Ministry of Education Lack of Enforcement on Ventilation.
July 27, 2022.
By law every early childhood centre in NZ must have adequate ventilation (natural or mechanical) that allows fresh air to circulate in all parts of its building or buildings used by children.
But it has emerged that the Ministry of Education allows centres to have indoor spaces that do not have fresh air circulation and does not enforce compliance. The Ministry of Education is responsible for approving centre licenses under the Education (Early Childhood Services) Regulations 2008 and for monitoring compliance and enforcement.
The requirement for ventilation is a good one. Ventilation removes exhaled air from a room, replacing it with fresh air from outside so children (and adults) will be less likely to breathe in any virus-carrying particles. This helps to prevent the spread of influenza and respiratory viruses, including Covid-19.
Learn more by watching the following video.
The video shares helpful information and tips for centres, staff, and service providers. Dr Sarah Alexander does not hold back from saying what the current situation is, and places responsibility on the shoulders of the Ministry of Education.
Quotes illustrating ventilation problems and concerns
To illustrate what some of the problems and concerns about ventilation are, we have included below a small selection of quotes from the requests of people at 471 early childhood centres received by the OECE earlier this year for air purifiers and CO2 monitors as the Ministry was providing these to schools only.
The 471 centres may be only the tip of an iceberg. By requesting help these centres were also indicating that they were non-compliant – a brave thing to do. We do not wish to put centres at risk of a licensing punishment by publishing their names here, when they are simply being honest about what is wrong. Clearly the Ministry of Education holds all or at least some responsibility for not addressing such problems at the time of licensing or through monitoring visits.
We have lived in Covid-19 environment for around for 21/2 years now and the Ministry of Education has had plenty of time to ensure every early childhood centre meets the regulatory requirement.
Ventilation video text
Good ventilation is vital to help to prevent the spread of influenza, respiratory viruses, and now Covid-19.
So, thank goodness for many years regulations for early childhood centres have included a licensing requirement that centres must have ventilation that allows fresh air to circulate in all rooms that infants and young children are in.
But regulations without enforcement are not regulations at all and for this particular centre licensing requirement there has been a lax approach to enforcement.
Hundreds, if not thousands, of early childhood centres may have been awarded licences by the Ministry of Education to operate, when they don’t have ventilation for the circulation of fresh air in all rooms used by children.
The Ministry has acknowledged that sleep room windows have been painted over or nailed shut to stop children from escaping.
Heat pumps are commonly used and relied on in centres. These are good at heating or cooling the air indoors – but don’t bring fresh air inside.
Centres have been licensed that have internal playrooms, sleep rooms with closed doors and no windows or windows that don’t open, nappy change areas with no fresh airflow, and children’s bag or locker areas in non-ventilated spaces.
The Ministry of Education says to centres that they can buy air cleaners from its supplier for air cleaners to receive the discounted pricing of $320-$550 + GST.
The government is providing centres catering for disadvantaged children with a one-off payment of $377.20, the price of buying a CO2 monitor from its supplier for CO2 monitors, less the cost of shipping.
But the Ministry have told me they are not intending to carry out an audit of centres to get an understanding of the scale of the problem.
Instead, they said they are checking ventilation only in circumstances such as when a parent makes a complaint, or a centre applies for a new licence.
This is not good enough for the Covid-19 and respiratory illness environment we already live in.
With winter here now, we are into the flu season.
On top of this, there are also fears of another major outbreak of RSV, as we saw last year, with hospitals flooded with seriously sick infants and toddlers.
The requirement for ventilation in early childhood centres is a good one. But lack of enforcement means the health of young children and staff, and the families of both, remain vulnerable to already well identified risks.
The question becomes then two-fold
- When, if ever, will the fresh air requirement be enforced?
- Does this mean there could be other health and safety requirements for licensing that the Ministry of Education is lax on making sure all centres meet?