital projects like this one. 

As summarized in Question 4, every project undergoes a rigorous testing process to ensure that materials containing regulated levels of hazardous materials are identified, reported and subsequently removed following strict protocols based on requirements outlined in Q5. Reoccupancy is only permitted after each area has been cleared.

Non-construction related programs (ie maintenance and operations) are in-place to monitor the condition of asbestos in school facilities.  The District inspects each facility in accordance with the U.S. Environmental Protection Agency’s Asbestos Hazard Emergency Response Act (EPA-AHERA) program to assure effective management and compliance. 

Capital projects: SFUSD’s Facilities Department maintains a pool of on-call industrial hygienists who can be contacted as needed by the District to perform hazardous materials surveys, write construction specifications, and monitor the general contractor’s adherence to hazmat management requirements. At the outset of a new capital project, SFUSD requests proposals from industrial hygiene consultants in the pool to perform a hazardous materials survey of the District’s area of work. If hazardous materials are identified in this survey, the industrial hygienist writes a list of hazardous materials requirements for the project contractor to adhere to during construction and includes them in the project drawings and contract documents. The bidding contractors sign a certification that they understand and have reviewed these specifications when they sign a construction contract with the District. The industrial hygienist then performs construction monitoring of the contractor’s work throughout the construction period to ensure that the contractor is adhering to the project documents and requirements. At the end of major project phases, when classrooms or other school spaces have been cleaned following construction activity and are turned back over to the school site, the industrial hygienist conducts final visual inspection and subsequent air and/or surface testing in the space to ensure that the space is ready for students to occupy safely. 
 

The work at CISDA is a construction project that required disturbance of various levels of lead. It is not an abatement project. This is notable only because the purpose of this project was not to eradicate a “lead hazard”; rather it required the removal of a paint film from a wall surface in which the paint contained lead. The regulations and requirements concerning lead can be complex; therefore, it is important to understand the distinction between a construction project that has lead that is being disturbed/removed as opposed to a project that its sole intent is to remove a lead hazard (ie “abating a lead hazard”).  The exterior waterproofing project is a construction project and not a lead abatement project. 

If the District’s industrial hygienist determines that any monitoring or containment requirements have not been followed by the contractor, the industrial hygienist is required to immediately notify the District and advise on what measures the contractor needs to take to ensure student safety.  In addition, there are safeguards built into the project specifications to reduce or eliminate the probability of an elevated test result outside of a controlled area. For example, for projects where daily air monitoring outside of the enclosed/contained area is occurring, a Stop Work Order would be issued if the results were ½ of the government permissible limit.  Furthermore, the District will not open spaces to students/faculty or other contractors that are not first inspected and cleared and determined safe to reoccupy. In the event a hazardous environment was observed, SFUSD will notify the school’s Principal immediately, and will develop a communication plan to promptly notify families and staff. 

The District’s industrial hygienist has not advised the District that there are safety concerns with this project’s construction to date, which is why proactive noticing was not distributed to site staff and students. 

SFUSD received eight bids for this project and accepted the lowest responsible and responsive bid, as required by public contracting code. Here are the bid results. Firm details and insurance information can be found in the linked contract documents below.

Waterproofing contractor:  

Urban Waterproofing Inc. is a reputable construction firm specializing in waterproofing projects for more than 20 years. 

Website: https://www.urbanwaterproofing.com 
Contract: Urban Waterproofing Contract

Industrial Hygienist: 

Millennium Consulting Assoc. (MECA) is an environmental engineering, industrial hygiene, and building science firm that has worked for the district for 28+ years.  

Website: Millennium Consulting Associates

MECA Statement of Qualifications

MECA Contracts

Demolition/paint removal contractor: 

Sterling Environmental Inc. is a subcontractor with Urban Waterproofing. Sterling is a firm specializing in hazardous materials services since 1988 and has been involved with numerous SFUSD projects.

Website: www.sterlingenv.com  

The project is in Phase 1 with approximately 90% of the paint removal complete. The remaining bulk of the work involves waterproofing, window replacement and painting which cannot occur in cold, wet weather. Pausing the current phase of the project means the building is susceptible to further water intrusion, risking damage. The full scope of the project is more extensive than can be completed in a single school break, summer included. 

Specifically, this project has tangible benefits to the short and long term integrity of the building, and these benefits accrue to students and staff. The building currently leaks both through the walls and the existing aluminum windows. Once water gets inside the building envelope, it can quickly damage materials and systems that were never designed to get wet. As we near a forecasted wet winter, completing this work now can help minimize potential water intrusion impacts that could occur if the work is not completed. 

SFUSD is closely monitoring work conditions in collaboration with a team of experts. We are committed to providing a safe and healthy environment for students and staff. The team will actively communicate any changes to the project if health and safety standards have been compromised at the work site.

Relocating a school community is a decision that can have significant impacts on students and families. It affects transportation, instructional programs, student services, staffing, meals, after-school activities, and access to the school community, and it also requires another facility with sufficient capacity and appropriate spaces to accommodate the program. For those reasons, the District’s approach is to keep schools operating in place when construction can be safely managed around them. This project’s construction phasing, containment measures, and hazardous materials protocols are specifically designed to make that possible. A relocation would be considered if our qualified professionals determined that the work could not be safely performed while the campus remains occupied.

Part of this project includes removing and replacing windows, which does block access and/or limit the ability to open windows. The window masking also prevents dust from entering classrooms. On Monday, August 24, 2026, SFUSD Facilities delivered a Portable Air Cleaners outfit with HEPA filtration to CISDA for use in the classrooms. 18” floor fans are also provided to increase air flow. Students will continue to have opportunities for outdoor learning and play in the yard. We will continue to push to complete this part of the project as efficiently as possible. We will also work with school staff on additional ways to support students in impacted classrooms.  

SFUSD takes student and staff health seriously. Though it is not a regulatory requirement, staff commissioned soil testing on August 20, 2026. Six samples were collected: two from bare soil east side of the garden area, two from planter boxes, two from bare soil west side. Wipe samples from the play pad (yard 1), short slide (yard 1), yard 2 north area (2), yard 3 play area, and yard 4 @ concrete landing. Lead levels ranged from 8 to 35 mg/kg, below California Department of Public Health’s 400 mg/kg standard for children's play areas, US EPA/HUD and CA Title 17 standards.

We will provide updates on the project every Thursday evening. These updates will be available in Chinese, Spanish, and English. In addition, we will hold an in-person community meeting in the next week to provide project updates and answer outstanding concerns

Because the school has been determined to be safe, students are expected to attend school as usual. Absences related to concerns about the work will not be excused. Independent Study is not being offered as an alternative. See also SFUSD website information here.