&EPA
          United States    Office of Pesticides
          Environmental Protection and Toxic Substances
          Agency       	
                  July 1991
Asbestos in Schools:
Evaluation of the
Asbestos Hazard
Emergency Response
Act (AHERA):
A Fact Sheet
                            Printed on Recycled Paper

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                AHERA EVALUATION FACT SHEET

               FINDINGS AND IMPLICATIONS FOR SCHOOLS
      The U.S. Environmental Protection Agency (EPA) recently completed an evaluation of the
Asbestos Hazard Emergency Response Act (AHERA) regulatory program in schools. The
evaluation focused on how well the schools implemented key aspects of AHERA and the factors that
affected implementation. The evaluation fulfills a commitment to Congress to study the AHERA
program to determine which elements of the statute, if any, could be used in a possible future
program for public and commercial buildings. However, the sole purpose of this fact sheet is to
inform schools of their initial AHERA successes, note areas for improvement, and provide
additional guidance.

      The evaluation was based on data gathered in a national statistical sample of 30 communities
and 198 schools. Each school was visited and thoroughly reinspected. In-person interviews were
conducted with each principal and AHERA-designated person. In addition, telephone interviews
were held with the original AHERA inspector, the head of the PTA (or other active parent), and an
active teacher in the school. In order to supplement the statistical data collected, focus group
discussions were held in communities nationwide that were not associated with the original sample.
Four focus groups were held with parents and teachers, and five others were held with school
maintenance and custodial workers. The evaluation concentrated on six elements of AHERA:
school building reinspection, management plans, response actions, overall AHERA inspection
reports, notification, and maintenance and custodial worker training.

      This fact sheet lists the key findings of the AHERA evaluation and provides some general
follow up recommendations for schools. The fact sheet also provides "Know This!" sections that
define terms which were identified by the Management Plan Evaluation as often misused. Informa-
tion on materials which provided specific guidance to local education agencies (LEAs) on how to
address possible deficiencies in the original inspection reports and management plans can be found
at the end of this document.

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SCHOOL BTITLDING REINSPECTION
   FINDINGS:
   Q  An estimated 89 percent of the total quantity of suspect asbestos-containing building
       materials (ACBM) reinspected in the evaluation was identified in the original AHERA
       inspection.

   Q  Eighty-two percent of the school buildings had at least one material unidentified. The
       suspect materials missed most frequently were fire doors, duct insulation, linoleum, and
       vibration dampening cloth in air ducts.  Although wallboard was not a part of the survey,
       EPA believes this is another suspect ACBM that was often missed in the initial AHERA
       inspection.

   Q  Only 56 percent of the areas where ACBM was identified had the exact location recorded in
       the management plan.

   Q  Ninety-two percent of the ACBM which should have been assessed according to AHERA
       was actually assessed. Forty-four percent of the ACBM assessed used AHERA categories
       reporting the amount of damage at the time of inspection as well as the potential for damage.

   WHAT THIS MEANS TO YOU:
       The identification and location of suspect material is crucial to the management of asbestos.
   The upcoming three-year reinspection, required for all schools by July 9,1992, is an opportunity
   for schools to have the original inspection report reviewed and corrected, should there be
   deficiencies in the identification and assessment of ACBM. Below are the steps EPA
   recommends to address possible deficiencies.

   Q  The LEA designated person should review the inspection report and management plan
       carefully to determine if the categories of frequently missed materials were identified.

    Q  You may want the inspector who performs the three-year reinspection to look for possible
       missed suspect material.  Inspectors should make sure that materials such as ceiling tile,
       wallboard, plaster walls, linoleum, fire doors, duct insulation and vibration dampening cloth
        are identified and recorded in the management plan.

    Q  The LEA designated person should review information on each material identified to ensure
       its specific location is recorded.

    Q  The inspector should provide additional information about the location of previously
       identified ACBM if it is not included in the management plan.


       KNOW THIS!
       Suspect materials are generally divided into three broad categories:
       1) thermal system insulation (TSI), such as pipe or boiler wrap;
       2) jprfacfog materials, such as sprayed on ceiling materials or firepnaofing; and
       3) miscellaneous, which includes floor tiles and fire doors.

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MANAGEMENT PLANS

    FINDINGS:
    Q  Management plans were generally complete. However, in many instances, the location of
       homogeneous areas was not clearly described and the material was insufficiently identified as
       TSI, surfacing materials, or miscellaneous.

    Q  Plans, while generally complete, were not "user friendly" or easy to understand. Almost one
       quarter of the plans were difficult to follow without specialized instruction.

