l CO
               United States
               Environmental Protection
               Agency •
                            June 1989
Of Asbestos
In Schools



• When is asbestos a problem?
• What should my school and
  school district be doing about
• What can I do to help?
This pamphlet, developed by the
U.S. Environmental Protection
Agency (EPA) in conjunction with
the National Parent Teacher Asso-
ciation (PTA) and the National
Education Association (NEA), can
help parents and teachers answer
questions and learn the facts
about asbestos in schools. It also
outlines the responsibilities of
school boards and other school offi-
cials to protect school children and
employees from possible exposure
to asbestos.
! ;

   The Asbestos  Issue
            sbestos fibers can
            cause serious health
            problems. If inhaled,
            they can disrupt the
   normal functioning of the lungs.
   Three specific diseases—asbesto-
   sis, lung cancer, and another
   cancer known as mesothe-
   lioma—have been linked to.as-
   bestos exposure. These diseases
   do not develop immediately
   after inhalation of asbestos
   fibers; it may be 20 years or
   more before symptoms appear.
    In general, as with cigarette
   smoking, the more  asbestos
   fibers a person inhales, the
   greater the risk of developing
   an asbestos-related disease. The
   most severe health problems
   from asbestos exposure have
   been experienced by some work-
   ers who held jobs in industries
   such as shipbuilding, where
   they were exposed to very high
   levels of asbestos in the air.
   These employees worked di-
   rectly with asbestos materials
   on a regular basis as a part of
   their jobs. Much uncertainty
   surrounds the risk from expo-
   sure to low levels of asbestos
    Nevertheless, the risk of
   school children being exposed
to even low levels of asbestos is
a concern. .Acting on this con-
cern, Congress passed the As-
bestos Hazard Emergency Re-
sponse Act (AHERA) in 1986 to
protect school children and
school employees from exposure
to asbestos in school buildings.
This pamphlet describes key
parts of these new federal asbes-
tos requirements for schools.

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What Exactly

Is Asbestos?

         sbestos is a mineral
         found in certain types
         of rock formations.
         When mined and proc-
essed, it takes the form of very
small fibers which are usually in-
visible to the naked eye. A typical
asbestos fiber is 1,200 times
smaller than a strand of human
hair. These individual fibers are
generally mixed with a material
which binds them together so that
they can be used in many differ-
ent products. Because the fibers
are so small and light, they can re-
main in the air for many hours if
they are released from asbestos-
containing material. This in-
creases the chance that someone
will inhale them.
  Asbestos became a popular com-
mercial product because it is
strong, won't burn, resists corro-
sion, and insulates well. Its com-
mercial use in the United States
began in the early 1900s, when it
was used as insulation in steam
engines. Since then asbestos has
been used to create about 3,000 in-
sulation, fireproofing and other
products. The peak years of asbes-
tos use in schools were from
World War H until the 1970s,
  V* •
when several major kinds of asbes-
tos materials were banned be-
cause of growing concern about
related health effects.
Where Is


Likely  to  Be


         PA estimates that
         there are asbestos-
         containing materials
         in most of the nation's
approximately 107,000 primary
and secondary schools. Asbestos is
most commonly used in schools as
insulation and in building materi-
als. It has also been used in floor
and ceiling tile, cement pipe, cor-
rugated paper pipe wrap, acousti-
cal and decorative insulation, pipe

 and boiler insulation, and spray-
 applied fireproofing. The fluffy
 white substance you may find
 above a dropped ceiling, for exam-
 ple, is one type of spray-applied
 material. The amount of asbestos
 in these products varies widely,
 from 1 to 100 percent, depending
 on the use. Pipe and boiler insula-
 tion typically contains more asbes-
 tos than other building materials.
 The precise amount of asbestos in
 a product cannot always be deter-
 mined from labels—since most
 products used in the past were
 not labeled—or by asking the
 manufacturer. Instead, positive
 identification of asbestos requires
analysis of samples by a qualified
When Is

