EVALUATION OF THE ASBESTOS
HAZARD EMERGENCY RESPONSE ACT (AHERA)
PEER REVIEW DRAFT FINAL REPORT
By:
Alexa Fraser
Robert Clickner
Naomi Everett
Susan Viet
Westat, Inc.
1650 Research Boulevard
Rockville, MD 20850
Prepared fon
Christine Augustyniak, Task Manager
Economics and Technology Division
U.S. Environmental Protection Agency
Washington, DC 20460
January 4,1991
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RESEARCH TEAM
Stephen K. Dietz, Vice President of Environmental Studies
Alexa Fraser, Ph.D., Project Director
Robert Clickner, Ph.D., Senior Statistician
Leslie Wallace, Adam Chu: Statisticians
Susan M. Viet, CIH, Senior Analyst
Thomas P. Milke, Senior Data Processing Coordinator
James August, Consultant
Eva Clay, CIH, Environmental Management Group, Consultant
William Ewing, CIH, Environmental Management Group, Consultant
Steve Hays, CIH, Gobbell Hays Partners, Inc. Consultant
Dale L. Keyes, Ph.D., Environmental Sciences, Inc., Consultant
David Mayer, Law Associates, Consultant
FIELD AND SUPPORT STAFF
William Devlin, John Michael, Ph.D.: Contract Coordinators
Naomi Everett, Field Director
Shirley Finnegan, Field Supervisor
Scotty Fallah, Deputy Field Director
Grethel Hoffmaister, Field Assistant
Susan Sole, Field Assistant
Diane Sickles, Coding Supervisor
Doug Duncan, David Lemanski, David Lowe: Programmers
Firms Providing Inspectors:
Environmental Management Group
Environmental Sciences, Inc.
Kasalaan & D'Angelo Associates, Inc.
Secretaries: Sandy Gallagher, Marsha Leizman, Nita Lemanski, Patricia Thayer,
Bonnie VanZile
Editor: Carol Hannaford
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TABLE OF CONTENTS
Chapter Page
GLOSSARY xiii
EXECUTIVE SUMMARY .-. xxiii
1 INTRODUCTION 1-1
1.1 Background 1-1
1.2 Description of AHERA 1-2
1.3 Study Tasks 1-4
1.4 Research Areas and Design 1-6
1.5 Final Report 1-10
2 METHODOLOGY OVERVIEW 2-1
2.1 Sampling Methodology for the AHERA
Building Sample 2-1
2.2 Building Inspection Protocols 2-2
2.2.1 Definition of a Building 2-2
2.2.2 Materials Included 2-3
2.2.3 Excluded Materials and Areas 2-3
2.2.4 Bulk Sampling 2-7
2.2.5 Field Procedures 2-8
2.3 Pretest of Data Collection Procedures and Forms 2-8
2.4 Contacting the Local Education Agencies
and Schools 2-10
2.4.1 School Eligibility and Sample Selection -
Task 1 2-10
2.4.2 Scheduling Interviews and Inspections 2-12
2.5 Field Data Collection 2-12
2.5.1 AHERA Designated Person Interview - Task 2 2-13
2.5.2 Reinspection of Schools-Task 3 2-16
2.5.3 Principal Interview-Task 4 2-21
2.6 Management Plan Evaluation 2-22
2.6.1 Management Plan Evaluation - Task 5 2-22
2.6.2 Original Inspector's Performance Score 2-24
2.7 Telephone Interviews 2-24
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TABLE OF CONTENTS (cont'd.)
Chapter Page
2.7.1 Parent and Teacher Notification Survey- Task 6 2-25
2.7.2 Original Inspector Survey - Task 7 2-25
2.8 Focus Groups 2-26
2.8.1 Parent and Teacher Notification Focus
Groups - Task 8 2-27
2.8.2 Maintenance and Custodial Workers Focus
Groups - Task 9 2-28
2.9 Schools Included in the Sample 2-28
3 SCHOOL BUILDING REINSPECTION 3-1
3.1 Suspect Material Found in the Original AHERA
Inspections 3-3
3.1.1 Identification of Materials 3-6
3.1.2 Estimation of Material Quantities 3-11
3.1.3 Recording Material Locations 3-15
3.2 Assessment of ACBM Found at Original AHERA
Inspection 3-21
3.3 Summary 3-24
4 MANAGEMENT PLAN EVALUATION 4-1
4.1 Completeness of Management Plans 4-1
4.2 Up-to-Dateness 4-10
4.3 Usability of Management Plans 4-12
4.4 Summary 4-17
5 RESPONSE ACTION EVALUATION 5-1
5.1 Response Actions Recommended in
Management Plans 5-1
5.2 Appropriateness of Response Actions Recommended 5-3
5.3 Evaluation of Response Actions Actually
Undertaken in Schools 5-5
5.4 Summary 5-9
6 ORIGINAL AHERA INSPECTION EVALUATION 6-1
6.1 Scoring the Original AHERA Inspection 6-2
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TABLE OF CONTENTS (cont'd.)
Chapter Page
6.1.1 Scoring Individual Materials 6-2
6.1.2 School Inspection Score 6-7
6.2 Analysis of Original AHERA Inspector's
Background 6-9
6.3 Summary 6-19
7 PROCESS OF NOTIFICATION 7-1
7.1 Persons Notified 7-2
7.2 Method of Notification 7-4
7.3 Response to Notification 7-8
7.4 Alternative Notification Contents 7-13
7.5 Summary 7-14
8 MAINTENANCE AND CUSTODIAL WORKERS
TRAINING AND EXPERIENCE 8-1
8.1 Training of Maintenance and Custodial Workers 8-2
8.2 Curriculum of Training 8-9
8.3 Tasks Required of Maintenance and Custodial
Workers 8-14
8.4 Summary 8-17
9 OTHER FINDINGS 9-1
9.1 Possible Compliance with AHERA 9-1
9.2 Clearance Air Monitoring Tests Performed 9-4
9.3 Current Assessment of Suspect Material in Schools 9-5
10 STATISTICAL PROPERTIES OF THE SAMPLE 10-1
10.1 Response Rates for the AHERA Evaluation 10-1
10.1.1 Building Access Results 10-1
10.1.2 Potential for Bias 10-3
10.2 Methodology for Weighting, Imputation, and
Variance Estimation 10-7
10.2.1 Weighting Methodology for the AHERA
Evaluation 10-7
10.2.2 Imputation for the AHERA Evaluation 10-7
10.2.3 Variance Estimation 10-8
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TABLE OF CONTENTS (cont'd.)
Appendices
Appendix
A AHERA Evaluation Data Collection Forms A-l
B Training Materials for Completing Field Forms for the AHERA
Evaluation To be done
C Training Materials for Completing Telephone Forms for the
AHERA Evaluation (Screening Questionnaire, Inspector
Questionnaire, Parents and Teachers Notification Questionnaire)... To be done
D Parent and Teacher Notification Focus Group Guide
and Summary D-l
E Maintenance and Custodial Workers Focus Group Guide and
Summary E-l
F Management Plan Completeness Item Results F-l
G EPA Key Elements Checklist G-l
H Local Education Agency and School Contact Letters H-l
I Coefficients of Variation and Confidence Intervals To be done
J Frequency Tables for Coded Questions To be done
K Statistical Technical Appendix K-l
L Assessment Score Tables L-l
List of Tables
Table
2-1 Field effort by wave 2-13
2-2 The percentage of schools nationwide by eligibility status 2-30
3-1 Estimated number and percent of suspect materials identified
in original AHERA inspections, by material category and
friability 3-7
3-2 Estimated quantity present and percentage identified in
original AHERA inspections of suspect materials, by material
type and friability 3-9
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TABLE OF CONTENTS (cont'd.)
List of Tables (cont'd.)
Table
3-3 Percentage of material quantities underestimated in
original AHERA inspection, by material category, asbestos
content and friability 3-14
3-4 Estimated percent of areas with suspect materials present,
but not recorded in original AHERA inspection, by area
type and material type 3-18
3-5 Estimated percent of areas with ACBM present, but not
recorded in original AHERA inspection, by area type and
material type 3-19
3-6 Percent of ACBM in school buildings assessed appropriately in
the original AHERA inspection 3-23
3-7 Percent of ACBM in school buildings assessed appropriately
in accordance with AHERA in the original AHERA inspection 3-24
4-1 Percent of Management Plans awarded various normalized scores
for completeness points for Form Ml 4-4
4-2 Percent of Management Plans containing AHERA-required
clearance air monitoring results 4-11
4-3 Percent of Management Plans containing various features
that increase usability 4-12
4-4 Percent of Management Plans containing usability
elements 1 - 7 4-13
4-5 Percent of Management Plans where features that decrease
usability were present 4-14
4-6 Percent of Management Plans using AHERA-defined terms
correctly 4-14
4-7 Percent of schools which defined Management Plan
terms correctly 4-15
4-8 Percent of Management Plans usable and understandable
without instruction, by persons of various educational
attainments 4-16
4-9 Percent of Management Plans judged easily usable without
prior instruction, by different types of persons 4-17
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TABLE OF CONTENTS (cont'd.)
List of Tables (cont'd.)
Table Page
5-1 Estimated numbers and percentages of recommended response
actions by asbestos material type 5-2
5-2 Estimated numbers and percentages of school buildings with
different recommended response actions by asbestos material
type 5-3
5-3 Characteristics of recommended response
actions by material type 5-4
5-4 Adequacy of response actions performed, by material type and
response action category 5-10
5-5 Differences in adequacy of response actions performed in
school buildings, by action 5-11
5-6 Differences in adequacy of response actions performed in
school buildings, by material type 5-12
6-1 AHERA Inspection Evaluation: Material Scoring Plan 6-6
6-2 Inspection quality by scoring factor 6-5
6-3 Comparison of different material weightings for computing
school inspection scores 6-10
6-4 Estimated percent of inspections in each range 6-12
6-5 Association between number of suspect materials in a school
and the school inspection score 6-14
6-6 Association between number of missed materials in a school
and the school inspection score 6-15
6-7 Selected characteristics of AHERA inspectors at the time
of the subject school inspection 1 6-16
6-8 Median school inspection scores by selected characteristics
of the AHERA inspector 6-17
6-9 Pearson correlation coefficients between school inspection
scores and selected original AHERA inspector attributes 6-18
7-1 Percent of schools notifying parents and teachers about
activities pertaining to asbestos since December 1987 7-3
7-2 Percent of schools notifying parents and teachers once
and more than once 7-3
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TABLE OF CONTENTS (cont'd.)
List of Tables (cont'd.)
Pace
7-3 Percent of schools using specific methods to notify
parents and teachers 7-5
7-4 Percent of schools with various contents in notification
as reported by principals, parents, and teachers 7-7
7-5 Percent of schools with notifications where parents
and teachers reacted to notification, as reported by
principals, parents, and teachers 7-9
7-6 Percent of schools where parents and teachers took
specific actions in response to notification 7-10
7-7 Percent of schools where various degrees of concern
were expressed by parents and teachers as reported by
principals, parents, and teachers 7-11
8-1 Percent of schools offering maintenance and custodial
worker training since October 1987 8-3
8-2 Percent of schools offering various lengths of
maintenance and custodial worker training since
October 1987 8-5
8-3 Percent of schools providing training to maintenance
and custodial workers since October 1987 8-6
8-4 Percent of schools with different training intervals
for maintenance workers and custodians 8-7
8-5 Percent of schools with different provisions for
training newly hired maintenance workers and custodians 8-8
8-6 Percent of schools where the location of training sessions
for LEA-employed maintenance and custodial workers was on-site,
off-site, or both 8-10
8-7 Percent of schools where training offered to LEA-employed
maintenance workers and custodians contained a description
of where asbestos-containing building materials were found
in the school 8-11
8-8 Percent of schools where training offered to LEA-employed
maintenance workers and custodians included a description of
the location of asbestos, by method of presentation 8-11
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TABLE OF CONTENTS (cont'd.)
List of Tables (cont'd.)
Table Page
8-9 Percent of schools where training presented information
on locations of asbestos-containing building materials 8-12
9-1 Estimated national percent of schools with selected responses
to screening interview 9-2
9-2 Estimates of noncompliance with the Management Plan and
inspection portion of AHERA under various assumptions 9-4
9-3 Percent of Management Plans that contained air sampling results
that used Transmission Electron Microscopy (TEM) and Phase
Contrast Microscopy (PCM) for their tests 9-5
9-4 Amount of ACBM material in each AHERA category at time of
reinspection, by material type and unit of measurement 9-8
9-5 Percent of ACBM material in each AHERA category at time of
reinspection, by material type and unit of measurement 9-9
10-1 Participation status of schools in the sample 10-1
10-2 Final completion status for schools in RA4 and RA5 10-2
10-3 Response rates for AHERA (%) 10-3
10-4 The schools in the AHERA evaluation by certain demographic
variables at various stages of sampling 10-4
10-5 The schools in the primary sample by response status
and certain demographic variables 10-6
List of Exhibits and Figures
Exhibit Page
2-1 Material types included in the AHERA evaluation 2-4
2-2 Material types excluded from the AHERA evaluation 2-5
2-3 Area classification for the AHERA evaluation 2-6
2-4 Flow chart of field procedures 2-9
4-1 Normalized overall completeness scores for Management Plans 4-5
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TABLE OF CONTENTS (cont'd.)
List of Exhibits and Figures (cont'd.)
Figure Page
3-1 Quantity of suspect material identified in original AHERA
inspection, by material category and friability 3-10
3-2 Incidence of buildings with suspect materials identified
and unidentified in original AHERA inspection, by
material type 3-12
3-3 Percent of buildings with suspect material quantity
underestimated in original AHERA inspection by
material category, asbestos content and friability 3-16
3-4 Percent of buildings with areas containing suspect
materials present, but not recorded in original AHERA
inspection, by material category, asbestos content and
area use 3-22
5-1 Estimated number of recommended response actions by
school building, among buildings with ACBM 5-6
5-2 Differences in characteristics of recommended response
actions within school buildings (percent of buildings
with indicated characteristics) 5-7
6-1 Distribution of original inspection scores on
individual materials 6-8
6-2 Mean inspection score by material type 6-9
6-3 Estimated national distribution of school inspection
scores 6-11
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GLOSSARY
ACBM
Asbestos-containing building material means surfacing
ACM, thermal system insulation ACM, or miscellaneous
ACM that is found in or on interior structural members or
other parts of a school building.
ACM
Asbestos-containing material means, when referring to
school buildings, any material which contains more than one
percent asbestos.
ACM Condition
Good: ACM with no visible damage or deterioration, or
showing only very limited damage or deterioration.
Damaged: ACM showing physical injury or deterioration
such that the internal structure of the material is inadequate,
or which has delaminated such that its bond to the substrate
is inadequate, or which lacks fiber cohesion or adhesion
properties for any other reason, or where TSI lacks part or
all of its covering. Such damage may be illustrated by the
separation of ACM into layers; flaking, blistering, or crum-
bling; water damage or stains; scrapes, mars or gouges; ex-
posed TSI beneath its covering.
Significantly Damaged: ACM showing damage which is ex-
tensive and severe.
ADP
AHERA
AHERA designated person.
Asbestos Hazard Emergency Response Act. This Act was
signed into law on October 22,1986 by President Reagan. It
requires, among other things, that primary and secondary
schools identify asbestos-containing materials in school
buildings, and institute programs aimed at minimizing the
risk of asbestos exposure in those buildings.
AHERA Designated
Person (ADP)
A person designated by the Local Education Agency to en-
sure that the AHERA requirements are properly imple-
mented.
Area
A well-defined space within a building, generally a distinct
room but may be a hall, crawlspace and so on.
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Asbestos
Naturally-occurring fibrous mineral used in many building
materials primarily for the purposes of fireproofing, thermal
insulation, sound insulation and decorative use.
Assessment
Evaluation of the physical condition and potential for
damage of all friable ACM and thermal system ACM.
AHERA requires classification of each ACBM assessed into
one of seven categories based on material type and
damage/potential for damage.
Building
A separate structure. Two structures sharing an interior wall
are considered one building, even though they may have
been constructed at different times. Two structures
connected only by an above-ground (covered or uncovered)
or underground walkway are considered two buildings.
Custodian
A person who is responsible for performing day-to-day rou-
tine care of the building; including such tasks as cleaning of
floors and bathrooms, locking doors and general security,
reporting items in need of repair, emptying garbage. In
some schools, the custodian is responsible for repairs as well
as general care, i.e., there are no individuals referred to as
maintenance workers in those schools. Schools may employ
custodial staff or may hire a vendor to perform custodial
services.
Eligibility
Criteria
Factors used to determine whether to include a
school/building in the study. Specifically, school criteria are:
if classes in any of grades 1-12 were taught during the 1989-
90 school year and if the school had a Management Plan.
Building criteria are: if the building was built before
October 1988 and had been inspected for ACM since
December 1987, if the inspection discovered ACM or sus-
pect ACM, and if students in any of grades 1-12 were re-
gularly in the building during the 1989-90 school year.
Encapsulation
The treatment of asbestos-containing material (ACM) with
a liquid that covers the surface with a protective coating or
embeds fibers in an adhesive matrix to prevent the release of
asbestos fibers.
Enclosure
An air-tight, impermeable, permanent barrier around as-
bestos-containing material to prevent the release of fibers.
