In order to prevent the spread of COVID-19 infection in the district, facilities operations are geared toward meeting social distancing requirements and cleaning frequently touched spaces regularly. In carrying out projects or tasks supporting infection control, requirements for changes associated with building spaces are met regularly. Additional plans for changes or additions to facilities that require review by the Office of Facilities Planning (OFP), will be submitted to comply with the requirements of the 2020 New York State Uniform Fire Prevention and Building Code (BC) and the State Energy Conservation Code. 

The East Rochester Union Free School District (East Rochester UFSD) recognizes that as students and adults return to their school buildings for in-person instruction, it is vitally important that the physical spaces they occupy are configured and maintained in a way that provides the maximum possible protection from spreading the coronavirus. 

East Rochester UFSD has followed health guidance related to social distancing and other safety measures to maximize the health and safety of our students and staff. To meet the requirements of that guidance, East Rochester UFSD needed to rearrange and re-purpose physical space within the building, needing to make changes in programming or operation. 

The District does not foresee the need to expand the building or the district’s footprint, or alter existing space through construction or add any temporary exterior space. This is not to say such changes will never occur, but at present the District does not think this will be necessary for the foreseeable future. 

Any future changes of a more substantive nature (such as construction) would naturally be subject to fire code compliance and review by the New York State Education Department’s (NYSED’s) Office of Facilities Planning. 

Questions will arise as we strive to balance fire safety and building security needs with our efforts to prevent the spread of COVID-19. Our district administrative team is in consultation with other school districts, and local and state agencies to ensure that all factors are fully considered, and that the risks to building occupants are minimized across the full range of potential concerns. 

General Health and Safety Assurances 

East Rochester UFSD has and will continue to follow all guidance related to health and safety. This includes meeting social distancing requirements and cleaning frequently touched spaces regularly to prevent spread of infection. These requirements are addressed in more detail in other parts of the District Reopening Plan. The reopening plan meets all requirements associated with building space related changes that may be made. 

Fire Code Compliance 

Any changes or additions to our facility requires a review by the Office of Facilities Planning (OFP), since all spaces to be occupied by public school students and staff must meet the requirements of the 2020 New York State Uniform Fire Prevention and Building Code (BC) and the State Energy Conservation Code. Should the District decide that alterations to the building are necessary, such proposed changes shall be submitted to the OFP for review and approval - just as with any other project. 


Many stairs and corridor doors have closers with automatic hold-opens. These doors are normally held in the open position and are automatically released by the fire alarm system. The function, position, and operation of those doors shall remain unchanged. They need not be touched during normal use. 

Emergency Drills 

East Rochester UFSD conducts standard operations and procedures to the best of its ability without deviating from current requirements. Fire (evacuation) Drills and Lockdown Drills are required by Education Law and regulation and the Fire Code and they will be conducted without exception. Fire Code Section 404 requires that schools maintain Fire Safety, Evacuation, and Lockdown Plans and these plans include how lockdown and evacuation drills are conducted. Methods to promote and provide for social distancing during evacuation drills are included in the District Fire Safety plan. 


Since the statute has not been changed to provide an extension to the submission deadline for the Building Condition Survey or Visual Inspections, the deadlines for these inspections will be met. 

Lead Testing due in 2020 

At present, the statutory requirement that lead testing occur in 2020 continues. NYS DOH regulation 67-4, Lead-In-Water Testing, DOH requires lead-in-water testing to be conducted when the building is “normally occupied.” Sampling will not be conducted when the building is vacant or has been vacant for an extended period due to COVID-19 closure. Moreover, simulation of “normally occupied operation” for the purpose of lead-in-water testing is not permitted. The District will follow NYS DOH guidance, to the fullest extent possible, on recommended procedures to provide clean and safe drinking water upon reopening. 

Means to Control Infection 

The following arrangements have been made to reduce transmission of infection: 

Time Management: One of the goals of the District Administrative Team was to examine student and class schedules to reduce student use of the corridors. The traditional practice of changing classes between periods has been minimized to reduce hallway congestion and promote social distancing. 