Asbestos a


         ntact and undisturbed
         asbestos materials gen-
         erally do not pose a
         health risk. Asbestos
materials, however, can become
hazardous when, due to damage or
deterioration over time, they re-
lease fibers. If the fibers are in-
haled, they can lead to health
  The potential for an asbestos-
containing material to release fi-
bers depends primarily on its con-
dition. If the material, when dry,
can be crumbled by hand pres-
sure—a condition known as "fri-
able"—it is more likely to release
fibers, particularly when dam-
aged. The fluffy spray-applied as-
bestos fireproofing material is gen-
erally considered "friable." Pipe
and boiler insulation materials
can also be "friable," but they
continued on p. 6

HHKJt-Kk  b-Mm-Nn-
 What Has the  Government
 Done about Asbestos?
          he federal govern-
          ment has been regu-
          lating asbestos for a
          number of years.
Any material which contains as
little as 1 percent asbestos is
subject to federal asbestos regu-
lations. Progress is being made
to limit the uses of asbestos and
to identify substitute materials.
EPA is now considering ways to
phase out the use of other as-
bestos materials.
   On October 22,  1986, Presi-
dent Reagan  signed AHERA
into law. The Act required EPA
to develop regulations creating
a comprehensive framework for
dealing with  asbestos in public
and nonprofit private elemen-
tary and secondary schools. The
regulations were published on
October 30,1987.
  The AHERA schools rule re-
quires all public school districts
and private schools, known as
local education agencies or
LEAs, to inspect all school
buildings for both friable and
nonfriable asbestos; to develop
plans to manage asbestos in
schools; and to carry out the
plans in a timely fashion. The
rule also provides an opportu-
nity for parents, teachers, and
other school employees to be-
come familiar with and involved
in their school's asbestos man-
agement program. School offi-
cials are required to notify par-
ent, teacher and employee
groups about asbestos-
related activities.
  EPA also has established an
asbestos-in-schools assistance
program. Through its Headquar-
ters office in Washington, D.C.,
and ten Regional offices, EPA
provides direct technical assis-
tance to help thousands of
school officials and workers un-
derstand asbestos issues. EPA
makes funds available to train
asbestos professionals, to assist
states in developing asbestos
programs, and to help schools
comply with the federal asbes-
tos regulations. Since 1985,
EPA also has provided loans
and grants to help financially
needy public and private schools
correct serious asbestos hazards
through the Asbestos School
Hazard Abatement Act
(ASHAA) program. Finally,
EPA publishes informational
pamphlets for the public.

often are enclosed in a protective
casing which prevents fiber re-
lease unless the casing is dam-
aged. Some materials which are
considered "nonfriable," such as
vinyl-asbestos floor tile, can also
release fibers when sanded, sawed
or otherwise disturbed. Materials
such as asbestos cement pipe can
release asbestos fibers if they are
broken or crushed when buildings
are demolished, renovated or
What  Are the Proper
Methods  for Managing
          ost asbestos-containing
          material can be prop-
          erly managed where it
          is. In fact, asbestos
that is managed properly and
maintained in good condition ap-
pears to pose relatively little risk
to students and school employees.
Accordingly, the AHEKA schools
rule rarely requires the removal of
asbestos materials.
  Proper asbestos management be-
gins with a comprehensive inspec-
tion by qualified, trained and ex-
perienced inspectors, accredited
through an EPA or state-approved
training course. Inspecting the
condition of asbestos materials—
initially with AHERA-accredited
inspectors and at least semi-annu-
ally with trained custodial or
maintenance staff—is extremely
important so that changes in the
material's condition, such as dam-
ape or deterioration, can be de-
tected and corrected before the
condition worsens. Sometimes nor-
mal school or maintenance activi-
ties can damage asbestos material
and cause fiber release, particu-
larly if the material is "friable."
A thorough initial inspection and
regular surveillance can prevent
accidental exposure to high levels
of asbestos fibers.
  The methods (see page 7), in
AHERA terminology, are asbestos
"response actions." The last three
methods of response actions—
encapsulation, enclosure, and re-
moval—and sometimes the second
method—repair—must be done by
accredited asbestos professionals.
  The final response action, asbes-
tos removal, is generally necessary
only when the material damage is
extensive and severe, and other ac-
tions will not control fiber release.
Although the AHERA schools rule
does not prohibit schools from re-