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EPA
Exclusion
Environmental Protection Agency
One of several situations which permit a LEA to delete one
or more of the items required by AHERA, e.g. records of
previous sample collection and analysis may be used by the
accredited inspector in lieu of AHERA bulk sampling.
Exterior Areas
Subdivison of areas of a building with one or more walls
open to the outside, such as covered walkways or porticos.
Forms
Al - AHERA Designated Person Interview - In-person ques-
tionnaire administered to the ADP to collect information on
building eligibility, Management Plans, and maintenance and
custodial training.
A2 - Building Information Questionnaire - In-person ques-
tionnaire completed by the interviewer after Form Al to
obtain information about the selected building's construction
and asbestos history.
Wl • Response Action Assessment - In-person data collec-
tion form used to record response actions as reported by the
ADP, and the completed during the walkthrough.
W2 • Area Identification - Data collection form used to iden-
tify and categorize each area inspected and to record num-
ber of suspect homogeneous materials.
W3 - Suspect Homogeneous Materials - Data collection
form used to record all suspect homogeneous materials in an
area, the quantity of each material, and the assessment
factors used to calculate the AHERA 1-7 category for each
material.
II - Suspect Homogeneous Materials Key Code - Three
forms, one each for TSI, surfacing, and miscellaneous ma-
terial, used to generate a unique identification number for
each suspect homogeneous material found in a building.
12 - Suspect Homogeneous Materials Calculations - Calcula-
tion space for inspectors to determine the quantity of a
homogeneous material in one area.
PI - Principal Interview - In-person questionnaire adminis-
tered to the school principal to collect information on notifi-
cations.
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Forms (cont'd.)
Nl - Parent and Teacher Notification Interview - Telephone
questionnaire administered to one parent and one teacher
from each school in the study sample, to collect notification
information.
Ol - Original Inspectors Interview - Telephone
questionnaire administered to the inspectors who conducted
the original AHERA inspection for the schools in the study
sample.
Ml - Management Plan Checklist - Checklist completed by
Management Plan reviewer to obtain information on the
Plan's completeness, usability, and content and thus present
a structure for grading the Plan.
M2 - Management Plan Comparison Report - computer
generated form that presents findings of the Westat rein-
spection with space for the Management Plan reviewer to fill
in findings of the original AHERA inspection for each ma-
terial found by Westat.
Friable
Functional Space
Material that, when dry, can be crumbled, pulverized, or re-
duced to powder by hand pressure.
A room, group of rooms or homogeneous area designated by
a person accredited to prepare Management Plans, design
abatement projects, or conduct response actions.
General Access Areas
Subdivision of areas of a building which includes all areas
accessible to school staff and students on a regular basis.
Homogeneous
Material
For this study, material that is uniform in color, texture and
appearance, was installed at one time, and is of a distinct
material type and use. The homogeneous material is
analogous to AHERA's homogeneous area.
Homogeneous Area
In accordance with AHERA definitions, an area of surfacing
material, TSI, or miscellaneous material that is uniform in
color and texture.
HVAC
Heating, Ventilating and Air Conditioning.
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Identified Material
Any suspect material found during the study reinspection
that was also recorded in the relevant Management Plan for
a particular building.
LEA
Local Education Agency
Limited Access
Areas
Subdivision of areas of a building which includes areas
accessible to staff and teachers, but not students, on a
regular basis.
Local Education
Agency (LEA)
An educational agency at the local level that exists primarily
to operate schools or to contract for educational services.
This includes primary and secondary public and private
schools.
Maintenance Worker
A person who is responsible for repairing, cleaning, or reno-
vating machines or for repairing or renovating other building
parts. Schools may employ persons as maintenance staff or
may hire a vendor to perform maintenance work.
Management Plan
A document that each Local Education Agency is required
to prepare under AHERA regulations. This document de-
scribes all activities planned and undertaken by a school to
comply with AHERA regulations, including: building inspec-
tions to identify asbestos-containing materials, response
actions, and operations and maintenance programs to mini-
mize the risk of exposure to asbestos in school buildings.
Material Category
Broad classification of suspect materials into TSI, surfacing
material and miscellaneous material.
Material Type
Classification of suspect material by its specific use or
application, e.g., pipe insulation, fireproofing and floor tile.
Mechanical
Areas
Subdivision of areas of a building which includes boiler
rooms, pipe shafts, telephone and electrical closets, and so
forth.
Miscellaneous
Material
Interior building material on structural components, such as
floor or ceiling tiles. Does not include TSI or surfacing ma-
terial.
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Original AHERA
Inspection/Original
Inspection/Inspection
Examination of school buildings arranged by Local Educa-
tion Agency, pursuant to AHERA, to identify asbestos-con-
taining materials, evaluate the condition of those materials,
and take samples of materials suspected to contain asbestos.
Inspections are to be performed by inspectors accredited by
the EPA.
OSHA
Permanent Building
Occupational Safety and Health Administration.
A permanent building is any building with poured concrete,
cinder block with mortar, or other non-temporary founda-
tion.
Principal
A staff member performing the assigned activities of the
administrative head of a school to whom has been delegated
major responsibility for the coordination and direction of
the activities of the school.
Private School
A private school is an elementary or secondary school (1)
controlled by an individual or agency other than a State, a
subdivision of a State (county, city, etc.), or the Federal
government; (2) usually supported primarily by other than
public funds; and (3) the operation of whose program rests
with other than publicly elected or appointed officials.
PSU
Primary Sampling Unit, a geographic area, usually a county
or group of counties, defined by the Census Department for
survey sampling purposes.
Public School
A public school is administered by state and local govern-
ments, including counties and territories and is paid for with
state and local funds.
Recorded Area
An area in which a suspect material is present during the
study reinspection, and which is also indicated in the
Management Plan as having the same material present.
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Reinspection
The examination of homogeneous materials in which an
original AHERA inspection has been performed previously.
For this study, reinspections were performed without know-
ledge of the results of the original AHERA inspection.
Remediation
Repair, encapsulation, enclosure, or removal of greater than
3 linear feet or square feet of ACBM.
Removal
The taking out or stripping of substantially all ACBM from a
damaged area of material or from a room.
Repair
Repair refers to procedures used to patch or cover damaged
asbestos-containing materials other than enclosure or encap-
sulation. Examples include covering the damage with plastic
sheeting, duct tape, or plaster.
Response Actions
Any of the following actions taken in school buildings in re-
sponse to AHERA, to reduce the risk of exposure to as-
bestos in school buildings: removal encapsulation, enclosure,
repair, and operations and maintenance.
Secondary School
A school that meets the state's definition of a secondary
school. A school that is intermediate in level between ele-
mentary school and college.
Superintendent of
Schools
A staff member who is the Chief Executive Officer of a
school administrative unit or Local Education Agency.
Surfacing Material
Materials sprayed or troweled onto structural members
(beams, columns or decking) for fire protection; or on ceil-
ings or walls for fireproofing, acoustical or decorative pur-
poses. Includes fireproofing, textured plaster, and other tex-
tured wall and ceiling surfaces.
Suspect Material
Building material suspected of containing asbestos because
of past practices in its manufacture and use; includes sur-
facing material, floor tile, ceiling tile, thermal system insula-
tion, and miscellaneous other materials. Suspect materials
are classified as ACM or non-ACM by analyzing bulk sam-
ples to determine asbestos content.
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Teachers' Union
Representative
A teacher's union representative may be of the National
Education Association (NEA), American Federation of
Teachers (AFT), or other union or associations. These
representatives may be called "shop stewards," "building
representatives," "union representatives," "officers," or
"association representatives."
Temporary Building
A temporary building is a structure put in place for a
specific, short-term purpose. The structure will be taken
down when that purpose is completed.
Total Amount
Estimated amount of suspect material in a building/s at the
time of the original AHERA inspection.
Transite
TSI
Commonly used trade name for cement asbestos product.
Thermal System Insulation; i.e., insulation applied to steam
and hot and cold water systems and HVAC systems to pre-
vent heat transfer and water condensation. Includes pipe in-
sulation; pipe joint, valve, fitting and elbow insulation; and
insulation applied to boilers, water tanks, compressors, air-
handling equipment, radiators, ducts, etc.
Underestimated Amount
The difference between the quantity of a suspect material
found during the study reinspection and the quantity of the
same material recorded in the Management Plan, when the
latter quantity is less than 80 percent of the former.
Unidentified Material
Any suspect material in the study that is not addressed in the
relevant Management Plan for a particular building but
which was found during the study's reinspection of the
building.
Usability
A measure of the ease with which a person learns from the
Management Plan which materials are asbestos, the
condition of the asbestos materials, and what special
precautions should be taken around those materials.
Included in the measure are document formatting items
such as glossaries and table of contents, and clarifying items
such as accurate use of terminology and floorplans.
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VAT Vinyl asbestos floor tile
VDC Vibration dampening doth, usually found on ductwork
where duct size changes, used to reduce noise.
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EXECUTIVE SUMMARY
In the fall of 1989, EPA's Office of Toxic Substances asked Westat to perform an
evaluation of the implementation of the Asbestos Hazard Emergency Response Act
(AHERA). The AHERA regulations called for the inspection of all elementary and
secondary schools in the nation to identify any asbestos-containing building materials
(ACBM) present, preparation of an Asbestos Management Plan for each school, notification
of parents and staff of the availability of the Management Plan for review, training of school
maintenance and custodial workers, and other tasks.
The AHERA evaluation study focused on occupied school buildings with students
in any of grades 1 through 12 in the U.S. There were few exclusions: buildings built more
recently than October 19881, buildings where the original AHERA inspection found no
asbestos, and buildings where no inspection was conducted in response to AHERA or where
no Management Plan was prepared. We estimate that the schools included in the evaluation
study represent approximately 80 percent of all schools in the nation.
The AHERA evaluation was conducted in a national statistical sample of 30
communities, in which we visited 198 schools and a total of 207 school buildings. Specially
selected and trained inspectors thoroughly reinspected each sampled school building and their
findings were compared with the original AHERA inspection at each school. In-person
interviews were conducted with each school's principal and AHERA designated person (the
person legally responsible for asbestos in the school). In addition, telephone interviews were
conducted with the inspector who had performed the original AHERA inspection, the head of
the PTA (or other active parent), and an active teacher in the school.
In both the original AHERA inspections and the reinspections, the inspectors
looked for suspect materials. Suspect materials are materials suspected to contain asbestos
because of past practices in their formulation and manufacture. Inspectors find and assess
1 Any building built after this date was not required to be inspected. AHERA regulations provide that an architect could certify
that the building contained no asbestos.
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asbestos by finding and assessing suspect materials. Laboratory analysis of a bulk sample is
required to determine if a particular suspect material in fact contains asbestos. However, to
efficiently utilize project resources, no bulk sampling or laboratory analysis was performed in
the AHERA evaluation. Instead, we focused on evaluating how well the original inspectors
identified, assessed, described, and quantified suspect materials.
To supplement the statistical data collected from these members of sampled
school's communities, a number of focus groups were undertaken in communities nationwide.
Four focus groups were held with parents and teachers not associated with schools in our
sample. In addition, five focus groups were held with school maintenance and custodial
workers also not associated with our sampled schools. In both cases participants to the groups
were not selected in a random or other statistical manner. Rather, as is usually the case in a
focus group, participants were invited purposefully to create a group with many different types
of participants. While this small sample of focus groups is not a reliable basis for statistical
estimate (and has not been used in such a way) it does provide useful qualitative insights into
the notification process and maintenance and custodial training.
The AHERA evaluation research consisted of six separate research areas. Each
research area addressed a different aspect of the AHERA program: school building
inspections, Management Plans, response actions, original AHERA inspector evaluation,
notification, and maintenance and custodial worker training. EPA, in consultation with
Westat and the technical consultants who worked on this project, developed specific research
questions for each research area. The goal of the evaluation research was then to collect and
analyze data to answer the questions. A brief summary of the research questions and the
study findings follows.
School Building Reinspection
• Was all the suspect material found at the original AHERA inspection ?
• Was the asbestos found at the original AHERA inspection property assessed?
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The goal of this research area was to estimate how much of the suspect material
was found in the original AHERA inspections and how much of the ACBM was assessed in
conformance with AHERA regulations. "How much" was measured in three ways: (1) how
many of the distinct suspect materials in school buildings were identified; (2) to what extent
were quantities of identified materials underestimated; and (3) what percentage of the areas
with each type of suspect material were recorded in the original inspection.
Figure 1 illustrates the universe of suspect materials in school buildings, and
some of the difficulties inherent in evaluating building inspections after the passage of several
months or more. The union (areas A, B, and C) of the two circles represents the universe of
suspect materials in school buildings at the time of the original AHERA inspection. The
circle on the left (areas A and B) represents materials found by the original AHERA
inspector. The circle on the right (areas B and C) represents materials found in the
reinspection.
Figure 1. Universe of suspect materials in school buildings2
Found both
by original
inspector
and in
reinspection
Missed in
original
inspection;
found in
reinspection
2 Diagram for illustration only. Ratios in actual data are not shown.
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An estimated 70 percent of the distinct suspect materials present in school
buildings was identified by the original AHERA inspectors. (In Figure 1, A + B is 70 percent
of A + B + C, when counting distinct suspect materials.) We would also like to estimate the
fraction of total quantity that the original inspector found (i. e., A + B for square feet or
A + B + C
linear feet). Unfortunately, the quantity already abated (A) is not known. However, we can
calculate —P_ as a lower bound on A + B . When we did this we found that, in
B + C
terms of quantity of subject material,
JL_ is 89 percent so that A + B
B
is at least
this high. This tells us that the original AHERA inspectors succeeded in identifying the vast
majority of the suspect material.
Our reinspections revealed that once the original AHERA inspectors had
identified suspect material they estimated the quantity within acceptable accuracy levels in
over 50 percent of buildings and estimated the quantity of each ACBM "correctly"3 in over 60
percent of buildings. The overall quantity of material underestimated ranged from 9 percent
(for TSI) to 55 percent (for friable miscellaneous materials). Also, original AHERA
inspectors recorded the specific locations of identified ACBM in approximately 60 percent of
the areas where the material was present.
With regards to assessment of ACBM, the original AHERA inspectors assessed
almost all materials appropriately. (Appropriate means that Management Plans assessed the
condition and potential for disturbance in accordance with AHERA requirements. Forty-four
percent of the original AHERA inspectors utilized the AHERA 1-7 assessment categories,
however. Those who did use them generally applied them appropriately.
Management Plan Evaluation
• Do schools know and understand the regulation, as shown by the
completeness of the Management Plan and degree to which the Management
Plan has been kept up to date?
Original quantities were considered "correct" if they were no more than 20% below the reinspection quantity.
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Management Plans nationwide were evaluated for completeness, up-to-dateness,
and usability. Completeness for this study was based primarily on the EPA's Key Elements
Checklist. Management Plans were generally quite complete, with 80 percent (±6%) of the
Plans receiving a score of 75 points or higher on a completeness scale of 1-100. However, 5
percent (±4%) of Management Plans received a score of 50 or below, making it clear that
these Plans, even with Federal and State guidelines, were substantially incomplete.
The second criterion, degree of up-to-dateness was studied by looking at whether
or not the results from the air monitoring tests used to clear an area as safe after a response
action were submitted with the Management Plan. Significantly, 56 percent (± 11%) of Plans
which should have, did not contain these results. This may be because schools did not
photocopy these pages when they gave us their Management Plan, because air sampling did
not have occurred at the time of a response action, or as it relates to up-to-dateness, air
sampling results were not filed with the Plan.
The third criterion, usability, was developed to determine how useful a Plan
would be and whether or not it could easily be used as a reference. This analysis looked at
features which would ease use of a Management Plan, such as table of contents, page
numbering, and floorplans showing sampling locations, homogeneous areas, or ACM. Many
Plans missed one or more of these elements. Also evaluated were various features which
decrease usability, such as computerized data not explained, or problems with the
presentation of homogeneous area information. Sixty-nine percent of Plans had one or more
features that detract from ease of use. AHERA defines four highly significant terms for use
in inspections and reporting. These terms are homogeneous area, functional space, exclusion,
and random sampling. All four terms were defined and used correctly in only 37 percent
(±9%) of Management Plans, while exactly 3 of the 4 were defined correctly in 46 percent
(± 12%). The final element used in our efforts to determine Plan usability was an attempt to
determine the percentage of Plans usable and understandable by persons of various
educational attainments. We found that 39 percent (±5%) of Plans are written for persons
with some college and that an additional 22 percent (±6%) could be used only by people who
had instructions in use.
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Response Action Evaluation
• What response actions wen recommended in the Management Plan?
• Arethey appropriate, given the assessed condition of the asbestos?
• Have the response actions undertaken in the school been done property?
An estimated 302,001 response actions were recommended in the Management
Plans of 126,282 of the 179,093 school buildings with ACBM. Over half of the recommended
response actions were for the establishment of operations and maintenance programs.
Another third specified the repair of damaged areas. Ten percent of the recommendations
were for removals of some or all of the ACBM.
Nearly all recommended response actions were appropriate, given the assessed
condition of the material. However, only 39 percent went beyond the minimal requirements
of AHERA and 80 percent were generic, that is, they failed to specify the locations where the
response actions should be performed.
