My firm is going to perform renovations in a school during the students’ summer break.  During the regular school year, the work area would fall under the definition of a child-occupied facility. However, no children under age six will be present during this multiple month break period.  Do we still have to comply with the pre-renovation education requirements?  If so, how should the information be distributed?

Answer: Yes. Even though the renovations will be taking place during a time when no children will be present, the building (or portion of the building) will remain a child-occupied facility. Breaks, such as those for summer or winter, are mere temporary disruptions in regular visits by children.

To provide the required information to the parents and guardian of children using the child-occupied facility, a firm must either (1) mail or hand deliver the pamphlet and the renovation information to each parent or guardian of a child using the child-occupied facility or (2) post informational signs describing the general nature and locations of the renovation and the anticipated completion date. These signs must be posted in areas where they can be seen by the parents or guardians of the children. The signs must also be accompanied by a posted copy of the pamphlet or information on how interested parents or guardians can obtain a free copy from the renovation firm. 

Question Number: 23002-19753

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