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Key Indoor Air Quality (IAQ) and Heating, Ventilation and Air Conditioning (HVAC) Deadlines for Connecticut Public School Districts

By Andrew N. Davis, Alfredo G. Fernández & Sarah Kettenmann on March 18, 2026
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Connecticut public school districts face two important compliance deadlines under CGS § 10-220(d) related to IAQ and HVAC systems. With these deadlines fast approaching, now is the time for districts to take action.

HVAC Assessments Beginning July 1, 2026

Starting July 1, 2026, districts must begin conducting HVAC assessments of their school buildings. The statute requires districts to conduct these HVAC inspections every five (5) years and to inspect at least 20% of their buildings each year, with all inspections for all school buildings completed by June 30, 2031 – and then the cycle repeats. The 2026–2027 school year marks the first compliance window.

These assessments cannot be performed by just anyone. The statute requires a qualified professional, specifically a certified Testing, Adjusting and Balancing (“TAB”) technician, an industrial hygienist or a mechanical engineer. Qualified technicians and their schedules are already in high demand (particularly during summer months when schools are out of session), and districts that delay in engaging these professionals risk falling behind on their compliance obligations. While the Department of Administrative Services (“DAS”) can grant a one-year waiver if technicians are unavailable, districts should not rely on this as a long-term solution. Even with a waiver, districts would still be required to achieve 40% of buildings assessed by June 30, 2028, so the relief is limited.

Annual IAQ Reports Due by December 31, 2026

In addition to the HVAC assessment requirement, since 2025, every district must conduct an annual IAQ inspection of each of its buildings using the EPA’s Tools for Schools program by December 31, 2026. Once completed, districts must post the results on both district and school websites, make them available at a regularly scheduled Board of Education meeting and confirm compliance with DAS.

The Bottom Line

Districts should not wait to begin planning (logistically and budget wise) for these deadlines. The dearth of qualified HVAC technicians makes early action on the assessment requirement especially critical. Districts that move quickly to schedule HVAC assessments and conduct IAQ evaluations will be in the strongest position to meet both deadlines without disruption. Questions? Please contact a Shipman environmental attorney for guidance. 

Photo of Andrew N. Davis Andrew N. Davis

Andrew Davis is Chair of the firm’s Environmental Practice Group. He counsels clients in transactional, permitting, compliance and enforcement matters under federal and state health and safety, hazardous waste, air and water pollution, site development and property transfer laws.

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Photo of Alfredo G. Fernández Alfredo G. Fernández

A former aerospace engineer, Alfredo focuses his practice on regulatory compliance and transactional due diligence with respect to a wide range of federal, state and international environmental, health and safety laws.  Alfredo regularly counsels clients regarding new and existing chemicals under the Toxic…

A former aerospace engineer, Alfredo focuses his practice on regulatory compliance and transactional due diligence with respect to a wide range of federal, state and international environmental, health and safety laws.  Alfredo regularly counsels clients regarding new and existing chemicals under the Toxic Substances Control Act (TSCA), “Superfund” liability under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), chemical crises under the Emergency Planning and Community Right-to-Know Act (EPCRA), and workplace safety under the Occupational Safety and Health Act.  Alfredo also has experience with unique investigation and remediation issues associated with emerging contaminants, state “Brownfields” programs and the “Connecticut Transfer Act.”

Alfredo’s complete biography can be found here.

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Photo of Sarah Kettenmann Sarah Kettenmann

Sarah is a member of Shipman’s Environmental Practice Group where she assists clients by creating technical and legal solutions to complex regulatory challenges. Sarah maintains a robust environmental regulatory and transactional practice, and guides buyers, sellers and lenders/investors in industrial and commercial real…

Sarah is a member of Shipman’s Environmental Practice Group where she assists clients by creating technical and legal solutions to complex regulatory challenges. Sarah maintains a robust environmental regulatory and transactional practice, and guides buyers, sellers and lenders/investors in industrial and commercial real property transactions to manage risks, including investigation, disclosure, remediation, liability and other legal or regulatory burdens that environmental contamination can trigger. Sarah helps clients comply with federal and state environmental, health, and safety (EHS) protocols, including regulatory compliance, auditing, and due diligence and is experienced in the development of environmental compliance programs. She has also helped corporate clients navigate enforcement actions brought under the Toxic Substances Control Act (TSCA), Occupational Safety and Health Act (OSHA), and Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA).

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  • Posted in:
    Environmental and Climate
  • Blog:
    School Law
  • Organization:
    Shipman & Goodwin LLP
  • Article: View Original Source

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