Response actions reported to the reinspectors were visually evaluated to
determine the adequacy of the response actions. The definition of adequacy varied with the
type of response action. For example, an enclosure was considered adequate if it appeared to
be airtight and impact resistant. Removals were considered adequate if there was no visual
evidence of remaining material
An estimated 246,260 response actions have been performed in an estimated
37,673 school buildings, through the Spring of 1990. This represents 21 percent of school
buildings with ACBM. Eighty-seven percent of the response actions were visually judged to
be adequate. Most encapsulations, repairs and removals were considered adequate.
However, only three percent of the 19,440 performed enclosures were adequate. Removals
were performed in 28,870 buildings, 16 percent of the buildings with ACBM.
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Original AHERA Inspection Evaluation
• Given the quality of the original AHERA inspection, as shown by a
comparison between the reinspection findings and the findings presented in the
Management Plan, what is the importance of the original AHERA inspector's
training, experience and background in inspection quality?
The research team, in consultation with the expert consultants, developed a
system for scoring a school inspection. The system evaluated the original AHERA inspector's
ability to perform with respect to six components of an inspection. In descending order of
importance - in the research team's judgement - the six components are: identify a suspect
material, assess it appropriately, record the areas where it was located in the school, quantify
if within acceptable standards of accuracy, take the correct number of bulk samples, and use
the AHERA assessment categories. Each suspect material in a school building was scored on
a scale from 0 to 40 according to the original inspector's performance on the six components.
A score of 40 was assigned if the original inspector satisfied all six criteria; a score of 0 was
assigned if the inspector failed to identify the material. Material scores were averaged to
obtain a school average inspection score. The school average scores were grouped into ranges
that characterize the inspector's performance. The ranges, their descriptions, and the
percentage of inspections in each range are as follows.
Range: 37-40. Thorough inspection". 16 percent of inspections.
On average, satisfied the 4 most important components, but may have
failed on one or both of the other 2 components.
Range: 29-36. "Some deficiencies". 46 percent of inspections.
On average, satisfied the 2 most important factors, but either failed to
accurately quantify the material or adequately locate it.
Range: 0-28. "Severe deficiencies". 38 percent of inspections.
On average, failed to identify the material, or assess it appropriately, or
quantify or locate it.
The primary causes of deficient inspections were failure to identify all suspect
material in a school, failure to either record the locations of the ACBM, and failure to
quantify it within acceptable standards of accuracy.
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Telephone interviews were conducted with the original inspectors to capture
information about their education, experience, and background. Statistical analyses of the
relationship between the inspection scores and the inspectors' backgrounds were conducted.
We found no statistically significant associations between any measured characteristic (e.g.,
education) of the inspectors' and the inspection scores. We suspect that this negative finding
is due to the facts that all our information on the original inspections was obtained from
reviews of the Management Plans, and many inspection companies use pre-programmed
report outlines and shells for the Management Plans. These outlines and shells tend to cancel
out much of the variation between individual inspectors which, in turn, negates the effects of
their backgrounds.
Process of Notification
• Who has been notified?
m Were these people notified through a letter, meeting, article in a school
newspaper or in another way?
• After notification occurred, did parents review the Management Plan, attend
meetings to discuss asbestos in the school, or respond to notification with any
other action?
• What might parent and staff reactions be to differently worded notification
letters?
The goal of Research Area 5 was to look into parent and teacher reactions to
notification. Through the use of focus groups and interviews with principals, active parents
and active teachers, the topic of notification was studied with remarkably consistent results.
In general, while principals recalled notifying parents about the presence of a Management
Plan, both parents and teachers very often did not recall either being notified or the contents
of the notification. The most common methods of notification used were letters, and in the
focus groups we learned that both parents and teachers believe that this is the most effective
method of notification, particularly if the letters are sent by mail rather than hand-delivered to
parents by students.
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Both the survey and the focus groups showed that parent reactions to
notifications tended to be slight. According to the survey, parents in less than 20 percent of
schools reacted to notification in any way. In the focus groups, almost no one recalled
reacting to notification, and only a handful of participants predicted that they would react to
any of the model notifications presented to them. Among those who did react, or predict that
they would react, both in the survey and focus groups, the range of actions was very small, and
included only such activities as reviewing the Management Plan, calling the AHERA
designated person for additional information, and requesting that a discussion of asbestos be
added to a meeting agenda.
Through the use of focus groups we also explored preferences for types of
notifications. Both parents and teachers were eager for a much more thorough level of
notification than they have experienced to date. In specific, they wanted a school-based
notification mailed to each parent. They wanted this letter to contain the name and telephone
number of the ADP, and a description of any planned response actions and the associated
timetable, and brief but informative health risk information.
Maintenance and Custodial Workers Training and Experience
• Are maintenance and custodial workers trained to work with and around
asbestos?
• What topics were included in this training?
• What tasks relative to asbestos or suspect ACM are regularly required of
maintenance and custodial workers, and do these tasks correspond to the level
of training received?
This research area responded to questions involving maintenance and custodial
workers' training and responsibilities in the wake of AHERA. AHERA designated persons
(ADPs) were interviewed regarding the training of workers in their schools. They reported
that 87 percent (±9%) of maintenance workers and 95 percent (±6%) of custodians were
trained by schools. They also report 74 percent (±5%) of maintenance workers trained were
trained for less than the 16 hours called for by AHERA for workers who work around or
disturb ACBM. By contrast, only 5 percent (±6%) of custodians were trained for less than
the two hours required by AHERA for basic awareness. However, of the custodians who
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work around or disturb ACBM, 83 percent (±8%) have received less than 16 hours of
training.
The perspective of the ADP on training was more favorable than what we found
in our interviews with maintenance workers and custodians in focus groups. In general, ADPs
presented a picture of training promptly given, though frequently shorter than AHERA
stipulates for staff who work directly with asbestos. ADPs also presented a picture of training
that included extensive and often multiple presentation of the locations of ACBM.
By contrast, several participants in the focus groups did not remember being
trained, or if they did, felt that it was no more than "showing a video." Many of the untrained
workers, as well as some of the trained workers also expressed concern about not knowing
where ACBM was located in their schools, or how to handle it properly.
The final questions in this research area related to tasks for which maintenance
workers and custodians are responsible around ACBM. The focus group findings in this area
showed that frequent, unprotected, and inappropriate work practices are being used by both
maintenance workers and custodians in schools in the five communities in which focus groups
were held. On the whole, these inappropriate work practices were performed to clean up
fiber release episodes of less than 3 linear or square feet, or as routine maintenance/custodial
activities. Because the workers were unsure if material contains asbestos, because of
inadequate training or no training, or because of pressure to act immediately in a
maintenance "emergency" situation (such as a pipe leak), exposure to asbestos is occurring
and appropriate procedures are being followed in only a few cases. Most workers did not
express concern that they might be disturbing asbestos and creating a health hazard when they
removed suspended ceiling tiles or brushed against insulated pipes. ACBM was seen as being
disturbed only when it was sawed, cut, or in some other way visibly damaged.
All of the focus group participants who were custodians reported that respirators
were unavailable to them, while maintenance workers often reported that respirators were
available only on a shared basis. Even when available, respirators are rarely used.
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1. INTRODUCTION
1.1 Background
In February 1988 the U.S. Environmental Protection Agency (EPA) published
Asbestos-Containing Materials in Public Buildings. A Report to Congress. As a result of this
report and the issues it raised, the EPA promised Congress to perform an evaluation of the
effectiveness of the Asbestos Hazard Emergency Response Act (AHERA) - that is, the reduction
of potential for exposure by the implementation of several of AHERA's important elements. The
EPA also promised to report on their findings by Spring 1991.
The Asbestos Hazard Emergency Response Act (AHERA) was signed into law on
October 22, 1986. AHERA required the EPA to establish a comprehensive regulatory structure
for inspection, management planning, operations and maintenance activities, and appropriate
abatement responses to control asbestos-containing materials in schools. The AHERA Asbestos-
Containing Materials in Schools Rule requires Local Education Agencies (LEAs) such as school
districts for public schools, and dioceses for Catholic schools, to: (1) use specially-trained and
certified asbestos inspectors to identify asbestos-containing materials; (2) develop asbestos
Management Plans; (3) design and conduct major activities to control asbestos; and (4) make
Management Plans available to all concerned persons and submit them to state governors.
The ultimate measure of AHERA's effectiveness is the degree to which it reduces
exposure to asbestos and thus the incidence of asbestos-related diseases in school populations.
However, the use of this measure implies the need for a long-term epidemiological study. Instead,
the EPA determined that this evaluation would focus on the degree to which most of the key
aspects of AHERA were properly implemented and the key factors which affect implementation.
The Economic and Technology Division (ETD) of the EPA's Office of Toxic
Substances (OTS) AHERA Evaluation workgroup provided project oversight. Westat, Inc.
designed and conducted the project.
The research was divided into nine tasks: (1) School Screening and Sample Selection,
(2) AHERA Designated Person (ADP) Interviews, (3) Reinspection of Schools, (4) Principal
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Interviews, (5) Management Plan Evaluation, (6) Parent and Teacher Notification Survey,
(7) Original Inspector Survey, (8) Parent and Teacher Notification Focus Groups, and
(9) Maintenance and Custodial Workers Focus Groups. Westat designed the specifics of these
tasks, including selecting the sample frames; designing instruments; conducting the reinspections,
focus groups, and surveys; analyzing the results; and writing this final report on the findings.
12 Description of AHERA
The Asbestos Hazard Emergency Response Act (AHERA, Public Law 99-519) was
signed into law on October 22, 1986. The law required the EPA to promulgate regulations to
address all aspects of asbestos-containing building materials (ACBM) in schools. The EPA
published two regulations in response to the mandate. The first (April 1987) was the Model
Accreditation Plan (40 CFR Part 763, Appendix C to Subpart E). The second regulation (October
1987) was the Asbestos-Containing Materials in Schools Rule (40 CFR Part 763 Subpart E).
The first step a LEA must undertake in complying with the AHERA regulations is to
have a thorough inspection of each school building performed by an EPA-accredited inspector.
During the inspection, all areas of the building are visually examined to identify suspect ACBM.
Each distinct homogeneous area of suspect ACBM (material determined to be of the same type
and age and uniform in color and texture) is either assumed to be asbestos-containing material
(ACM), or random bulk samples of the material are collected to determine asbestos content by
laboratory analysis. Each homogeneous area of suspect ACBM is described, at a minimum, by
material type, quantity, and location(s) within the building.
If the homogeneous area is ACBM, (either assumed or determined by laboratory
analysis) the inspector must further determine whether the material is friable. A friable material
may be crushed, pulverized, or otherwise reduced to powder by hand pressure. If the material is
friable, the inspector must assess both the actual and potential damage to the material. The
inspector must date and sign the inspection report, thus taking personal responsibility for the
information contained therein.
AHERA requires that a Management Plan contain, among other things, a report of
the inspection to be developed by an EPA-accredited Management Planner. The Plan must include
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an inventory of each building at the school, the information generated by the inspection for each
building, laboratory analysis results, and recommendations for response actions for each friable
ACBM by functional space.1 AHERA also requires an evaluation of resources needed and a
schedule to carry out the response actions and other asbestos activities in the school. Submission
of the Management Plan to the state governor's office, and filing all documents related to asbestos
activities in the Management Plan, are also required. Several activity plans must be described in
the Management Plan. These include an Operations and Maintenance (O&M) Plan for working
with friable asbestos materials, a plan for periodic surveillance of the ACBM at least every 6
months and for reinspection of the ACBM at least every 3 years, a plan for notification of parents
and staff about asbestos activities, and a plan for initial and periodic cleaning of areas where
friable ACBM is present. The Plan must also identify the person assigned by the LEA to ensure
that the requirements of AHERA are properly implemented (the AHERA designated person or
ADP). Both the management planner and the ADP sign the Management Plan, thus taking
responsibility for their respective roles.
AHERA lists response actions which must be performed depending on ACBM type
and condition. Appropriate response actions include placing the material in an O&M Plan,
repairing damage to the material, encapsulating or enclosing the material, or removing the
material. AHERA specifies the procedures for performing response actions. These procedures
include training and accreditation of workers, reference to proper work practices, and detailed
methodology for collecting air samples as the clearance criteria for labeling a response action
complete. In addition, a schedule for gradually introducing transmission electron microscopy as
the method for clearance air monitoring is provided.
A unique feature of AHERA is the requirement that workers and building occupants,
or their legal guardians, be notified at least once each school year about the availability of the
Management Plan and other asbestos activities. These other activities include response actions
and periodic reinspections that are planned or in progress. The regulation is not specific about
how notification is to be made. Written or verbal notification to either individuals or groups is
usually considered acceptable.
Functional space is defined as a room or group of rooms designated by the management planner for purposes of response actions as one
space.
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The AHERA regulations recognize that maintenance and custodial workers in a
building perform a variety of tasks which may impact asbestos in a variety of ways. Therefore,
training of these workers is defined for two categories, based on the likelihood their work will
disturb ACBM. A two-hour training is required for all workers in a building containing ACBM,
whether or not they work directly with it. An additional 14 hours of training is required for all
workers who conduct activities that will result in the disturbance of asbestos. Short-term workers
in a building must be informed about the locations of ACBM.
Additional items discussed in the regulations include placing of asbestos warning
labels adjacent to friable asbestos materials in maintenance areas, and enforcement guidelines.
Exclusions, methods by which various otherwise required elements may be deleted, are also
described by AHERA. For example, bulk sampling may be waived if previous sampling is
determined by the accredited inspector to have been performed in substantial compliance with the
regulation.
13 Study Tasks
Nine study tasks were developed to provide the data needed to fulfill the study
objectives. These tasks were:
Task 1: School screening and sample selection
• A sample of AHERA designated persons representing a total of 1,400 schools
nationwide were called to determine school and building eligibility for the
study.
• A sample of buildings within eligible schools was selected systematically,
including primary and backup buildings.
Task 2: AHERA designated person interviews verifying building eligibility for the
evaluation
• Two interviews were conducted in person with the ADP for each school in the
sample. One determined training provided to school maintenance and
custodial staff and the other collected a copy of the school's Management Plan.
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Task 3: Reinspection of schools
• Field teams conducted reinspections of selected buildings within sampled
schools in order to collect data to later compare to the original AHERA
inspection.
Task 4: Principal interview
• The principal of each school in the sample was interviewed in person to learn
about the methods used for notifying parents of the presence of a Management
Plan at the school.
Task 5: Management Plan evaluation
• A Management Plan evaluation was conducted for each school in the sample.
This task compared the findings of the reinspection and original AHERA
inspection, and evaluated the completeness and usability of each school's
Management Plan.
Task 6: Parent and teacher notification survey
• A telephone survey of one active parent and one active teacher for each school
in our sample was conducted to learn about methods used for notifying parents
and teachers of the presence of a Management Plan at the school.
Task 7: Original inspector survey
• Telephone interviews with inspectors responsible for the original AHERA
inspections of schools in our sample were conducted to determine inspector
qualifications and background at the time of the original AHERA inspection.
Task 8: Parent and teacher notification focus groups
• Focus groups were conducted in four locations nationwide with parents and
teachers not associated with the schools in our sample. Groups discussed
potential reactions to different styles of notifications.
Task 9: Maintenance and custodial workers focus groups
• Focus groups were conducted in five locations nationwide with maintenance
and custodial personnel not associated with the schools in our sample. Groups
discussed maintenance and custodial worker training and tasks regularly
performed in schools.
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Further description of each of these tasks is found in Chapter 2 of this report.
1.4 Research Areas and Design
A multifaceted research design was developed to conduct the nine separate research
tasks for this project. A total of 16 forms for data collection, abstracting, interviewing and
conducting building reinspections were developed and used. These forms included two in-person
questionnaires, three telephone questionnaires, one building reinspection form, and two separate
Management Plan abstracting forms for each school.
Six research areas were investigated, and the quantitative data required to address
these research areas were collected in a statistical national survey of schools and school buildings.
The building sample was a multi-stage stratified cluster sample in which 30 Primary Sampling
Units (PSUs), 200 schools within PSUs, and 210 buildings within the schools were selected. A PSU
is a geographic area, usually a county or group of counties, defined by the Census Bureau for
survey sampling purposes. Of these, 198 schools and 207 buildings in schools were successfully
included in the study.
Schools were considered eligible for inclusion in the study if classes in any of grades 1
through 12 were taught, the school had a Management Plan, and the school had at least one
eligible building. Buildings were considered eligible if they were built before October 1988 and
had been inspected for asbestos-containing materials since December 1987, if the original AHERA
inspection discovered some ACBM or suspect-assumed ACBM, and if students in any of grades 1
and 12 were in the buildings on a regularly scheduled basis during the 1989-1990 school year.
In total, the sample represents 83,840 of the estimated .106,032 schools nationwide and
as such, represents approximately 80 percent of schools nationally.
The research design for the six research areas and the basic questions to be answered
in each are presented on the following pages. These research areas 'and the questions to be
answered were developed primarily by the EPA in consultation with Westat and the technical
consultants used by this project. These technical consultants included James August; William
Ewing of the Environmental Management Group; Steven Hays of Gobbell Hays Partners Inc.;
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Dale Keyes of Environmental Sciences, Inc.; and David Mayer of Law Associates, Inc. (formerly
with Georgia Technical Research Institute).