 HHKJt-K-k U-Mm-Nrr
  How To
  Proper methods for dealing
  with asbestos are:

  • Developing and carrying out
   a special maintenance plan to
   insure that asbestos-contain-
   ing materials are kept in
   good condition. This is the
   most common method when
   the materials are in good con-
   dition at the time of initial
  • Repairing damaged pipe or
   boiler covering, which  is
   known as thermal system
  • Spraying the material with
   a sealant to prevent fiber
   release—a process called
  • Placing a barrier around
   the materials, known as an
  • Removing asbestos—under
   special procedures.
moving any asbestos materials,
removal decisions should not be
made lightly. An ill-conceived or
poorly conducted removal can actu-
ally increase rather than elimi-
nate risk. Consequently, all school
removal projects must be designed,
supervised, and conducted by ac-
credited professionals and should
be performed in accordance with

           Bb-C-e Ed- Ee-Ff-G
 state-of-the-art procedures. In ad-
 dition, schools may wish to hire an
 experienced and qualified project
 monitor to oversee the asbestos
 contractor's work to make sure the
 removal is conducted safely.
  Only an AHERA-accredited
 management planner—an asbestos
 professional with proper training,
qualifications, and experience—is
authorized to advise school offi-
cials on which response action is
appropriate for a particular situ-
ation. The final selection of the
proper method is up to school offi-
cials after they receive the advice
of the school's accredited manage-
ment planner.
What Should  My School &
School  District  Be Doing?
         nder the new AHERA
         schools rule, each local
         education agency
         (LEA, which means
a school district or private school)
must take the following asbestos-
related actions:

 I Designate and train a person to
oversee asbestos-related activities
in the school system.
   Inspect every school building
for "friable" and "nonfriable"
asbestos-containing building
whatever asbestos actions are nec-
essary and appropriate to protect
health and the environment. These
actions or methods must be docu-
mented in the management plan.
   Prepare a management plan
for managing asbestos and control-
ling exposure in each school.
   Notify the public about the as-
bestos inspection and the availabil-
ity of the asbestos management
plan for review.

W Use only properly accredited
persons to conduct inspections, to
develop the asbestos management
plan, and to carry out the appro-
priate response actions.

/ Keep records of all asbestos-
related activities in the plan and
make them available for public
   Consult with accredited
inspection and management profes-
sionals to identify and carry out

What  Does the LEA
Designated Person
  School officials may choose a
consultant or one of their own
employees to oversee their as-
bestos program. This desig-
nated person must meet certain
training requirements, and
serves as the single point of con-
tact for public information
about asbestos-related activities
in the LEA. He or she is respon-
sible for:
• Ensuring that initial asbes-
  tos inspections, reinspections
  every three years, and semi-
  annual surveillance activities
  are conducted properly by
  qualified personnel.
• Including results of the in-
  spection in the management
  plan. The plan must identify
  all asbestos-containing build-
  ing materials found in
  schools and recommend ac-
  tions for dealing with asbes-
  tos hazards.
• Submitting the management
  plan to the appropriate state
  agency, designated by the
  Governor to review and ap-
  prove plans, by October 12,
  1988 (or by May 9,1989, if
  the school has been granted
  a deferral  by the state).
Making sure that custodial
and maintenance workers re-
ceive required safety training
and information about the lo-
cation of asbestos-containing
materials in their school.
Warning labels must be
posted in all routine mainte-
nance areas, such as boiler
rooms, where asbestos-con-
taining building materials
are found.
Assuring that response
actions specified in the man-
agement plan are carried out
according to the plan's time-
tables. The regulations re-
quire that all LEAs begin to
carry out their management
plans no later than July 9,
Seeing that all asbestos
records required by the reg-
ulations are accurately
Informing  all teacher, par-
ent and employee organiza-
tions at least once a year
about the asbestos activities
in each school and about the
availability of the manage-
ment plan for their review.

-AG- Bb-C-e
When Are School
Management Plans Due?

