v>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
EPA
730/
1991.1
c,2
                              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 BUILDING 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!   ,,. .    :,     :,::     .,,..   ,.,  ....:.	;     ^.   .^j...  ..:,-;: .
      Suspect materials are generally divided into three broad categories:
      1)  therma.) system insulation (TSI), such as pipe or boiler wrap;
      2)  sjn^cjpg^rnaten^s. such as sprayed on ceiling materials or fireproofing; and
      3)  miscellaneous, which includes floor tiles and fire doors.
                                                               LIBKAKT
                                                  ENVIRONMENTAL PROTECTION AGENCY
                                                  WASHINGTON, D.C. 20460

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                                                                                                 I
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.
   KNOW THIS!        -;r   -W:            =   '             /:;$v''   'W    '  .   IS
      Homogeneous Area: an area of surfacing material, TSI or miscellaneous material that is
       ^iform in colpr and texture.                                 ,
     -Functional Space: a room, 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
   Q Asbestos was removed in 15 percent of
      the school buildings where response
      actions were completed.

   Q 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.
   H 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:

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

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

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

   FINDINGS:
   G 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.
                                                            SotausfyDefictnt
B  Deficient
                HI Thorough or Some Defldenctes
WHAT THIS MEANS TO YOU:
       It is important that school officials be aware of the asbestos (or suspect 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 reinspcction'). It is also a good time for the
   inspector to correct deficiencies regarding unrecorded locations or unquantified
   amounts of ACBM.
NOTIFICATION 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
FINDINGS:
   Q Eighty-seven percent of schools provided
      maintenance workers with asbestos-related
      training while 7 percent offered no training
      (approximately 6 percent do not have
      maintenance workers). Ninety-five percent of
      schools conducted classes that met the
      two-hour awareness training for custodial
      workers required by AHERA. Only 22
      percent of schools that trained their
      maintenance workers provided  16 or more
      hours of training, as required by law, for those
      employees who may disturb asbestos.
 Percent of Training Which Did Not Describe the
            Location of ACBM
30%
20%
10%
               Custodians
              B Maintenance Personnel
   Q During maintenance-worker training, 25 percent of schools did not describe the locations of
      ACBM in their buildings.  Classes for custodial workers included the locations in all but 18
      percent of the schools.

   Q According to discussions with some custodial and maintenance workers, frequent
      unprotected and inappropriate work practices occur in schools. Often, workers did not
      perceive everyday tasks as disturbing asbestos, unless the asbestos was sawed, cut, or in
      some other way visibly damaged.

   WHAT THIS MEANS TO YOU:
      It is important that schools train custodial and maintenance workers appropriately. It is the
   LEA's responsibility to ensure that:

   Q all maintenance and custodial workers who work in school buildings with ACBM receive
      at least 2 hours of awareness training;

   Q specific locations of ACBM in each building are included in the two-hour training;

   Q all maintenance and custodial workers who may disturb ACBM receive an additional 14
      hours of training;

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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.

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

   G  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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