Research Area 1: School Building Reinspection
Questions:
• Was all the suspect material found at the original AHERA inspection?
• Was the asbestos found at the original AHERA inspection properly assessed?
Method:
Using information collected during the ADP interview and school reinspection (Tasks
2 and 3), each building in the study was given a thorough reinspection for suspect materials, that is,
building materials suspected of containing asbestos. During the reinspection the type, location,
amount of material, and condition of the material were recorded. Bulk samples of suspect
material were not taken.
Management Plans were reviewed for all schools in the study as part of the
Management Plan evaluation. Each Plan was reviewed (based on the data collected during the
reinspection of schools [Task 3]) by experienced Management Plan reviewers who compared the
findings of the original AHERA inspection and the reinspection on a material-by-material basis.
The results of this comparison allowed us to determine when the findings of the two inspections
differed significantly, and to determine potential reasons for these differences.
Research Area 2: Management Plan Evaluation
Question:
• Do schools know and understand the regulation, as shown by the completeness
of the Management Plan and degree to which the Management Plan has been
kept up to date?
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Method:
Management Plans for each school were reviewed and evaluated for completeness
and usability, as were specific components of each Management Plan, such as notifications
(Task 5). Completeness was evaluated using a checklist adapted from the EPA Key Elements
Checklist (See Appendix G) utilized by many states. Usability was evaluated in terms of what level
of education or knowledge a person was considered to need in order to understand and use the
Management Plan.
Research Area 3: Response Action Evaluation
Questions:
• What response actions were recommended in the Management Plan?
• Are they appropriate, given the assessed condition of the asbestos?
• Have the response actions undertaken in the school been done properly?
Method:
The first two research questions were answered by reviewing Management Plans to
determine the types of response actions recommended (Task 5). These recommended response
actions were reviewed to determine whether they were appropriate given the findings of the
original AHERA inspection, whether they were specific to the material or generic, and whether
they met or exceeded the AHERA standards. The third research question was answered via direct
evaluation of completed response actions observed during the reinspection of schools (Task 3).
Response actions were visually evaluated during the reinspection (no air sampling was performed).
Research Area 4: Original AHERA Inspection Evaluation
Question:
• Given the quality of the original AHERA inspection, as shown by a comparison
between the reinspection findings and the findings presented in the
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Management Plan, what is the importance of the original AHERA inspector's
training, experience and background in inspection quality?
Method:
The original AHERA inspectors for the schools in our sample were interviewed by
telephone (Task 7) to determine their training experience and background at the time they
conducted the original AHERA inspection in the sample schools. These characteristics were then
compared with the results of the original AHERA inspection, using data gathered as part of the
Management Plan evaluation (Task 5). Each inspection was assigned a numerical score based on
the inspector's performance on six key elements of the inspection. Analyses were conducted of the
association between the inspection score and dimensions of the inspector's background.
Research Area 5: Process of Notification
Questions:
• Who has been notified?
• Were these people notified through a letter, meeting, article in a school
newspaper or in another way?
• After notification occurred, did parents review the Management Plan, attend
meetings to discuss asbestos in the school, or respond to notification with any
other action?
• What might parent and teacher reactions be to differently worded notification
letters?
Method:
The first three research questions above were addressed during an interview with
each school's principal (Task 4) about the notification of parents which they had undertaken. In
addition, Westat conducted interviews with parents and teachers (Task 7) about their recollections
of being notified.
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The final research question was conducted through in-depth discussions in focus
groups with parents and teachers from schools outside our sample (Task 8). These parents and
teachers were questioned about their reactions to various types of notification letters.
Research Area 6: Maintenance and Custodial Workers Training and Experience
Questions:
• Are maintenance and custodial workers trained to work with and around
asbestos?
• What topics were included in this training?
• What tasks relative to asbestos or suspect ACM are regularly required of
maintenance and custodial workers, and do these tasks correspond to the level
of training received?
Method:
Two study approaches were used in this research area. The first approach was
interviews with each school's ADP (Task 2). These interviews covered the type of training given to
maintenance and custodial personnel, the duration of this training, and the topics covered. The
second involved focus groups with maintenance and custodial personnel at schools other than
those in our sample (Task 9). In addition to discussing the types of training received by
maintenance and custodial staff, these groups discussed the types of work around asbestos that the
workers are asked to undertake.
1.5 Final Report
This final report presents data addressing the six research areas outlined on the
preceding pages. The report contains descriptive statistics projected to the U.S. as a whole for the
aspects of the research areas that collected quantitative data. The qualitative aspects of the
research areas are presented both by generalizing the data to the national level and by reporting
the findings of each group, as is common for focus group reports.
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Chapter 2 of this final report presents an overview of the methodology for the study.
Chapters 3 through 9 present a summary of the Research Areas. These chapters are organized as
follows:
• School Building Reinspection (Chapter 3);
• Management Plan Evaluation (Chapter 4);
• Response Action Evaluation (Chapter 5);
• Original AHERA Inspection Evaluation (Chapter 6);
• Process of Notification (Chapter 7);
• Maintenance and Custodial Workers Training and Experience (Chapter 8); and
• Additional Research Findings (Chapter 9).
Within the chapter devoted to each Research Area, the text is organized by research
question. Selected data required to address each research question are presented within the
chapter, while tables summarizing all data collected are presented in Appendix J. Some exhibits
are also presented in these chapters, as needed, to highlight specific findings and address the
study's research questions. The basic analysis tables and data plots are not included with this
report.
Chapter 10 outlines the statistical properties of the sample, including sampling error
(confidence intervals) and nonsampling error (especially non-response bias). The appendices
present the training materials for the field effort, the training materials for the telephone
questionnaires used for this study, the data collection forms, and information on the coefficient of
variation and confidence intervals for quantitative data collected.
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2. METHODOLOGY OVERVIEW
Chapter 2 presents the methodology for sample selection of the buildings within
schools which were the primary sample for the AHERA Evaluation Study. Protocols for
conducting the building reinspection reinspections are presented to provide the background
necessary to understand the complexity of the reinspection procedures. Then, beginning with the
early efforts of this study and continuing to implementation, the pretest, the contact with the Local
Education Agencies, and the field data collection effort are discussed on a task-by-task basis. The
Management Plan evaluation aspects of this study are presented and include the original inspector
evaluation effort. Finally, the telephone interviews with parents and staff and with original
inspectors are discussed, as are the notification and maintenance/custodial workers focus groups.
2.1 Sampling Methodology for the AHERA Building Sample
The building sample for the AHERA study was selected in several stages, which are
summarized here. For a more detailed statistical description of how the buildings were selected,
see Appendix Z.
First, 30 primary sampling units (PSUs) were selected from a list of all the PSUs in
the continental United States. A PSU is a limited geographic area (often a county or cluster of
counties), and can usually be covered by a field interviewer in one day. The PSU boundaries for
the AHERA evaluation were based on those used by the U.S. Department of Census.
Next, a screening sample of 1,041 schools was chosen from the schools in the 30
selected PSUs. The schools included at this stage were the public, private, and Catholic schools on
the 1988 QED file (Quality Education Data, Inc., Denver, Colorado).
Then, a primary sample of 200 schools was selected from those schools that were
eligible for the AHERA evaluation after screening. Eligible schools are those which have students
in some of grades 1 through 12, have a Management Plan, and have at least one eligible building as
described below. The schools were sampled at different rates in each PSU in order to control the
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workload in each PSU. Replacement schools were used when schools in the primary sample did
not participate.
Finally, 207 buildings were selected from the eligible buildings in the 198 schools that
agreed to participate. An eligible building had students in any of grades of 1 through 12, and had a
Management Plan. In 198 of these schools, one building was selected, and in 9 of them two
buildings were selected. No more than two buildings were selected from any one school since the
number of inspections that could be performed was limited and both building-level and school-
level statistics were desired.
22 Building Inspection Protocols
22.1 Definition of a Building
One of the first questions to be answered when conducting any survey of buildings is,
'What definition of a building will be used?' For this study, we have defined a single building as a
separate structure. Two structures sharing an interior wall are considered one building, even
though they may have been constructed at different times or are considered to be more than one
building by the school. Two structures connected only by an above-ground (covered or uncovered)
or underground walkway are considered two buildings, even if the school considers them to be one
building. In addition, in cases where the school shares an interior wall with a non-school "building"
(e.g., a community center or public library), only the school portion of the building was to be
inspected.
This definition of a building was used throughout the study and was found to facilitate
statistical analysis. It is important to note, however, that due to definitional differences, in many
cases the number of buildings we found at a school was different from the number the district, and
even the school, said that it had. In one notable case, the district defined a school as having one
building, despite the fact that 14 temporary buildings and two permanent structures were present.
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222 Materials Included
In order to design the inspection protocols for the study, Westat had to decide about
materials and areas to be included and excluded from the study. The list of materials included is
presented in Exhibit 2-1. All materials in Exhibit 2-1 are considered to be able to be identified in
any complete AHERA inspection. The Type" column in Exhibit 2-1 lists materials for which study
inspectors were specifically trained to inspect. An "Other" type listing was provided on data
collection forms in the event the inspectors found a material not on the list, but also not excluded
from the study. The "Data aggregates" column shows how the field data were combined for
statistical analysis. For example, interior and exterior duct insulation were combined as "duct."
When duct is mentioned in the analytical chapters, it refers to both interior and exterior duct
insulation.
223 Excluded Materials and Areas
In general, all materials included in AHERA were included in the study. Three types
of materials were excluded from the evaluation. They include those materials that never contain
asbestos or so infrequently do that the large effort needed to assess them would provide little
information to the study; those materials not addressed clearly by AHERA; and a few small
quantity materials which would be difficult to assess. The list of materials excluded from the study
is presented in Exhibit 2-2. This list of materials was reviewed and approved by consultants who
work on this project.
All areas within a building were inspected except those that were either inaccessible
(e.g., a key to a storage closet was unavailable) or considered by the inspector to be unsafe to
enter. Explicitly included in the study were crawlspaces, rooftop, mechanical areas, boiler rooms
and attics, where accessible. Exhibit 2-3 shows how areas were classified for the study.
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Exhibit 2-1. Material types included in the AHERA evaluation
Thermal system insulation
Surfacing materials
Miscellaneous materials
Type
Data aggregates
Type
Data aggregates
Type
Data aggregates
Breeching
Boiler
Chiller
Duct - exterior
Duct - interior
Elbow
Fitting
Pipe
Tank
Tee
Valve
Other (SPECIFY)
Breeching
Boiler
Duct - interior/exterior
Elbow/Fitting/Value/Tee
Pipe
Tank
Other: Chiller
Ceiling material - hard and
granular/cementitious
Ceiling material - fluffy
Ceiling material - soft and
granular
Ceiling material - textured
paint or popcorn
Fireproofing - hard and
granular/cementitious
Fireproofing - fluffy
Fireproofing - soft and ,
granular
Wall coating - hard and
granular/cementitious or
stuccoed
Wall coating - fluffy
Wall coating - soft and
granular
Wall coating - textured paint
or popcorn
Other (SPECIFY)
Ceiling material
Fireproofing
Wall coating/Other
Acoustical wall tile
Ceiling tile - glue on
Ceiling tile - lay in
Ceiling tile - spline
Cooling tower slats
Fire doors
Floortile-9-x9",l'xl'
Fume hood sheeting
Linoleum or solid
floor covering
Patch
Radiator board
Rope insulation
Transite -ducts
Transite - panels
Transite - water
pipe (interior)
Vibration dampening
cloth on ducts
Other (SPECIFY)
Acoustical wall tile
Fire doors
VDC
Floor Tile-9" x 9", 1'xl'
Transite - ducts, panes,
& pipe
Ceiling tile - glue on,
lay in, & spline
Other: Cooling tower
Slats
Fume hood
sheeting
Patch
Radiator board
Rope insulation
Other
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Exhibit 2-2. Material types excluded from the AHERA evaluation
MATERIALS SPECIFICALLY EXCLUDED BY AHERA
Auditorium curtains
Brake shoes
Bunsen burner pads
Carpet
Chalkboards
Cinder blocks
Concrete blocks
Cork materials
Fiberglass materials
Fire blankets
Foamglass materials
Glass materials
Kiln bricks
Laboratory gloves
Laboratory tabletops
Metal materials
Plastic materials
Roofing materials, exterior
Rubber materials
Stored materials
Styrofoam materials
Structural concrete
Tectum-board
Wood materials
EXCLUDED FROM STUDY FOR OTHER REASONS (SEE TEXT)
Adhesives (other than with floor tile)
Caulking
Electrical wire insulation
Fire brick for boilers
Flooring under wall-to-wall carpeting
Gaskets
Hard plaster walls
Light socket collars
Masonite materials
Paint, smooth
Sheetrock/drywall
Terrazzo flooring
Vinyl wallpaper
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Exhibit 2-3. Area classification for the AHERA evaluation
EXTERIOR AREAS
Portico
Covered connecting walkway
GENERAL ACCESS
Auditorium (fixed chairs)
Classroom (includes closet)
Classroom group (classroom &
one or more of bathroom
& office)
Dining room (cafeteria)
Gymnasium
Gymnasium equipment room
Hallway, interior
Laboratory
Library/Media center
Lobby/Entryway
Locker room
Multipurpose room (2 or more
of cafeteria, gym, assembly)
Restroom
Stage
Stairway
Swimming pool
Weight/Exercise room
MECHANICAL AREAS
Air and duct shaft
Air handling units
Air plenum
Boiler room
Crawl space
Elevator shaft or equipment
Mechanical room
Pipe shaft
Rooftop HVAC unit
Space above dropped ceiling
(non-air plenum)
Telephone and electrical
LIMITED ACCESS
Dormitory bedroom
Garage, underground
Janitor's closet
Kitchen
Office
Storage/Supply room
Teachers' lunch room
Teachers' lounge
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22.4 Bulk Sampling
The decision was made by EPA not to perform bulk sampling as part of this study.
Early in the project there was considerable discussion about the desirability of
collecting and analyzing bulk samples of suspect material during the building reinspection
inspections. This discussion recognized that the only way to determine that suspect material is
ACM is through bulk sampling, but questioned the importance of this determination given the
research questions to be answered by the study. The discussion also focused on the additional
costs associated with bulk sampling. These costs included ont only the costs of laboratory analyses,
but also the cost of greater inspector time spent on each inspection, and the costs of inspecting
schools only when students and other building users were not present and possible loss of school
response if bulk samples had to be collected.
The National Institute of Science and Technology has established a proficiency
program through the National Voluntary Laboratory Accreditation Program (NVLAP) for
laboratories which perform bulk sample analysis by polarized light microscopy (PLM). Data from
this program could provide an estimate of sample analysis error, if desired.
Research Area 1, which studied School Reinspection, asked the following two
questions: (1) "Was all the suspect material found at the original AHERA inspection?" and (2)
"Was the asbestos found at the original AHERA inspection properly categorized?" Neither of
these questions required data that could be gathered through bulk sampling: Question (1)
addressed all materials, regardless of asbestos content and Question (2) depended on original bulk
sample results. Rather each of these questions required a large sample size to decrease the size of
confidence intervals for projections for all other parts of the study.
Another factor in the decision not to bulk sample was that AHERA was primarily
interested in suspect material, and the presence of asbestos in the suspect material did not affect
the quality of an inspection.
Despite the fact bulk samples were not collected, the study was able to determine the
percent of suspect asbestos-containing material missed by the original AHERA inspections. Detail
on the method of estimation and results of this analysis are presented in Chapter 3 of this report.
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2.2.5 Field Procedures
The specific field procedures followed for the evaluation are described in the
following sections. Exhibit 2-4 will be helpful in understanding these procedures. This Flow Chart
of Field Procedures shows which data collection forms were used each step of the field process.
2 J Pretest of Data Collection Procedures and Forms
After preliminary development of the forms for this study, three Local Educational
Agencies (LEAs) in the Washington, D.C. metropolitan area were selected to participate in the
screening pretest. The pretest screening questionnaire was administered to three LEAs to obtain
information on 14 schools, 10 public and 4 Catholic, representing 7 elementary schools, 3 middle
schools and 4 high schools. Of these 14, 11 were urban/suburban and 3 were rural. The
procedures for contacting the LEAs were the same for the pretest as for the actual field study, as
described in Section 2.4 of this report.
After the screening questionnaire had been administered, and school and building
eligibility were determined, a total of four schools were included in the field portion of the pretest.
Three schools were public and one was Catholic, while two were elementary schools and two were
middle schools. One school was in a rural area while the remainder were in suburban or urban
communities. Again, procedures for contacting the LEAs and schools were the same for the
pretest as for the actual field study. For each of these schools the following field steps were
undertaken:
The ADP was interviewed to verify school and building eligibility. The school's
Management Plan was also collected at this point (Form Al). Questions about
school practices for training maintenance workers were added to this form after
the pretest.
The ADP was interviewed about the maintenance and construction history of
the building selected for inclusion in the reinspection for the pretest (Form
A2).
The school's principal was interviewed about the types of notifications given to
parents (Form PI).
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Exhibit 2-4. Flow chart of field procedures
Doaloatad Ponaa latarvlm. for* At. Collect* Maaafcawat
Plaai Collect Information Concerning Operation! and Maintenance. Balldlac
lafaraatlt*. Fan A2. (Intenrlewar). aik Kty Outitloni about lulldloi Con-
traction. Hlcnllfat Mac inert Rtaovatlont and XtBtdlatloa >a> perforate*1.