  As noted before, management
plans originally were due to the
states by October 12,1988. Be-
cause some LEAs have had prob-
lems complying with this dead-
line, however, Congress amended
AHERA to allow school officials to
apply for extra time to inspect
their schools and prepare manage-
ment plans. The amendment per-
mitted LEAs to ask their states
for a deferral of the October 1988
deadline. If the state granted the
deferral, the LEA must submit its
plan to the Governor no later than
May 9,1989. Before applying to
the state for a deferral, an LEA  is
required to notify parent, teacher
and employee organizations of its
plan to file a deferral request. In
the case of a public school, the
LEA was also required to discuss
its intention to file at a public
meeting before submission to the
  Schools which sought deferrals
had to certify to the state that
they made a "good faith" effort to
meet the original October AHERA
deadline. They also had to provide
a schedule outlining significant ac-
tivities leading up to submission of
the plan by May 9,1989. This
schedule of events must include in-
specting the school, having sam-
ples of suspected asbestos material
analyzed by a qualified laboratory,
and preparing the management
  Although your LEA may have
applied for extra time to inspect
its buildings and to prepare its
asbestos naanagement plan, all
schools are still required to begin
putting their plans into action no
later than July 9,1989.
What Can  I

Do to  Help?

          Hs a parent, teacher,
          service worker or other
          school employee, the
          most important thing
you can do first is to learn about
your school's asbestos activities.
As you do so, remember that the
mere presence of asbestos in a
school doesn't necessarily mean
that the health of its occupants is
endangered. Again, asbestos that
is managed properly and main-
tained in good condition poses
relatively little risk. Federal regu-
lations do not require the removal
of all friable asbestos from schools
until the building is demolished.
In fact, during the life of the
building, other methods of dealing
with the material are often prefer-
able to removal.
  In those cases when removing
asbestos is determined to be the
appropriate decision, the work

i -Hl°r H-JHfr  b-  Mm -Nrr
  must be done under strict controls
  by trained, qualified and experi-
  enced asbestos professionals who
  are properly accredited under

  Step One: Awareness

    Your first step is to find out if
  your school has prepared or is pre-
  paring an asbestos management
  plan as required by AHERA. By
  becoming familiar with this plan,
  you will know if asbestos materi-
  als are in the school, what plans
  the school has for managing this
  asbestos, and when these activities
  are scheduled to occur.

  Step TWo: Minimize

    There are several simple things
  you can do to minimize your expo-
  sure to asbestos. The most im-
  portant one is to find out which
  materials in your school contain
  asbestos; you should be able to get
  this information from your LEA's
  designated person  or from the
  school's management plan.
    Once you know where asbestos
  is, use special care to insure that
  any day-to-day activities, such as
  repair or maintenance work, do
  not disturb the material. In fact,
  special training is required to par-
  ticipate in any maintenance activi-
  ties which might disturb asbestos.
  In schools, asbestos-containing
  materials can also be damaged by
student activities. For example, an
asbestos ceiling in a gym may be
disturbed if basketballs or other
objects are thrown up against it.
Students and others who use the
gym. should be warned  to avoid
such activities.

Who Is
for Making
       11 of us are responsible.
       Making the AHERA
       schools rule work to
       I protect the nation's
school children and employees is a
joint responsibility of the LEA
and its officials, school employees,
parents, students, federal and
                      state governments, and asbestos
                      control professionals.
                       EPA conducts compliance in-
                      spections of hundreds of schools
                      each year to make sure they are
                      obeying the law. The Agency is re-
                      sponsible for insuring that schools
                      comply with AHERA and it will
                      investigate reported violations.
                      Since the AHERA schools rule is
                      intentionally designed to involve
                      parent, teacher and other school
                      employee organizations, however,
                      it is important that you work with
                      your school to make sure that
                      its asbestos program is properly
                                A/rr /