    WHAT THIS MEANS TO YOU:
       The management plan is the basis for all asbestos work done in the school and is a guide
    for anyone who could disturb the ACBM during maintenance or custodial work. It should be
    reviewed for clarity and usability and continually updated to reflect all asbestos activities.
   KNOWTHIS!
   *   Homogeneous Area: an area of surfacing material, TSI or miscellaneous material mat is
       uniform in color and texture,
                       %                                         v
   *   Functfonal gpftcg: aroom> group of rooms, or homogeneous area designated by a person
       accredited to prepare Management Plans* design abatement projects, or conduct
       response actions,        \. "    , ' ,
RESPONSE ACTIONS

   FINDINGS:
   Q Seventy-one percent of the management plans included recommendations for response
      actions such as operations and maintenance  (O&M), repair, encapsulation, and removal;
      fifty-five percent of those recommendations called for O&M techniques while 10 percent
      called for removals.                             Flammed Response Actions
      Asbestos was removed in 15 percent of
      the school buildings where response
      actions were completed.

      Ninety-eight percent of the
      recommended response actions were in
      accordance with AHERA guidelines.
      However, 80 percent of the buildings
      had recommendations that were
      considered generic because of a failure
      to specify exactly where the response
      action should be performed.
      Removal
                 D  Encapsulation
H  Repair
                                  O&M
   Q  The majority of prior remediations were judged to be adequate.

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   WHAT THIS MEANS TO YOU:
      All friable ACBM should have an appropriate response action associated with it. To ensure
   your management plan has an appropriate response action, EPA recommends:

   Q The LEA designated person should check their management plan for a clear match between
      friable ACBM and recommended response action.

   a If there appear to be deficiencies, an accredited management planner should review the
      inspection report and document recommended response actions.

   Q LEAs may want to address this when an accredited management planner reviews the
      reinspection report.
                                                  Level of School Inspection Thoroughness
ORIGINAL A HER A INSPECTIONS

   FINDINGS:
   Oi Thirty-eight percent of the inspections
      were found to be either deficient or
      seriously deficient. The primary causes of
      deficient inspections were failure to
      identify all suspect material in a school,
      failure to clearly record the precise
      locations of ACBM, and failure to
      quantify it within acceptable standards of
      accuracy.
                                                            Seifousfy Deficient
13  Deficient
 WHAT THIS MEANS TO YOU:
        It is important that school officials be aware of the asbestos (or susipect ACM) in their
    buildings and that the locations and amounts of ACBM are accurately recorded and marked.
    Without this information, a school cannot effectively manage its asbestos. Those who may
    come into direct contact with the material, such as custodians, maintenance personnel and
    short-term workers, may inadvertently disturb the material if they are unaware of its location.

        Although only known or assumed ACBM is required to be reinspected in the triennial
    reinspections, EPA recommends schools take this opportunity to inspect for materials
    that may have been overlooked in the initial inspection (frequently missed materials are listed
    on this fact sheet under school building reinspection).  It is also a good time for the
    inspector to correct deficiencies regarding unrecorded locations or unqualified
    amounts of ACBM.
 NOTTFTCATTON PROCESS
     FINDINGS:
     Q  A survey of school principals showed that parents and teachers did not appear to overreact

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     upon learning about the presence of asbestos in their schools (overreacting can sometimes
     lead to improper or poorly conducted removals). In the focus group discussion, some parents
     and teachers did not recall receiving the notification.

  WHAT THIS MEANS TO YOU:
     As required by AHERA, schools should continue to send the annual notifications including
  information on planned response actions and reinspections. Copies of notifications should be
  kept in your management plan.
MAINTENANCE & CUSTODIAL WORKER TRAINING & EXPERIENCE
WTwrvnvrr- o                                      Percent of Training Which Did Not Describe the
*irsmrs
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   Q the 16-hour training includes hands-on training in the use of respiratory protection and good
      work practices; and

   Q newly hired custodial and maintenance workers are trained within 60 days.

GENERAL  INFORMATION

   LEAs need to be aware of these AHERA evaluation findings, build upon their successes,
and work toward improving deficiencies. To assist the schools with this effort, EPA has
available guidance materials and activities that address the concerns raised in the evaluation:

   Q EPA has published its Green Book, Managing Asbestos In Place, which has been mailed to
      schools. If you require an additional copy, call the EPA asbestos hotline at (202) 554-1404.

   Q Seminars on the Green Book's in-place management guidance were conducted for school
      officials around the country earlier this year.

    01 An AHERA questions-and-answers document was distributed late last month to help schools
      plan and conduct the three-year reinspections required by AHERA.

    Q EPA is now preparing model training materials, which should be available in autumn, for the
       16-hour AHERA maintenance training requirement.

    Q  The Agency is developing, with the National Institute of Building Sciences, an operations
       and maintenance manual for custodial and maintenance workers who come in contact with
       ACM.  The manual, enlarging upon the Green Book's in-place management guidance, is
       scheduled to be completed by the end of 1991.

    Q  EPA is revising the model accreditation plan which specifies training and certification
       requirements for asbestos control professionals working in schools.

    Q  The Agency is also planning an AHERA self-study guide for school "designated persons"
       planned for spring 1992.

    Q  Additional detailed guidance on how to conduct an AHERA reinspection is set for
       distribution later this year.
 LEAs will be notified when the new guidance materials are available.

 To obtain a report on the AHERA evaluation, or other asbestos guidance, contact the EPA asbestos
 hotline at (202) 554-1404.
                                                                         July 1991

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