Tta
iaamiatlaa
rill IB Flrtt Half or Uraawa* «•«!•• A»a«a»»m. Fora •!. CIat*rvl«nr>
School 10 for Roam. (Hart Room* with Rttioatt action on Mai)
PrlMlMl I*tor*l*w. Fora Pt. (Int*r»l*nr). Coadrat Scrtniar. aim
notification ouoitlont.
Ana IdaMif IcatlM. Fora K. far taca room (Teaai). Ol«*« Vtttat
to tack arta. dttirmlntt If iv*M
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• A building reinspection to inspect for suspect asbestos-containing material
(Forms II, W2 and W3) and to inspect for different types of response actions
(Form Wl) was conducted in selected rooms throughout the school. A sample
of rooms in each school were inspected to minimize costs of these pretest
inspections.
The findings of the pretest were used to improve the various questionnaires and data
collection forms, to improve field procedures, and to determine the type of training materials
required to instruct interviewers and inspectors in the field procedures.
After the data were collected and preliminarily analyzed, a report was sent to each
pretest ADP and school principal to inform him or her of the locations of all suspect asbestos-
containing materials located during the reinspection of the school.
2.4 Contacting the Local Education Agencies and Schools
2.4.1 School Eligibility and Sample Selection - Task 1
A letter was written to each Local Educational Agency (LEA) responsible for one or
more schools in the sample to be used for screening purposes. This screening of sample consisted
of 1,041 schools in 30 PSUs nationwide. This was the first contact with the LEA. The letter was
addressed to the superintendent in the case of public or Catholic schools, and the principal in the
case of private schools. Attached to the letter was a request from Mr. Charles Elkins of EPA's
Office of Toxic Substances encouraging schools to participate. The letter was addressed simply to
Superintendent as EPA was not informed who participated in the study. A copy of both letters was
also sent to the AHERA designated person (ADP) for each school system. (Sample initial LEA
contact letters are presented as Appendix H).
Approximately two weeks after these letters were mailed, trained Westat telephone
interviewers called each LEA and requested to speak with the person in charge of the district's
asbestos program. When that person was located, he/she was asked his/her name, and screening
questionnaire was administered to determine school and building eligibility for inclusion in the
study. A copy of this data collection instrument is presented in Appendix A, and the training
manual used to instruct telephone interviewers on how the screening questionnaire was to be
administered is presented in Appendix C.
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It is important to note that this questionnaire was administered on a school-by-school
basis. This means that some ADPs were requested to answer the questionnaire for each of the
different schools in their district that were in our screening sample.
The screening questionnaire was designed to determine not only school eligibility but
also building eligibility for inclusion in the study. At the school level, eligibility was determined by
positive answers to the following questions:
• Does the school currently have classes in any of grades 1-12?
• Does this school have an asbestos Management Plan?
At the building level, after the ADP was asked to list all of the buildings on the school
campus, positive responses to the following questions determined building eligibility:
• Was this building built before October 1988?1
• Has this building been inspected for asbestos since December of 1987?2
• Did the inspection discover asbestos-containing materials or suspect ACM in
this building?
• Are there students in this building on a regular basis?
In addition, the ADP was asked the following questions about each building:
• What is the size of this building?
• Since December 1987, was removal, enclosure, or encapsulation of asbestos-
containing material performed on three or more linear feet or three or more
square feet of material in this building?
The answers to these questions were used in sample selection as described in
Appendix K.
* AHERA allows buildings built after October 12, 1988 to be excluded from inspection if an architect, project engineer, or accredited
inspector signs a statement that no ACBM was specified as a building material in any construction document or to the best of their
knowledge, no ACBM was used as a building material.
AHERA became effective in December 14,1987, so any inspection after that date is assumed to be in response to AHERA.
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2.42 Scheduling Interviews and Inspections
After the screener data were collected, key entered and cleaned, the primary sample
of 200 schools was drawn. A letter from Westat was written to the ADPs of the selected schools,
informing them that specified schools in their district had been selected for inclusion in the study.
(See Appendix L.)
Each ADP was then called and asked to participate in the study, and an appointment
was made for the Westat field team to visit the ADP. The ADP was then given the choice of either
contacting the principals of the schools to schedule the building reinspection and principal
appointment, or letting Westat make this contact. In either case a letter from Westat and a letter
from Mr. Elkins of the Office of Toxic Substances was sent to the principal informing him or her
about the study, and requesting the school's participation (see Appendix L).
Thirteen field teams, each composed of a Westat interviewer and an EPA accredited
expert3 asbestos inspector, traveled to 30 PSUs during a 10-week field period. Prior to the field
period, Westat conducted a three and one-half day training session in Rockville, Maryland
designed to familiarize the teams thoroughly with the purpose of the study, the field procedures,
and the data collection forms. A copy of the field training manual is contained in Appendix B.
The appointments were scheduled during three waves, each wave spanning
approximately three weeks. Table 2-1 provides further detail on the effort during each wave.
2.5 Field Data Collection
The field data collection effort for the AHERA evaluation Study was carried out
within a three-month period and involved travel to 30 PSUs as described earlier. During this
effort, interviews were conducted with ADPs and school principals, Management Plans were
collected, and building reinspections were performed. This section presents the methodology used
All inspectors used for this evaluation meet or exceed the criteria set forth in the National Asbestos Council's March 1989 Model Plan
for Reciprocity.
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to complete this effort. A copy of all forms used in the data collection effort are presented in
Appendix A.
Table 2-1. Field effort by wave
Wave
Wave I
WaveH
Wave HI
Total
Number of
field teams
13
12
8
Number of
PSUs visited*
16
20
11
30
ADP
interviews
86
81
31
198
Principal
interviews
84
83
31
198
School
buildings
inspected
90
84
33
207
'Some PSUs were visited during more than one wave.
2.5.1
AHERA Designated Person Interviews • Task 2
The initial in-person meeting with the ADP usually took place in his/her office, close
to the LEA's records of asbestos remediation and inspection findings. In most cases the field team
consisting of the inspector and interviewer were present for this interview. In some cases the
inspector was not present, and the interview was conducted by the interviewer alone.
During this interview, the ADP was asked questions about all the schools selected for
inclusion in the study in his/her district. In some cases, the ADP answered the same questionnaire
several times, once for each selected school.
Form Al: AHERA Designated Person Interview
The AHERA Designated Person Interview was the first of two in-person
questionnaires administered to the ADP. Since this form is a school-based form, one Form Al
was filled out for each school selected within that LEA. All questions on this form were asked by
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the interviewer, and was used to collect three types of information: building eligibility and re-
selection, Management Plans, and maintenance and custodial training.
Building Eligibility and Re-Selection - Every building in every school in the sample
must have had a predetermined chance of inclusion in the sample. For this reason the screening
questionnaire was re-administered to verify the eligibility of each building in each school, and
buildings were reselected for inclusion in the study where eligibility had changed. (See
Appendix Z.)
Management Plans - One of the central tasks for the AHERA evaluation was to
collect Management Plans for each school in the sample. A Management Plan is a document
prepared in response to AHERA that presents the findings of the AHERA inspection for
asbestos-containing materials, an outline of recommended response actions for the school, and
other asbestos-related information. For purposes of this study, a copy of the Management Plan
was requested with emphasis on obtaining at least five key elements of each school's Management
Plan. These elements are: (1) the building inspector's report, (2) response action
recommendations, (3) the school's Operations and Maintenance Plan (O&M Plan), (4) copies of
notifications, and (5) copies of AHERA clearance air monitoring results for response actions
(where available). The interviewer collected each Management Plan and sealed it in an envelope.
The inspector did not review the Management Plan prior to the reinspection.
Maintenance and Custodial Training - Under AHERA each school is required to
conduct "asbestos awareness" training for custodians and maintenance workers employed at the
school who work around asbestos. Form Al asked questions about this training in order to review
compliance and adequacy of training.
Form A2: Building Information Questionnaire
The Building Information Questionnaire (Form A2) was completed by the interviewer
after completion of Form Al. Form A2 was used to obtain information about the selected
building's construction and asbestos history to help the inspector perform an efficient and
thorough building reinspection.
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If the inspector was present during the interview, he/she was encouraged to ask
followup questions to ensure a good understanding of the mechanical systems in the building and
the building's history. From this form, only questions about building age were key entered as data
to be used possibly for analyses purposes. The remainder of Form A2 was solely intended to
provide building information to the inspector.
Form A2 is a building-based form, and one Form A2 was filled out for each building,
with two A2 forms completed in schools for which two buildings were sampled. Form A2 was used
to collect information about the building's layout and building systems.
The Master Floorplan - A floorplan of the selected building was obtained from the
ADP. This floorplan was then marked to show the building's construction dates and asbestos
remediation history. This Master floorplan was used throughout the building reinspection to
record area IDs and other information discovered during the reinspection.
Form Wl: Response Action Assessment
Form Wl was used by the interviewer to record response actions taken by the school
as reported by the ADP. Only the first half of the form was completed during the ADP interview;
the remainder was completed during the reinspection.
Form Wl is an area-based form; one Form Wl was filled in for each area where
response actions were reported or observed. During the ADP interview, Form Wl was used to
collect three kinds of information:
Room Name or Number - The interviewer recorded the room name or number where
a response action occurred, as reported by the ADP.
Respondent - During the ADP interview, the interviewer noted the respondent,
usually the ADP, who provided information regarding the location of a response action.
Description of Material and Response Action - The interviewer recorded the ADP's
description of the asbestos material and the response action taken.
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The remainder of Form Wl was completed during the reinspection and is described
further in the following section (2.5.2).
2JS2 Reinspection of Schools - Task 3
The building reinspection was one of the central field research activities of this
project. Both the interviewer and inspector participated in the reinspection, with the interviewer
recording the information on the three "W (reinspection) forms, and the inspector recording the
information on the two "P (inspector) forms.
In most cases the reinspection began in the boiler room and proceeded from lower
floors to upper floors. Crawlspaces were inspected last. If particular conditions at a school made
an alternative starting point in the building preferable, this was allowed. All areas of the building
were to be inspected, though provisions were made for recording an area as inaccessible when keys
were unavailable, an area was sealed, or otherwise inaccessible, or considered to be unsafe by the
inspector.
FormW2: Area Identification
The Area Identification Form (Form W2), was the first form used during the
inspection (though the first part of Form Wl may have been filled out during the ADP interview).
Form W2 was used to identify uniquely and categorize each area inspected and to record the
number of suspect homogeneous materials present in each area, if any. It also recorded whether
response actions had been taken in the area, thus prompting the interviewer to complete Form
Wl, where required.
Form W2 is a building-based form, meaning that one row of the form was used to
record data on a specific area in a building. In a building with 10 or fewer areas, only one W2 form
was used. An area was generally a distinct room within the building. However, some areas are not
typically thought of as rooms, e.g., hallways, stairwells and closets. One of the purposes of the
building reinspection was to collect data to compare with the original AHERA inspection. As
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different inspectors divided schools up into areas in many different ways, inspecting materials on a
room-by-room basis provided enough detail to allow comparison with the original AHERA
inspection report.
The Area Identification form was used to collect four types of information:
Area IDs - The use of Westat-assigned, sequential ID numbers permitted an
organized comparison of areas from our inspection to those of the original AHERA inspection.
Area Use Code - For this study we used pre-coded area use identifiers to categorize
areas into exterior, interior or mechanical areas and then into sub-areas such as classrooms.
A "No Access" code was provided for cases where the area was locked or otherwise
not accessible (e.g., the area above a dropped ceiling which does not have movable panels).
Number of Suspect Homogeneous Materials - This information was used as a check
by data entry personnel to ensure the correct number of rows were completed on Form W3 for
each area.
Response Actions - This information was used to prompt the interviewer to complete
Form Wl. Several sources of information on response actions were used, including the ADP's
report, inspector observation, and comments of school staff observing the reinspection.
Form W3: Suspect Homogeneous Materials
The Suspect Homogeneous Materials Form (Form W3), was used to record all
suspect homogeneous materials found by the inspector in an area, the quantity of each material,
and the assessment factors used to calculate the AHERA 1-7 category for each material. These 1-
7 categories are specified by AHERA and assess the current and potential damage found in
suspect TSI, surfacing and miscellaneous material in a school. The interviewer was responsible for
completing Form W3 with the assistance of the inspector.
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Form W3 is an area-based form; that means one Form W3 was filled in for each area
where suspect homogeneous materials were found. If no suspect homogeneous materials were
found in an area, no W3 Forms were used for that area. Form W3, the Suspect Homogeneous
Materials Form, was used to record four types of information:
Suspect Homogeneous Material Key Code - This code was generated by the inspector
on Form I1T for TSI, Form IIS for surfacing material, and Form I1M for miscellaneous material
(described below). Each distinct homogeneous material in the area was identified, quantified and
assessed.
Suspect Homogeneous Material Dimensions - Information was collected on the
amount of each suspect material in each area in square or linear feet or inches. Provisions were
made for the team to record dimensions directly in square or linear feet when this was most
convenient, or for area dimensions to be calculated by computer from the recorded length and
width.
Damage - Data on current damage and potential for damage were collected for use in
determining the AHERA 1-7 category for the homogeneous materials in the area. These damage
categories were assigned by computer, based on the answers to questions about friability, current
levels of local and dispersed damage, and potential for damage from sources such as water and
vibration. These categories are:
1. Damaged or significantly damaged thermal system insulation ACM;
2. Damaged friable surfacing ACM;
3. Significantly damaged friable surfacing ACM;
4. Damaged or significantly damaged friable miscellaneous ACM;
5. ACBM with potential for damage;
6. ACBM with potential for significant damage; and
7. Any remaining friable ACBM or friable suspected ACBM.
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Forms II: Suspect Homogeneous Materials Key Codes
There are three Form Us, one for each of the three general AHERA material types:
TSI, surfacing and miscellaneous. They are called Form I1T, IIS and I1M, respectively, and were
used to generate a unique identification number for each suspect homogeneous material found in
a building. These forms were color coded by material type to facilitate finding the appropriate
form.
Form II is a building-based form. The inspector completed one row of the
appropriate form each time a new suspect homogeneous material was found.
This form sought to collect two different types of information about the suspect
asbestos-containing materials in the school:
Materials - Each suspect homogeneous material found was given an identification
code which was unique within the school. This reduced the paperwork associated with completing
the other reinspection forms and speeded data entry.
Material Type - Commonly-found materials were pre-coded. Material types which
have been intentionally excluded from the scope of this study were also listed on these forms. This
saved team members' time which might have been spent assessing materials unnecessarily. (For a
comprehensive list of materials excluded from the study, see the three II Forms in Appendix A or
Exhibit 2-2.)
Form 12: Suspect Homogeneous Materials Calculations
The Suspect Homogeneous Material Calculations Form (Form 12) provides a
calculation space for inspectors to calculate the quantity of a homogeneous material in one area.
The inspector was responsible for recording on this form any field notes taken, though he/she was
not required to fill in the form for a specific material or area. Form 12 is a building-based form;
one row was filled out for a homogeneous material in an area. Information on this form was not
key entered.
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Form Wl: Response Action Assessment
The Response Action Assessment Form (Form Wl) was initially used by the
interviewer during the ADP interview to record reported response actions taken by the school. It
was then completed by the interviewer during the reinspection by recording the inspector's
observations about the quality of the response actions taken, as well as any additional response
actions discovered by the inspector or reported by any other respondent during the reinspection.
This form covers information not normally addressed in an AHERA inspection. Its overall
purpose in the study is to determine if response actions are occurring, what response actions are
occurring, and what the visual quality characteristics of those actions are. For purposes of this
study, response action means that more than three square feet or three linear feet of material were
removed, repaired, enclosed, or encapsulated.
i
Form Wl is an area-based form, and one Form Wl was filled in for each area where
response actions occurred. If no response actions occurred in an area, no Form Wl was used for
that area. Form Wl was used during the reinspection to collect three types of data:
Confirmation of Response Action - Since the initial description of response actions
was obtained away from the school during the ADP interview, we anticipated that there might be
some discrepancies found in the field. This aspect of the form addressed whether the initial
information was correct or able to be verified. If it was not, there is an area for recording the
reason.
Classification of Response Action - The inspector classified the response action into
one of four categories—enclosure, encapsulation, removal or repair. The inspector performed the
classification in accordance with specific definitions for this study, rather than relying on
terminology used by the ADP. The goal was for all types of response actions to be classified
uniformly by all inspectors.
Observations/Quality Factors - Five visually determined factors indicative of quality
factors (lamination, complete barrier, impact resistant, airtight, and material removed) were
observed by the inspector and were intended to evaluate the quality of the response action by
looking at specific characteristics of the response action. The quality factors for enclosure are
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airtight and impact resistant. If the enclosure is not airtight or is not impact resistant, it was not
considered a visually adequate enclosure. The quality factors for encapsulation are lamination and
complete barrier; for repair, lamination and visually airtight; and for removal, only the presence of
the material.
Key definitions used in the field study are found in the AHERA Field Training
Manual in Appendix B.