Leave Doors Open: To reduce the spread of the virus from touching door levers and knobs, doors may be fixed in the open position. This is only permitted at doors without door closers and doors which are not fire rated. 

Plastic Separators: The use of clear light-transmitting plastic barriers is utilized in locations where social distance or mask requirements cannot be complied with or easily regulated. (Example: separating individual lavatory sinks from each other.) Light-transmitting plastics comply with 2020 BCNYS Section 2606 to mitigate the negative impact of life and safety features of a school. 

Alcohol-based Hand Rub Dispensers: East Rochester UFSD has adequate hand-washing facilities, as mandated by Code, and has supplemented hand-washing with alcohol-based hand rub dispensers in most rooms. Alcohol-based hand-rub dispensers are permitted to be installed in rooms and corridors in limited quantities in accordance with FCNYS 2020 Section 5705. 

Dividers at doors and other points of congregation: East Rochester UFSD may decide to use dividers, if necessary, at queue lines and other areas subject to overcrowding. Such dividers, if used, will be OFP-approved so as not to interfere with safety. 

Required Square Footage 

While recommendations on social distancing suggest that maintaining a six-foot distance from others is optimal, the building code itself does not mandate a minimum square footage per person on which districts must base the number of students and staff in a building. Code sets standards for individual rooms and it varies on room function. East Rochester UFSD uses 20 square feet (SF) per person for a classroom, 15 SF per person for cafeterias, 50 SF Vocational, Tech and Special Ed., 150 SF for offices and 5-15 SF for gymnasiums. 

The District shall contact and consult with an architect at the OFP if a change in room use results in a change in occupant load, or if a change in occupancy of a space results in an occupant count greater than 49. A higher than expected number of occupants may change the requirements for exits. 

Facility Alterations and Acquisition 

Districts may choose to ease social distancing by changing the way they use space in their existing buildings or by acquiring additional space. All spaces to be occupied by school students and staff must meet the requirements of the 2020 New York State Uniform Fire Prevention and Building Code and the State Energy Conservation Code. At present, East Rochester UFSD does not anticipate a need to acquire additional space. 

Changes to Space Utilization and/or Alterations

Should East Rochester UFSD decide to make space alterations to the physical space or the building, these items will be required: 

● If alterations to the configuration of existing classrooms or spaces are made, or if temporary and/or movable partitions are introduced, such changes shall be submitted to OFP, the local municipality and/or code enforcement officials for review. 

● If the means of egress, fire alarm system, ventilation, and lighting are affected, such changes must be indicated on all submitted plans. 

● Any alterations to the building will be performed in consultation with the District’s architect, with all floor plans submitted to OFP for approval. 

● Any alterations proposed due to COVID-19 shall be indicated as “COVID-19 Reopening” when submitted to the OFP. This will allow NYSED to expedite those reviews.
● If the District proposes installation of movable partitions (gym, cafeteria, Library classroom dividers) and queue barricades an abbreviated submission consistent with the Form FP-AU Request for Approval of Use of a Facility shall be provided. 

● Use of Cafeterias, Libraries, Auditoriums and Gymnasiums: A floor plan of the entire room showing the furniture layout with egress aisles shall be submitted to OFP for approval. Lighting, ventilation, means of egress, and fire alarm coverage must be indicated. 

East Rochester UFSD may utilize available space in the cafeteria, gyms, auditorium and libraries (or sections thereof) as classroom space. Minor alterations and the use of space dividers may be utilized in existing classrooms. The need for social distancing may be enhanced by alterations to a lobby or corridor and /or interior spaces/rooms. 

Space Expansion 

East Rochester UFSD does not anticipate the need to expand square footage (e.g. building additions, lease space, transportable classroom units or spaces such as tents) in order to enable improved social distancing. Should such need arise in the future, the District will comply with the following requirements as they apply to all spaces to be occupied by school district staff and students: 

● Code Review: Per statute, NYSED’s Office of Facilities Planning must review and approve the above types of projects to ensure that the proposed spaces meet the fire code. 

● Off-Site Lease Requirements: For offsite facilities, the district must contact their project manager at NYSED Office of Facilities Planning (OFP) and submit a Temporary Quarters (TQ) Project submission. 