Where Can  I
Get  More
         nder AHERA, citizens
         have the opportunity to
         become informed about
         asbestos activities in
their schools. If you have a ques-
tion or concern about those activi-
ties, you should first contact your
LEA designated person. This per-
son knows the most about the as-
bestos situation in your school.
When you find out who this per-
son is, ask him or her what steps
your school has taken, and will
continue to take, to meet the re-
quirements of the AHERA schools
  The LEA designated person
also can tell you which agency in
your state government is responsi-
ble for state AHERA activities.
The same agency usually is re-
sponsible for reviewing the LEA's
asbestos management plan. This
LEA designated person also should
be aware of any local asbestos
control requirements.
  State AHERA designees also
are a good source of information.
These officials can help you better
understand the AHERA schools
rule and can answer questions
about your school's asbestos
  You also can contact your EPA
regional office. There are ten EPA
regional offices around the coun-
try, and each one has a Regional
Asbestos Coordinator (RAG).
Their addresses and phone num-
bers are listed at the end of this
pamphlet. School employees can-
not be penalized for contacting
EPA or the appropriate state
agency to discuss their concerns
about a school's asbestos program.
  Local, state, and national parent
and teacher organizations are
other good sources of information
about asbestos in schools. Many of
these groups worked with EPA in

developing the new AHERA
schools rule, and some have
started their own educational ef-
forts to improve understanding of
the AHERA requirements and
proper asbestos control practices.
The addresses and phone numbers
of the national offices of PTA and
NEA are listed at the end of this
  The EPA Toxic Substances Con-
trol Act (TSCA) Hotline is avail-
able to answer your questions
about the new AHERA regula-
tions and about asbestos in gen-
eral. You can obtain a variety of
asbestos guidance documents by
calling the TSCA Hotline at
(202) 554-1404.
  Finally, EPA has an asbestos
ombudsman to help citizens with
asbestos-in-schools issues, ques-
tions, and complaints. This office
can be reached through a toll-free
number at (800) 368-5888.
Regional Asbestos Coordinators
EPA Region 1
  JFK Federal Building
  Boston, MA 02203
  (617) 565-3835
  (Connecticut, Maine,
  Massachusetts, New
  Hampshire, Rhode Island, and
EPA Region 2
  Woodbhdge Avenue
  Edison, NJ 08837
  (201) 321-6671
  (New Jersey, New York, Puerto
  Rico, and Virgin Islands)

EPA Region 3
  841 Chestnut Street
  Philadelphia, PA 19107
  (215) 597-3160
  (Delaware, District of
  Columbia, Maryland,
  Pennsylvania, Virginia, and
  West Virginia)
EPA Region 4
  345 Cortland Street, N.E.
  Atlanta, GA 30365
  (404) 347-5014
  (Alabama, Florida, Georgia,
  Kentucky, Mississippi, North
  Carolina, South Carolina, and

 EPA Region 5
   230 S. Dearborn Street
   Chicago, IL 60604
   (312) 886-6003
   (Illinois, Indiana, Michigan,
   Minnesota, Ohio, and

 EPA Region 6
   Allied Bank Tower
   1445 Ross Avenue
   Dallas, TX 75202-2733
   (214) 655-7244
   (Arkansas, Louisiana, New
   Mexico, Oklahoma, and Texas)

 EPA Region 7
   726 Minnesota Avenue
   Kansas City, KS 66101
   (913) 236-2835
   (Iowa, Kansas, Missouri, and

EPA Region 8
   One Denver Place
   999 18th Street, Suite 500
   Denver, CO 80202-2413
   (303) 293-1744
   (Colorado, Montana, North
   Dakota, South Dakota, Utah,
   and Wyoming)

EPA Region 9
   215 Fremont Street
   San Francisco, CA 94105
   (415) 974-7290
   (Arizona, California, Hawaii,
   Nevada, American Samoa, and
 EPA Region 10
   1200 6th Avenue
   Seattle, WA 98101
   (206) 442-4762
   (Alaska, Idaho, Oregon, and
National Parent Teacher

National PTA
700 N. Rush Street
Chicago, IL 60611
(312) 787-0977

National PTA
Government Relations Office
1201 16th Street, N.W.
Suite 621
Washington, DC 20036
(202) 822-7878
National Education Association

120116th Street, N.W.
Washington, DC 20036
Division of Government
Relations         U.S. Environment
(202) 822-7300     ' < :n 5, Library
or               / 7 Wesi Jackscn_
Office of General CoQteB°> s L  60 -
(202) 822-7035
                                     ;-41 llli Floor .

          Prepared by the

U.S. Environmental Protection Agency

     •HIM The National
     llC/d Education Association