2.53 Principal Interview - Task 4
Sometime after the ADP meeting, usually the day of the building reinspection, the
school's principal was interviewed by the Westat interviewer. This interview briefly introduced the
AHERA study to the principal and made reference to a letter previously sent. The first questions
verified the school's eligibility for the study. The majority of the remaining questions were about
notifications sent by the school to students' parents regarding asbestos activities performed in the
school. Finally, the form was used to collect names and phone numbers of representatives of
teachers' unions and parents' groups. These representatives were interviewed by telephone in
Task 6, the Parent and Teacher Notification Survey.
Form PI: Principal Interview
Form PI was used primarily to collect information on notifications by the Westat
interviewer from each school's principal.
Notification • Notification is the process by which the school tells parents and staff
about the availability of a Management Plan and other activities pertaining to asbestos in the
school. Common methods of notification are: in an article in a regularly-issued school newsletter;
in a special letter sent to parents specifically about asbestos-related activities in the school; during
a regularly-scheduled meeting or a specially-scheduled meeting specifically on asbestos-related
activities; or in an official press release approved by the school. The notification may originate in
the LEA, perhaps the ADP's office, or the superintendent's office, and be distributed by the
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school. For purposes of this study, notification does not include informal talks with teachers or
other school staff, or newspaper articles other than official school press releases.
2.6 Management Plan Evaluation
2.6.1 Management Plan Evaluation • Task 5
Evaluation of the Management Plans collected in Task 2, the ADP Interview, was a
multifaceted task which involved looking at each Management Plan from two totally different
perspectives. The first of these perspectives was as an historic document, to be reviewed without
reference to any of the findings of Westat's reinspection. The second perspective was as a form for
presenting the findings of the original AHERA inspection which were then compared with
Westat's reinspection findings. Two primary forms were used to review the Management Plans,
and each views a plan from one or the other of these perspectives.
Primary review of the Management Plans using forms Ml and M2 was performed by
Susan Viet and Eva Clay, both senior AHERA-certified Management Planners. Both reviewers
are Certified Industrial Hygienists, and each has over five years of experience as asbestos
inspectors, consultants, and educators. A secondary quality assurance review of selected
Management Plans was conducted by Dale Keyes, a respected expert in the field of asbestos
management and control.
Form Ml: Management Plan Checklist
The Management Plan Checklist (Form Ml) views the Management Plan as an
historic document. It asks questions that relate to the completeness, usability and content of the
Management Plan, and presents a structure for "grading" each Plan. The general structure of this
form follows the EPA's Key Elements Checklist (Appendix G), used by the EPA to determine the
completeness of a Management Plan according to the criteria established by AHERA.
This form makes no attempt to compare any findings of Westat's reinspection (even
such findings as the number of buildings in a school) with those presented in the Management
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Plan. For instance, Question 3 on Form Ml asks, "Is the name and address indicated for each
school building on the inventory?" In this case, as in all others on this form, we are looking for
internal consistency rather than that the Management Plan agree with our findings.
Form Ml evaluates the completeness of the Management Plan in the following areas:
• General Inventory (10 points);
• Exclusion/Inspection Information (70 points);
• Response Action Recommendations (30 points);
• Activity Plans (39 points);
• Resource Evaluation (10 points); and
• Presentation of the ADP's Qualifications (6 points).
In addition to a review of these mandatory Elements of a Management Plan, Form
Ml also covers whether air sample clearance results were present and the type of clearances
undertaken [e.g., Transmission Electron Microscopy (TEM) vs Phase Contrast Microscopy
(PCM)] for the purpose of determining how well schools are updating the Management Plans.
Usability questions for this review cover the presence or absence of non-mandatory,
but very helpful Management Plan components such as numbered pages, a definitions section, and
a program organization chart. This aspect of Form Ml also requests the reviewer to determine
the characteristics of a person who could use and understand the Management Plan, from both the
perspective of educational level, and the perspective of knowledge of the school's buildings and
AHERA asbestos inspection experience.
FonnM2: Management Plan Comparison Report
The Management Plan Comparison Report (Form M2), is a computer generated
form that presents the findings of the Westat reinspection (Task 3, Reinspection of Schools) on a
material-by-material basis. This form also has areas for the Management Plan reviewer to fill in
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the findings of the original AHERA inspection for each material found by Westat. The specific
questions asked about each material include:
• Was the material found in this room by the original AHERA inspection?
• What was the quantity of material found by the original AHERA inspection?
• Were bulk samples of this material taken, and if so, how many?
• Was the material assessed, and if so were AHERA 1-7 categories used for this
assessment?
• If the material was found to contain asbestos, was a response action
recommended, was it appropriate, and was it a "specific" or a "generic"
response?
The results of this comparison were used to generate the Original Inspector's
Performance Score.
2,62 Original Inspector's Performance Score
Each original inspector was scored or graded on a scale of 0 to 100 on the quality of
his/her performance during the reinspection he/she conducted in any schools in our sample. The
score was generated by averaging each inspector's material-by-material performance in answer to
questions about the identification of suspect material, the assessment of material appropriately,
the number of samples taken, etc.
2.7 Telephone Interviews
Task 6, Parent and Teacher Notification Survey, and Task 7, Original Inspector
Survey, were both conducted as telephone interviews from Westat's headquarters office in
Rockville, Maryland.
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2.7.1 Parent and Teacher Notification Survey - Task 6
The Parent and Teacher Notification Survey (Task 6) was a telephone survey of active
parents and teachers whose names were provided to us by the principal of each sampled school. In
some cases a postcard was given to the principal to give to the desired respondent. One parent
and one teacher for each school were called and asked questions about any asbestos notifications
from the school that they recalled receiving since December of 1987.
Form Nl: Parent And Teacher Notification Interview
Questions in the Parent and teacher Notification Interview followed closely those in
the Principal Interview (Form PI). In each case the respondent (parent/teacher) was asked if
he/she remembered whether one or more notifications to parents went out, and if so, how many
and when. A respondent was then asked about notification format (e.g., letter, meeting, or
newsletter) and about the content of the notification. He/she was also asked if there was any
particular reaction to the notification. All of these questions were then repeated for notifications
to teaching staff.
2.12 Original Inspector Survey - Task 7
In the Original Inspector Survey (Task 7), Westat called the inspectors who conducted
the original AHERA inspection for each of the schools included in the sample. In cases where
only one inspector was listed as performing the inspection, all efforts were made to track and
interview that inspector. In cases where more than one inspector was listed as performing the
inspection, only the most senior inspector, Management Plan author (if also an inspector), or
inspection team leader was called.
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Form Ol: Original Inspector Interview
The Original Inspector Interview (Form 01) was a telephone survey form which was
used to learn the inspector's qualifications at the time that the original AHERA inspection
occurred. The particular types of qualifications we were interested in included:
• Level of formal education obtained;
• Technical or vocational education and certifications held;
• Number of asbestos inspections performed, both AHERA and non-AHERA
inspections; and
• Number of years of work experience in such fields as construction, industrial
hygiene and engineering.
The results of this interview were combined with the Original Inspector's
Performance Score and a statistical analysis of inspector performance and qualifications was
performed.
2.8 Focus Groups
A total of nine focus groups were conducted in five locations nationwide. Four of
these focus groups were with parents and teachers of local public and private schools not included
in our sample, and five were with maintenance and custodial personnel from schools not included
in our sample.
"Focus group" discussions, or "intensive group interviews," provide a flexible tool for
exploring respondent awareness, behavior, concerns, beliefs, experience, motivation and practices
related to a particular topic. The focus group is a small discussion group of eight or so people, led
by an experienced moderator who is skilled at bringing out full discussion of the issues. The
moderator guides the discussion in order to identify points of consensus, as well as differing views
and the reasons behind the differences.
The focus group approach is used to develop qualitative insight rather than
quantitatively precise or absolute measures. The results of these focus groups cannot be
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considered a statistical data collection methodology as the recruiting of participants cannot be
replicated nor can the flow of conversation be repeated to enable the exact same questions in the
same order to be asked of other respondents. This type of research is intended to provide depth of
knowledge, awareness, and opinions.
The moderator uses a discussion guide, which is a guide to collect qualitative data,
similar to a questionnaire in a formal survey, to lead the group. (The discussion guide for the
parents' and teachers' groups is presented in Appendix D, and the guide discussion for the
maintenance and custodial workers is presented in Appendix E.) The topic guide presents general
areas for discussion, rather than a list of questions to be read verbatim. Departures from the guide
and probing of areas that arise are often highly valuable.
2.8.1 Parent and Teacher Notification Focus Groups - Task 8
Westat conducted a total of four focus groups with parents and teachers not
associated with schools in our sample. These groups were held in St. Louis, Boston, Seattle, and
New Orleans. Each group had ten or more participants from public, private and Catholic schools.
These focus groups were tape recorded for subsequent analysis. Even though
respondents were aware of the recording, they quickly became oblivious to it. Each focus group
was analyzed and a written summary was prepared shortly after the group met. These summaries
are presented in Appendix D. Finally, in the synthesis of results, all groups were analyzed
collectively, general themes were identified, and any contrasts of responses from group to group
were presented.
Topics discussed included:
• The level of participant knowledge about asbestos in their school, and sources
of that knowledge;
• Participant reaction to three examples of notifications; and,
• Participant reaction to differing methods of notification (e.g., mail, newsletter,
etc.).
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The discussion guide and examples of notification used are presented in Appendix D.
2.82 Maintenance and Custodial Workers Focus Groups • Task 9
A total of five focus groups with maintenance and custodial workers were conducted
in St. Louis, Boston, Seattle, New Orleans, and Bethesda, Maryland. Participants were recruited
from public, private and Catholic schools not in our sample, and no supervisory personnel were
invited to attend. The maintenance and custodial focus groups were video taped. Even though
respondents were aware of the recording, they quickly became oblivious to it. Each focus group
was analyzed and a written summary was prepared shortly after the group met. These summaries
are presented in Appendix E. Finally, in the synthesis of results, all groups were analyzed
collectively, general themes were identified, and any contrasts of responses from group to group
were presented.
Topics included:
• Participant knowledge of asbestos in their schools both prior to AHERA and
post AHERA;
• Participant knowledge of and utilization of the school's Management Plan;
• The length, scope, and format of participant training in asbestos management;
and
• Participant job responsibilities and techniques used around asbestos-containing
material.
The discussion guide for these focus groups is presented in Appendix E.
2.9 Schools Included in the Sample
All data analyses presented in Chapters 3 through 9 are national estimates based on a
nationwide statistical sample of schools and school buildings. The data for schools and school
buildings were projected to the population of schools or buildings by multiplying the amounts
found as a result of this evaluation by the weights described in Chapter 10. There are an estimated
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106,032 schools in the nation. This number excluded Department of Defense schools, libraries,
universities, prison schools and State Departments of Education. The school-level estimates used
in the evaluation represent all schools nationally that would be eligible for the AHERA evaluation,
and total 83,840. Eligible schools are those which taught classes in any of grades 1 through 12, had
an asbestos Management Plan during the 1989-1990 school year, and had at least one eligible
building as described below. There are an estimated 189,022 eligible school buildings contained in
eligible schools. Estimates of eligible buildings were statistically derived from data gathered
during both the screening and field portions of the evaluation. The resulting building-level
estimates represent all buildings nationally that would be eligible for the AHERA evaluation.
Eligible buildings meet the following conditions:
1. School building is in an eligible school;
2. School building was built before October 1988;
3. School building was inspected for ACM since December 1987;
4. The inspection discovered some ACM or suspect ACM; and
5. Students were regularly in the building during the 1989-1990 school year.
These eligible schools and school buildings constitute the study population for all
research areas. Due to the eligibility requirement, the AHERA evaluation results apply only to
eligible schools and eligible buildings in those schools, not to all schools and buildings in the
country. At least 72 percent of schools nationwide were eligible for the AHERA evaluation. If we
assume the schools that were not contacted or refused to participate in the screening were eligible
to participate in the evaluation with the same frequency as contacted schools, then the sample
could represent as much as 79 percent of all schools in the nation. Table 2-2 shows the estimated
percentage of schools nationwide by eligibility status, based on the results of the screening sample.
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Table 2-2. The percentage of schools nationwide by eligibility status
Eligibility status
Eligible
Ineligible
No grades 1-12
No Management Flan
No eligible buildings
No contact
Refusal
Percent
72
18
(4)
(1)
(13)
4
6
Estimates based on probability samples like the one used in AHERA, have sampling
errors associated with them. The sampling errors in Appendix K were used to construct
"difference tests" to determine statistically significant differences (for example, between principals
and parents or between maintenance workers and custodians). The "P-value" of a particular
comparison represents the probability that a difference may not be statistically significant. In
practice, differences with a P-value of .05 or less are considered significant. In the AHERA
evaluation we are interested in many comparisons. In a large number of comparisons, 1 in 20 P-
values are expected to be less than .05 when in fact the difference is not significant. To
compensate for these multiple comparisons and control the overall P-value of several related
comparisons, we have considered a difference to be statistically significant if the P-value is less
than .05 - g, where g is the number of related comparisons. See Appendix K for a complete
discussion of sampling error.
Sampling errors are sometimes used to form confidence intervals for estimates to
indicate their precision. Results in Chapters 3 through 9 are followed by a number in parenthesis
for example, "...80(±(%) of schools nationally... This number in parentheses may be used to form
a 95 percent confidence interval on the estimate and gives a quick indication of the precision of the
data. Ninety-five percent confidence intervals and coefficients of variation for all results in
Chapters 3 through 9 are in Appendix I.
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3. SCHOOL BUILDING REINSPECTION
Research Area 1 addresses the AHERA inspections performed in the nation's
elementary and secondary schools. Two research questions were posed for investigation: 'How
much of the suspect material in the schools was found at the original AHERA inspection?' and
'How much of the asbestos was appropriately assessed?' Data for both questions were obtained by
conducting a reinspection of a statistical sample of 207 school buildings and comparing the results
of the reinspections with the original AHERA inspection results as reported in the schools'
Management Plans. A number of technical terms are used in this report. Their definitions are
collected in a Glossary and the terms are in boldface when first used in this chapter.
In order to ensure the objectivity and validity of the reinspections, they were "blind".
That is, the reinspectors had no access to the Management Plans or prior knowledge of where
asbestos supposedly existed in the sampled schools. Thus, the comparisons of the original
AHERA inspections and the reinspections were comparisons of two independent inspections of a
school building.
The related terms suspect materials and asbestos-containing materials (more
precisely, asbestos-containing building materials) are used extensively throughout this report.
Since these terms are not synonymous, they need to be defined in a manner that clarifies the
distinctions among them. Suspect materials are materials suspected of containing asbestos
because, before 1980, they were frequently manufactured using asbestos. Examples of suspect
materials include pipe insulation, boiler insulation, spray-on acoustical surfacing material, ceiling
tile, vinyl floor tile, etc. Suspect materials are generally divided into three broad categories of
materials, thermal system insulation, surfacing materials and miscellaneous other materials. Each
of these categories is subdivided into more specific and descriptive material types such as pipe
insulation, fire proofing, floor tile, etc. AHERA regulations define a list of specific suspect
building materials to be inspected in schools.
It is impossible for a visual examination of a particular suspect material to determine
if that suspect material does in fact contain asbestos. It is necessary to submit samples of the
material (known as bulk samples) to laboratory analysis to determine what percent of the material
is asbestos. If the material contains more than one percent asbestos, then it is considered to be
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asbestos-containing material (ACM). If the ACM is a building material, it is more precise to call it
asbestos-containing building material (ACBM).
In many asbestos inspections, including those under AHERA, some suspect materials
are not submitted to laboratory analysis. Instead, the inspector and building owner agree to
assume that the material contains asbestos and treat it accordingly. These assumptions are
generally made to save laboratory costs when materials are much more likely to be ACM than
asbestos-free, or to avoid potential fiber release associated with cutting into undamaged materials
such as floor tile.
The objective of both the original AHERA inspections and the reinspections was to
identify, describe, locate, assess, and quantify each homogeneous suspect material in the school
building. A homogeneous material is a material that is uniform in color, texture and appearance,
was installed at one time and is unlikely to consist of more than one formulation of ACBM. Thus,
9" by 9" and 1' by 1* floor tile would be two different homogeneous materials of the same type. A
particular suspect material was considered to be identified in the original inspection if it was
reported in the Management Plan, in any manner. Locating suspect homogeneous materials
means to report the locations of the material in the building. Suspect materials are generally
quantified as square feet of surface covered by the material. A few materials, most notably pipe
wrap, are quantified as linear feet of insulated pipe.
In order to compare original inspection and reinspection results, it was necessary to
estimate the actual quantity of each suspect material present in the building at the time of the
original AHERA inspection. This quantity will be referred to as the total amount in the building.
It is defined as the quantity of material reported by the study team during the reinspection, unless
a removal of some or all of the material has been reported. In the latter case, the total amount is
defined as the larger of the two quantities reported in the original inspection and reinspection.
This definition presumes no new suspect material has been added since the original AHERA
inspection; replacement of materials does not affect the study results.
We believe the reinspection findings provide a reliable basis for evaluating the
original AHERA inspection, for the following reasons:
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• The inspectors performing the reinspections all met or exceeded the criteria set
forth in the National Asbestos Council's March 1989 Model Plan for
Reciprocity. This plan outlines experience and educational background well in
excess of the basic three-day training mandated by EPA for building inspectors.