To ensure that these sites meet all requirements, TQ submissions require submission of:

● OFP Form FP_AU-Request for Approval of Use of a Facility; 

● Architectural quality floor plan; 

● Site plan; 

● AHERA Plan; 

● Fire Safety Report; 

● Confirmation of Americans with Disabilities Act compliance; 

● Local Code Authority Certificate of Occupancy; and 

● Approval of use of space. 

Please note – if a Change of Occupancy in the Existing Building Code applies (e.g. office or B-occupancy to E-occupancy) code requirements such as rescue windows; accessibility; fire protection systems such as sprinkler or emergency voice alarm communication systems; ventilation – may make it infeasible. 

Districts or other applicable schools should identify COVID-19 Projects as “COVID-19 Reopening” when required materials are submitted to OFP for review and consult with OFP for a preliminary evaluation of all facilities under consideration for leasing. All leased facilities must be submitted to OFP for review and approval. 

Any space expansion request/proposal will be made in consultation with the District’s architect/engineer of record. 

Tents for Additional Space 

If the district needs to utilize tents as alternate spaces, the following requirements apply: 

● Tents, both temporary and permanent are regulated by code and must be submitted for a building permit. 

● Temporary structures and tents are those erected for 180 days or less. The Building Code Section 3103.1 indicates, “tents and membrane structures erected for a period of less than 180 days shall comply with the Fire Code of NYS”. 

● The Fire Code (FC) Chapter 31 contains extensive requirements for Tents and Other Membrane Structures. FC Section 3103.2 indicates that a permit and approval of temporary tents is required. FC Section 3103 contains requirements for temporary tents and Section 3104 has requirements for permanent tents. They include requirements for construction documents, access roads, location, seating plans, means of egress, illumination, exit signs, construction, use. 

● Permanent tents are considered a membrane structure and are regulated by Building Code Section 3102 and other applicable sections.

● Districts or other applicable schools must consult their design professional to prepare submission drawings for approval by OFP. 

● The following information must be shown on the drawings: Dimensions, Minimum separation distance to other structures, Tent sides (yes) (no), Duration of use, Type of use/activity, Anchorage, Number of Exits, Width of each exit, Table/Chair/Contents, layout, Fire extinguisher Location, Occupant load, Heating or Cooking equipment, Utilities, Exit signs, NFPA 701 testing/label/certification. 

● If the tent is used for E-occupancy, consult with local municipalities and/or code enforcers to provide code-compliant design for mechanical heat and ventilation; lighting; emergency lighting; power; fire alarm; plumbing; etc. as required. 

● Districts or other applicable schools must consult their architect and submit to OFP for approval. The district, or other applicable school, must provide an architectural quality floor plan, which clearly indicates existing and proposed use of space showing the furniture layout with egress aisles. Lighting, ventilation, means of egress, and fire alarm coverage must be indicated. 

Plumbing Facilities and Fixtures 

Toilet and Sink Fixtures: East Rochester UFSD may consider reducing the number of available toilet fixtures in the building in order to facilitate frequent cleaning. However, any reduction in available toilet fixtures will not fall below the minimum number of toilet fixtures that must be available for use as established in the building code. Any changes made will be in consultation with the District’s architect/engineer of record. 

Since frequent handwashing is a key component to avoiding the spread of COVID-19, sinks and soap are available to building occupants at all times. 

Drinking Water Facilities: Drinking fountains are a code required plumbing fixture in schools. Currently, the District has no plans to reduce the number of available drinking fountains but have modified them in accordance with safety guidelines. Students and staff are encouraged to bring their own water bottles. 

Ventilation: East Rochester UFSD maintains adequate, code required ventilation (natural or mechanical) as designed. 

Any proposed air cleaning equipment was submitted to OFP for review and approval. Schools are encouraged to increase the fresh air ventilation rate to the extent possible to aid in maintaining a healthy indoor air quality. The district has installed a higher efficiency filter in all air handlers and univents, increasing filter quality from a MERV-8 to a MERV-13 rating (MERV = Minimum Efficiency Reporting Value. MERV is an industry-standard scale to measure the effectiveness of air filters). MERV-13 shall be the new District standard.