• Our inspectors received a four-day training specific to the study, to standardize
field procedures within the group of reinspectors.
• Two-person teams reinspected each building, each member having clearly
defined roles. The inspector was required to make actual measurements of
each suspect material using a measuring device (estimating or "eyeballing" was
not permitted).
• Realistic scheduling of reinspections allowed teams plenty of time to perform
complete and thorough reinspections.
• Our data collection forms were designed with internal checks which ensured
that all required quantity, location, and assessment information was collected
for each material found.
• Our data processing, key entry and supervisory review were all used to ensure
accurate transfer of data to computerized form.
• We conducted expert review of the reinspection reports to provide rigorous
checks for potential outliers.
As discussed in Chapter 2, no bulk samples of suspect materials were collected during
the reinspections. Instead, we extracted laboratory results from the original AHERA inspection
(as reported in the Management Plans) to classify suspect materials as ACBM or non-ACBM.
Thus, if a suspect material encountered in the reinspection was identified in the original inspection
as ACBM, through either laboratory analysis or assumption, then it was considered to be ACBM
for this research. Suspect materials encountered during the reinspection which had not been
identified in the original AHERA inspection cannot be classified as either ACBM or non-ACBM
and thus remain in the "suspect materials" category.
3.1 Suspect Material Found in the Original AHERA Inspections
The basic research question, 'How much of the suspect material was found at the
original AHERA inspection?' is too general to be answered exactly as stated. There are a number
of ways to refine it into meaningful questions that can be answered analytically:
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Identification of Materials
• How many of the homogeneous suspect materials in the school building were
identified at the original inspection?
• What percentage of the total amount of suspect material was identified at the
original AHERA inspection?
• How many school buildings have one or more suspect materials that were not
identified in the original inspection?
Estimation of Material Quantities
• For materials which were identified at the original AHERA inspection, what
was the extent of the underestimation?
Recording Material Locations
• For materials which were identified at the original AHERA inspection, was the
suspect material recorded in every area where it was present?
Variation in Inspections with Material Type and Area Use
• Do the answers to the previous questions vary with the type, friability or
asbestos content of the material or with area use?
The first three specific questions asked above address the ability of the original
AHERA inspectors to identify suspect materials. The questions are important because, if a
material was not identified, it was not sampled to determine asbestos content. Moreover, it would
not have been included in the asbestos management program, even if it was AC8M.
The fourth question addresses the ability of the AHERA inspectors to quantify
suspect materials. LEAs need reasonably accurate quantifications of the asbestos materials in
their schools in order to be able to estimate the costs of remediations.
The fifth question addresses the ability of the original inspectors to clearly record all
areas in a building where the suspect material is located. This is important because Management
Plans should provide school employees and parents with reliable information about the locations
of ACBM, and areas that have no ACBM. In particular, school maintenance workers should know
where it is necessary to protect themselves from potential exposure to asbestos fibers and where
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such protections are unnecessary. Clear records of the locations of non-ACBM give a worker
information with which to differentiate between similar materials. Records of non-ACBM are also
required by AHERA.
The sixth and last question seeks to determine if the ability of the original AHERA
inspector to identify, quantify and locate suspect materials varies with material types or area use.
These relationships are explored within the context of the previous five questions. They are
important to consider in order to improve training curricula for asbestos inspectors.
In order to answer these specific questions, Westat compared in detail the results of
the study reinspections with the results of the original AHERA inspections, as reported in the
Management Plan. To do this, Westat generated a report on the quantity and area locations of
every suspect material identified in a building during the reinspection (Form M2, Appendix A).
Each Management Plan was then reviewed to determine if the original inspection had identified
suspect materials of the same types in the same areas and, if so, what quantities were reported.
This information was recorded on Form M2 next to its companion reinspection information.
Some difficulties were encountered in performing these comparisons. Management
Plans do not treat non-ACBM consistently. Some report only the negative laboratory findings;
they do not describe the material or report its locations. Some Management Plans did not provide
area-by-area reports of discovered asbestos, e.g. they reported a particular material as "throughout
building". Not unexpectedly, Management Plans reported suspect materials in different, frequently
coarser, categories than those employed in the reinspection. For example, they might report TSI
in the boiler room", not subdividing it into boiler insulation, pipe wrap, joint insulation, etc. Many
Management Plans recorded areas in a manner that made it difficult to match them with the
school floor plans and the reinspection report. Differences in architectural and materials
nomenclature between the original AHERA inspections and reinspections, and across LEAs also
complicated the comparisons. In most of these cases, it was, nonetheless, possible to confidently
match areas and materials by grouping what the reinspection had viewed as separate areas of a
building or separate subcategories of materials. For example, grouping two or three different
types of ceiling tiles into one material type sometimes permitted a meaningful comparison
between the reinspection findings and the Management Plan. Where reasonable doubt existed in
the mind of the reviewers, the original AHERA inspection was given credit for correctly
identifying, quantifying or locating a material. In addition, the reviewers used all items within a
...3-5 -
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PEER REVIEW DRAFT
Management Plan during the comparison process. For example, the original inspector was given
credit for identifying a material which was mentioned only in a laboratory bulk sample report; or
for locating material by highlighting areas on a floorplan, or even when sample locations were
listed.
3.1.1 Identification of Materials
Table 3-1 addresses the first analytical question posed above, 'How many of the
suspect materials in the school building were identified at the original AHERA inspection?' Table
3-1 displays national estimates of the total number of materials within AHERA's scope, and the
number and percent of these materials identified in the original AHERA inspections, by category
of material and by friability. It is important to note that this table deals with all suspect material,
and not just ACBM, since asbestos content cannot be determined for the unidentified materials.
Note also that TSI is considered in this study to be friable in all instances. Hence, there are no
differences between the "All" and "Friable" columns for TSI. The total number of suspect
materials is the estimated number of suspect materials in the schools of the time of the original
AHERA inspections; it is calculated as the sum of the individual suspect materials found in the
reinspection plus the number of materials completely removed since the original inspection.
Finally, each suspect material contributes equally to Table 3-1, regardless of the amount of
material in each instance.
Friability data for Table 3-1 come from the reinspection report, because Management
Plans do not provide that information for unidentified materials. Nineteen materials in the sample
had been totally removed at the time of the reinspection, so that friability could not be determined
in the reinspection. Seventeen of the 19 materials were TSI, which is always considered to be
friable. The friability data in the Management Plan was used for the remaining two totally
removed materials (surfacing materials).
Accurate interpretation of Table 3-1 requires an understanding of how the table was
constructed, which is perhaps best explained by way of an example. Suppose that the original
inspector visited a school building in which boiler insulation, pipe wrap, elbow insulation, and
fireproofing were located. If this inspector identified the boiler insulation, pipe wrap and elbow
3-6
-------
Table 3-1 Estimated number and percent of suspect materials Identified In original AHERA Inspections, by material category
and friability
Material Category
TSI
Surfacing
Miscellaneous
All Materials
Total Number of Materials (000)
All
243
41
687
971
Friable
243
32
231
506
Number of Materials Identified (000)
All
197
27
459
683
Friable
197
21
146
364
Percent of Materials Identified
All
81%
66%
67%
70%
Friable
81%
66%
63%
72%
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PEER REVIEW DRAFT
insulation, but failed to identify the fireproofing, then one surfacing material would be counted as
unidentified out of a total of one surfacing material or four total suspect materials in that building.
A number of findings emerge from a review of Table 3-1:
• There were an estimated 971,000 individual suspect materials in schools
throughout the nation, of which 506,000 were friable.
• Over all material categories, approximately 70 percent of suspect materials
were identified in the original AHERA inspections.
• TSI was more likely to be identified in AHERA inspections than surfacing or
miscellaneous materials.
• There was no significant difference in the ability of the original AHERA
inspectors to identify all suspect materials as compared to just friable materials.
The significance of the findings from Table 3-1 can be better understood by
translating the number of materials into the corresponding quantities of material. Table 3-2
displays national estimates of the amounts of suspect materials in school buildings at the time of
the original AHERA inspection and the percentage identified in the original AHERA inspections,
by friability and material type. Figure 3-1 graphically presents the information from Table 3-2 for
each material category. It is important to keep in mind that Table 3-2 and Figure 3-1 present data
for all suspect materials, not just ACBM, and that TSI is always considered friable.
To understand Table 3-2, read across the row entitled "All surfacing" as: there were
299,751,000 square feet of surfacing material present in schools of which 86 percent was identified
in original AHERA inspections; 241,190,000 square feet of the surfacing material was friable; 90
percent of the friable surfacing material was identified in the original inspections. Likewise, the
first bar on the left of Figure 3-1 reads as: 45 million square feet of friable TSI was present in
school buildings, of which over two-thirds was identified in original AHERA inspections.
Review of Table 3-2 and Figure 3-1 shows:
• While 70 percent of the total number of suspect materials was identified in the
original AHERA inspections (see Table 3-1), 89 to 94 percent of the total
quantity of material was identified.
3-8
-------
Table 3-2 Estimated quantity present and percentage Identified In original AHERA Inspections of suspect materials,
by material type and friability
Material Type
AIITSI
Breeching
Boiler
Tank
Pipe
Elbow/Fitting/Valve
Duct
Other TSI
All Surfacing
Ceiling Material
Fireproofing
Wall Coating, Other
All Miscellaneous
Acoustical Wall Tile
Fire Doors
Linoleum/Solid Floor Cover
Vibration Dampening Cloth
Floor Tile
Trans ite
Ceiling Tile
Other Miscellaneous
All Materials
Unit of
Measurement
Square Feet
Linear Feet
Square Feet
Square Feet
Square Feet
Linear Feet
Linear Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Square Feet
Linear Feet
Square Feet
All Suspect Material
Total
Amount
Present (000)
45,562
89,221
9.896
11,121
9,521
65,262
23,959
14,603
421
299,751
244,913
38,534
16,304
4,318.636
23,173
12,255
29,439
2,408
1,815,468
31,659
2,399,493
4,741
89.221
4.663,949
Percent
Identified
71%
94%
80%
92%
99%
94%
95%
32%
69%
86%
92%
56%
67%
89%
85%
24%
35%
14%
98%
76%
84%
46%
94%
89%
Friable Suspect Material
Total
Amount
Present (000)
45,562
89,221
9,896
11,121
9,521
65,262
23,959
14,603
421
241,190
212,287
21,567
7,340
2,222,677
20,396
3,214
456
988
80,937
15.207
2,097,439
4,040
89,221
2,509,429
Percent
Identified
71%
94%
80%
92%
99%
94%
95%
32%
69%
90%
89%
98%
80%
85%
86%
8%
38%
21%
99%
88%
85%
20%
94%
85%
3-9
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Rgure 3-1 Quantity of suspect material Identified In original AHERA
Inspections, by material category and friability
4500 j
4000.-
3500..
3000 "
Total Amount aiw • •
(000,000) 2000 • •
1500..
1000 ..
Sqtl
Sqft '
Thermal System Insulation
Surfacing Material Miscellaneous Material
Suspect Material Category
D Identified • Unidentified
F = Friable suspect materials only
Rgure 3-1 Quantity of suspect material Identified In original AHERA
Inspections, by material category and friability (Detail)
500 -r
Total Amount
(000,000)
Thermal System Insulation Surfacing Material Miscellaneous Material
Suspect Material Category
D Identified • Unidentified
F = Friable suspect materials only
3-10
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PEER REVIEW DRAFT
• The least frequently identified suspect materials were vibration dampening
doth (VDC), fire doors, duct insulation and linoleum. Over 50 percent of these
materials were not identified in the original AHERA inspections.
• The most frequently identified suspect materials were tank insulation, floor tile,
elbow/fitting/valve insulation, pipe insulation, boiler insulation and ceiling
surfacing material. Over 90 percent of the total amount each of these materials
was identified in the original AHERA inspections.
• Few differences were observed in the original inspector's ability to identify all
suspect materials as compared to just friable materials. The notable exceptions
were in the cases of fireproofing and wall coatings, where a much higher
percent of the friable materials was identified.
Figure 3-2 describes unidentified suspect materials at the building level; it presents
data on the percent of buildings that have all materials identified, and at least one material not
identified by the original inspector, by material type. (Chapter 6, Original Inspection Evaluation,
presents additional related information on this topic.) Figure 3-2 provides insight into how many
materials were missed per building inspection. In this figure, the bar labeled "transite" may be
interpreted as: 13 percent of buildings have at least one transite material unidentified, while 11
percent of buildings have all transite materials identified. The significant findings from Figure 3-2
are:
TSI materials were more likely to be identified in buildings than either
surfacing or miscellaneous material types. Tank insulation was identified in 95
percent of buildings where it was located, and breaching insulation was
identified in 79 percent of buildings.
Vibration dampening cloth was least likely to be identified (14% of buildings),
followed by linoleum (36%), fire doors (41%), and transite materials (46%),
where those materials were present.
Because ceiling tile and vibration dampening cloth are common in buildings and
were frequently unidentified, there remain 20 percent and 30 percent,
respectively, of school buildings with some of these materials unidentified.
3.12 Estimation of Material Quantities
The previous discussion dealt with the ability of the original AHERA inspectors to
identify materials; unidentified materials were materials found in the reinspection but not
mentioned in the Management Plan. We now turn to an examination of the original inspector's
3-11
-------
Figure 3-2 Incidence of buildings with suspect materials identified and unidentified in original AHERA
Inspection, by material type
90% -r
Percent of bldgs with at
least one material
to
30% -•
10% -•
0%
Breech- Boiler
ing
Tank Pipe Fittings Spray- Ceiling Fire Floor
on tile doors tile
ceiling
material
Suspect material type
Lino-
leum
Tran-
site
VDC
D Bldgs with any unidentified materials • Bldgs with all materials identified
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PEER REVIEW DRAFT
ability to provide accurate information about the quantities of identified materials. Table 3-3,
therefore, focuses our attention solely on the materials identified by the original inspection and
answers the specific question, 'What quantity of suspect material was underestimated?' Suspect
materials are addressed by material category and friability, as with the previous discussion, as well
as by asbestos content. This is because bulk sample results from the Management Plans are
available for each of these materials. ACBM includes materials which had positive (greater than
one percent asbestos) bulk sample results and materials which were assumed to be ACBM by the
original inspector.
The determination of underestimated amounts deserves some discussion. The
evaluation team recognized that deviations in measurement between inspectors is fairly broad.
The expert consultants agreed that an original inspection quantity within 20 percent of the
reinspection quantity should be considered an acceptably accurate estimate. The study team
therefore decided to conservatively calculate the underestimated quantity of ACBM by labeling a
quantity in a Management Plan as an underestimate only if it was less than 80 percent of the
reinspection quantity. Accordingly, a conservative calculation of the underestimated quantity was
obtained by taking the difference between 80 percent of the reinspection quantity and the original
inspection quantity. If the original inspection quantity exceeded 80 percent of the inspection
quantity, the amount underestimated was set to zero. For example, suppose a reinspection found
500 square feet of boiler insulation and the Management Plan reported 300 square feet. The
underestimated amount would then be (.8)(500) - 300 = 100 square feet. If, instead, the
Management Plan reported 420 square feet, the underestimated amount would be zero, since 420
square feet is greater than 80 percent of 500 square feet. The project team and expert consultants
agreed that underestimated amounts calculated in this manner would clearly be attributable to
underestimations on the part of the original inspector, rather than differences in material
description; architectural nomenclature, etc. Since overestimates of quantity are not considered to
be particularly detrimental to the school, no evaluation of these phenomena was made.
To illustrate Table 3-3, read across the row titled Surfacing as: an estimated
258,600,000 square feet of surfacing material was identified in school buildings of which 10 percent
was underestimated by the original AHERA inspectors. Of the 258,600,000 square feet:
241,191,000 square feet was friable of which 10 percent was underestimated; 76,048,000 square feet
contained asbestos of which 13 percent was underestimated; and 63,105,000 square feet was friable
and asbestos-containing, of which 12 percent was underestimated by the original inspectors.
3-13
-------
Table 3-3 Percentage of material quantities underestimated In original AHERA Inspection, by material category, asbestos content and friability
Material Category
TSI
Surfacing
Miscellaneous
All Materials
Unit of
Measurement
Square Feet
Linear Feet
Square Feet
Square Feet
Square feet
Linear Feet
All Suspect Material
Total
Amount
Present (000)
32.104
83.643
258,600
3,851.839
4,142,543
83,643
Percent
Under-
Estimated
29%
9%
10%
30%
29%
9%
Friable
Amount
Present (000)
32,104
83,643
241,191
1.893.855
2.167.150
83,643
Percent
Friable Under-
Estimated
29%
9%
10%
41%
38%
9%
ACBM
Total
Amount
Present (000)
30,450
80,409
76,048
2,108.997
2.215.495
80,409
Percent
Under-
Estimated
28%
9%
13%
26%
28%
9%
Friable
Amount
Present (000)
30,450
80,409
63.015
453,329
546,794
80,409
Percent
Friable Under-
Estimated
28%
9%
12%
55%
48%
9%
Note: Only materials Identified In AHERA Inspection are addressed In this table.
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PEER REVIEW DRAFT
Significant findings in Table 3-3 include:
/
• The percent of ACBM underestimated ranged from 9 percent for linear TSI to
55 percent for friable miscellaneous materials.
• The original inspectors estimated quantities for lineal feet of TSI
(pipe/joint/elbow/valve insulation) much better'than for square feet of TSI
(boiler/tank/duct insulation).
• Friable miscellaneous materials are not as well quantified as all miscellaneous
materials.
Figure 3-3 further characterizes underestimated material quantities. It presents
estimates of the percent of buildings nationally that have underestimated materials by material
category, friability and asbestos content. This figure is different from Table 3-3 in that the total
quantities of each material category, rather than the sum of each individual material type in a
building, are used to define underestimation. The last bar on the right of Figure 3-3 shows that in
42 percent of buildings, the total quantity of suspect friable miscellaneous material is
underestimated by 20 percent or more; and in 24 percent of buildings, asbestos-containing friable
miscellaneous material is underestimated by 20 percent or more.
Several findings are shown in Figure 3-3:
• More than 50 percent of buildings have the total quantity of each suspect
material category properly estimated.
• More than 60 percent of buildings have the total quantity of each asbestos-
containing material (by category) properly estimated.
• About twice the number of buildings have underestimated quantities of
miscellaneous materials as compared with surfacing materials or TSI.
• Fewer buildings have friable materials underestimated as compared with all
suspect materials.
3.13 Recording Material Locations
This section continues the analysis of the inspectors' ability to provide accurate
information about identified materials. The previous section dealt with underestimated amounts
of identified materials. This section provides answers to the question, Tor materials which were
3-15
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PEER REVIEW DRAFT
Figure 3-3 Percent of buildings with suspect material quantity underestimated
in original AHERA Inspection by material category, asbestos content and
friability
50% -,-
45% --
40% --
35% --
30%
Percent of
Buildings with
Total Material 25%
Quantity
Underestimated
20%
15%
10%
5%
0%
Thermal System Insulation Surfacing Material Miscellaneous Material
Suspect Material Category
DACBM •NOH-ACBM
F = Friable suspect materials A = All suspect materials
3-16
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PEER REVIEW DRAFT
identified at the original AHERA inspection, was every area where the material was present
recorded?' AHERA requires the locations of suspect materials be clearly indicated in the
Management Plan by use of blueprints, diagrams or written description. Table 3-4 displays the
estimated national percent of building areas with suspect material present, but not recorded in the
original AHERA inspection. This presentation is by type of material and by type of area.
Table 3-5 presents the same information for ACBM only.
Area types are discussed and specifically listed in Chapter 2, but are summarized here
for convenience:
• Exterior areas - such as porticos, covered walkways, rooftop HVAC units (no
walls), etc.
• Mechanical areas - such as boiler rooms, elevator shafts, mechanical rooms, air
and duct shafts, telephone and electrical closets, etc.
• Limited student access areas - such as janitor's closets, kitchens, offices, supply
rooms, teachers' lounges, etc.
• General access areas - including classrooms, gymnasiums, auditoriums,
cafeterias, restrooms, hallways, etc.
The term recorded area is used in this analysis to mean any area within a building in
which a particular material was present at the reinspection that was also recorded in that area by
the original inspection. Conversely, an "unrecorded area" is one in which material was found
during the reinspection which was not recorded, in any manner, in the original AHERA
inspection. It is not possible to differentiate among areas in which the original inspector did not
look, areas where the inspector did look, but did not find the material and areas which the
inspector merely failed to document as containing the material; thus, the use of the term
"unrecorded". As with the quantity of material underestimated, some discussion is needed
regarding how the count of unrecorded areas was performed. We recognized that there are many
factors that could contribute to some of the areas being labelled as unrecorded during the review
process. These factors include differences in floorplans or naming building areas and, to a lesser
extent, renovations in the school buildings since the original inspection. As with the determination
of underestimated quantities, the study team and expert consultants determined that an error of 20
percent was reasonable given the kinds of discrepancies possible. Thus, the percent of unrecorded
areas in a building was calculated by taking the difference between 80 percent of the total number
3-17
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Table 3-4 Estimated percent of areas with suspect materials present, but not recorded in original AHERA inspection,
by area type and material type
Type of Suspect Material
AIITSI
Breeching
Boiler
Pipe
Tank
Ducts
Elbow/Fitting/Valve
Other TSI
All Surfacing
Ceiling Material
Fireproofing
Wall Coating, Other
All Miscellaneous
Acoustical Wall Tile
Fire Doors
Linoleum/Solid Floor Cover
Vibration Dampening Cloth
Floor Tile
Transits
Ceiling Tile
Other Miscellaneous
All Suspect Materials
Type of Area
Exterior
— —
fm
-—
mm
^m
„
»
mm
mm
mm
mm
^m
13%
_
„
mm
mf
mf
29%
mf
„
14%
Umited
Student Access
43%
„
„
32%
„
..
50%
».
55%
68%
„
„
50%
mm
70%
37%
„
47%
.,
52%
45%
49%
General Access
52%
^,
M
50%
w.
..
53%
..
44%
51%
10%
__
43%
30%
72%
47%
53%
33%
28%
54%
42%
44%
Mechanical
26%
12%
0%
21%
7%
29%
33%
42%
44%
62%
23%
„
43%
„
47%
mm
41%
70%
9%
67%
18%
29%
All
Areas
42%
13%
0%
37%
8%
46%
47%
50%
47%
55%
13%
24%
45%
28%
66%
45%
43%
37%
19%
54%
40%
44%
- The sample size for this combination of area and material was too small for reliable estimation.
Note: This table excludes materials not Identified in the AHERA inspection.
3-18
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PEER REVIEW DRAFT
Table 3-5 Estimated percent of areas with ACBM present, but not recorded In original AHERA Inspection,
by area type and material type
Type of ACBM
All TSI
Breeching
Boiler
Pipe
Tank
Ducts
Elbow/Fitting/Valve
Other TSI
All Surfacing
Ceiling Material
Fireproofing
Wall Coating, Other
All Miscellaneous
Acoustical Wall Tile
Fire Doors
Linoleum/Solid Floor Cover
Vibration Dampening Cloth
Floor Tile
Transits
Ceiling Tile
Other Miscellaneous
All ACBM
Type of Area
Exterior
..
„
mm
„
„
9m
m^
„
mm
mm
fm
mm.
8%
fm
mm
mm
mm
mm
8%
„
„
9%
Limited
Student Access
42%
mm
_.
32%
-—
„
47%
mm
32%
32%
mm
mm
48%
„
70%
39%
mf
46%
..
67%
44%
47%
General Access
49%
»
„
50%
mm
..
100%
mm
18%
18%
69%
„
38%
23%
72%
25%
55%
32%
28%
67%
41%
39%
Mechanical
26%
10%
0%
21%
7%
30%
33%
44%
23%
20%
25%
„
45%
„
47%
„
49%
64%
10%
100%
10%
28%
All
Areas
40%
11%
0%
37%
7%
47%
44%
52%
20%
20%
42%
0%
40%
20%
60%
30%
47%
36%
19%
67%
38%
40%
The sample size for this combination of area and material was too small for reliable estimation.
Note: This table excludes materials not Identified In the AHERA Inspection.
3-19
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PEER REVIEW DRAFT
of areas recorded by the reinspection (for a given material) and the total number of areas reported
by the original inspection, and then converting to percent of total number. If the number of areas
recorded by the original inspection was greater than 80 percent of the number recorded by the
reinspection, the number of unrecorded areas was defined as zero.
To illustrate the interpretation of Tables 3-4 and 3-5, the "All miscellaneous" row in
Table 3-4 shows: 13 percent of exterior areas where miscellaneous suspect materials TSI was
present were not recorded in the original AHERA inspection, 50 percent of limited student access
areas where TSI was present were not recorded in the original inspection, and so forth. A number
of findings emerge from a careful review of these tables:
• Overall, approximately 44 percent of all areas where suspect material is present
were unrecorded. This reflects a tendency among inspection reports to either
not indicate areas where materials are present or do so in an incomplete
manner.
• Overall, areas in which ACBM is present were recorded in approximately the
same proportion as areas in which any suspect material was present.
• When boiler insulation was identified, its location was universally recorded by
all inspectors. Likewise, the location of tank insulation is almost always
recorded.
• TSI is more likely to be recorded in mechanical areas than in non-mechanical
areas.
• The locations of asbestos-containing surfacing materials are recorded more
often than for suspect surfacing materials. The exception is fireproofing for
which locations of all suspect fireproofing is almost always recorded (87%),
while asbestos-containing fireproofing was recorded in only 58 percent of the
areas present.
• Locations of fire doors were more frequently unrecorded than any other
material (66%).
• There are no patterns of differences in locating material between areas with
limited student access and general access areas.
Figure 3-4 provides estimates of the percent of school buildings, out of an estimated
189,022 school buildings in the study population, in which the AHERA inspector failed to record
more than 80 percent of the areas with suspect materials, by material type and area type. The first
bar on the left shows that 8 percent of buildings have suspect TSI (all of which is ACBM)
3r20^
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PEER REVIEW DRAFT
unrecorded in exterior areas. The second bar shows that 60 percent of buildings have suspect TSI
unrecorded in limited access areas, while 58 percent of buildings have asbestos-containing TSI
unrecorded in limited access areas. Significant findings from Figure 3-4 are:
• More buildings have unrecorded materials (over 50 percent of buildings for
each material category) in limited and general access areas than in exterior or
mechanical areas.
• The percent of buildings with unrecorded areas does not vary significantly with
asbestos content of the materials in those areas. This suggests the original
inspectors did not give greater attention to locating ACBM than to locating
other suspect materials.
32 Assessment of ACBM Found at Original AHERA Inspection
The second research question addressed in Research Area 1 asks, 'Was the asbestos
found at the original AHERA inspection appropriately assessed?' This component of the
AHERA evaluation is a check of the internal consistency of the Management Plan's logic and its
compliance with AHERA's assessment classification of materials. No comparisons were made
between the AHERA categories reported in the Management Plans and the categories observed in
the reinspection. Such comparisons would not be valid because there were numerous
opportunities for changes in the assessment category in the year or two years between the two
inspections. Materials may have been repaired or removed or, conversely, they may have suffered
further damage or deterioration.
The first part of the analysis of this research question considers how often asbestos
containing materials were assessed appropriately in the original AHERA inspection. Table 3-6
displays percentages of the number of ACBMs assessed and number assessed appropriately.
These numbers are the juxtaposed to the total number of materials which were required to be
assessed plus those nonfriable materials which were assessed. Assessment refers to ability of the
inspector to consider factors which may contribute to the increase in release of fibers from a given
material. An appropriate assessment in this table indicates that, at a minimum, the condition of a
material or amount of damage to TSI and other friable materials was indicated. AHERA
regulations did not require nonfriable materials to be assessed, though they were occasionally in
3-21
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PEER REVIEW DRAFT
the Management Plans reviewed. Assessed nonfriable materials were included in the count of
total number of materials assessed and were counted as appropriately assessed.
Table 3-6 shows that 92 percent of the ACBM which should have been assessed
according to AHERA was indeed assessed. In addition, all of the materials assessed were assessed
appropriately.
Table 3-6. Percent of ACBM in school buildings assessed appropriately in the original AHERA
inspection
Total number of ACBM*
653
Percent ACBM assessed
92%
Percent ACBM
appropriately assessed
92%
* Some inspections provided assessments for nonfriable materials. These are included in the total number of materials
assessed. Unweighted numbers are presented here.
The second part of the analysis addresses how often the AHERA assessment
categories were employed in the original AHERA inspection and how often those categories were
appropriately assigned. In this table, the assessment must be one of the seven categories defined
by AHERA, using either the numbers 1 through 7 or the wording corresponding to those numbers.
An appropriate assessment in this table means the original AHERA inspector assigned the
AHERA 1 through 7 category number or wording correctly based on material category (TSI,
surfacing, miscellaneous), and reported amount of damage at the original inspection and potential
for damage. If nonfriable materials were assigned an AHERA category, they were counted as
appropriately assessed. Since some original AHERA inspectors assessed nonfriable materials
even though it was not required, those inspections were not penalized if the AHERA categories
were not employed. This explains the difference in the total number of ACBMs in Tables 3-6 and
3-7.
Table 3-7 shows that only 44 percent of original AHERA inspections used the
AHERA categories. Of those inspections which used the categories, 93 percent (41 percent of 44
percent using the categories) applied them appropriately.
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Table 3-7. Percent of ACBM in school buildings assessed appropriately in accordance with
AHERA in the original AHERA inspection
Total number of ACBM*
568
Percent ACBM assessed
using AHERA 1-7
44%
Percent ACBM appropriately
assessed using AHERA 1-7
41%
' Some inspections provided assessments for nonfriable materials. If AHERA 1-7 was not used for nonfriable materials,
those materials have not been included here. Unweighted numbers are presented here.
33 Summary
The purpose of this research area was to estimate how much of the suspect material
was found in the AHERA inspections and how much of the ACBM was assessed in conformance
with AHERA regulations. "How much" was measured in three ways: we estimated how many
materials were identified; to what extent were the quantities of identified materials
underestimated, and what percentage of the areas with each type of suspect material did the
inspection record.
An estimated 70 percent of the materials present were identified in original AHERA
inspections. TSI was more likely to be identified than either miscellaneous or surfacing materials.
When the numbers of the individual suspect materials identified were translated into quantities,
approximately 90 percent of the quantity of material present was identified. Materials which were
highly likely to be identified accounted for most of the quantity of material, e.g., floor tile, pipe
insulation, and boiler insulation. Conversely, materials which were infrequently identified tended
to be small quantity materials, such as vibration dampening cloth, fire doors, duct insulation and
linoleum flooring. Despite the relatively high percentage of materials identified and material
quantities reported, many buildings have at least one material unidentified. Noteworthy is the
estimate that 36 percent of surfacing material is unidentified.
Once a suspect material was identified, original AHERA inspectors estimated the
quantity correctly in over 50 percent of buildings and they estimated the quantity of each ACBM
correctly in over 60 percent of buildings. The overall quantity of material underestimated ranged
from 9 percent (for linear TSI) to 55 percent (for friable miscellaneous ACBM).
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Also, once a material was identified, original AHERA inspectors recorded its location
in approximately 60 percent of the areas where the material was present. The location of boiler
insulation was universally recorded. In fact, TSI in mechanical areas was recorded more often
than in limited and general access areas.
With regards to assessment of ACBM, original AHERA inspectors assessed almost all
materials, and did so appropriately. Less than half the inspectors utilized the AHERA 1-7
assessment categories, but those who did use them generally applied them appropriately.
In conclusion, there are a few material types which are commonly unidentified by
original AHERA inspectors. Measurements of materials are commonly lower than 20 percent of
actual values. Numerous areas with materials present are not clearly recorded as such.
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4. MANAGEMENT PLAN EVALUATION
Research Area 2 seeks to evaluate Management Plans nationwide. The completeness,
up-to-dateness, and usability of Management Plans were determined by experts in order to
evaluate the level of knowledge and understanding of the AHERA regulation.
The question to be answered in Research Area 2 is, 'Do schools know and understand
the regulation, as shown by the completeness of the Management Plan and degree to which the
Management Plan has been kept up to date?' Expert review of Management Plans for
completeness and for the presence of selected up-to-dateness features was used to collect data to
answer this question. The data collection form for this effort was Form Ml, the Management Plan
Checklist. This form is presented in Appendix A.
Form Ml was based on the EPA's Key Elements Checklist, attached as Appendix G,
and was developed to standardize evaluation of the Management Plans collected for each of the
schools in the study. Three evaluation criteria were incorporated into the study checklist:
completeness, degree of up-to-dateness, and usability. A fourth evaluation criterion, correctness,
was considered but rejected as the time that had elapsed between the original AHERA inspection
and our reinspection made it impractical to use. Each of the three evaluation criteria and findings
associated with them are discussed in the following sections.
4.1 Completeness of Management Plans
The completeness of each Management Plan was determined through a series of
questions based primarily on the EPA's Checklist, with some minor changes and deletions. The
questions addressing completeness were grouped into sections similar to EPA's Checklist as
follows:
• General Inventory - Form Ml divided EPA's single general inventory question
into three questions: addressing the presence of an inventory; the inclusion of
the name and address of each building at a school; and whether each building
was identified as containing friable or nonfriable ACBM, assumed ACBM or no
ACBM (10 points total).
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• Exclusion/Inspection Information - Form Ml merged the EPA Checklist
questions about exclusions for those inspections conducted before December
14,1987 into a single section. This was done because much of the information
was substantially the same in these two sections of the EPA Checklist and to
equalize scoring among Management Plans, some of which would contain this
information, and some of which would not. One finding of this study is that
most inspections were entirely repeated for purposes of AHERA. The results
of previous inspections were used for general information only. The exclusion
for buildings built after October 12,1988 was not applicable to this study as this
type of building was not included in the evaluation. Descriptions of response
actions taken prior to December 14, 1987 were not evaluated. A final question
was asked in Form Ml, the study Checklist, to determine whether the method
used to determine the sampling location of each bulk sample was provided (70
points total).
• Response Action Recommendations - Form Ml merged the EPA Checklist
questions for response action recommendations and response actions into a
single section. It did not collect data on the inclusion of reasons for selecting
each response action or preventive measure as analysis of this information was
not planned (30 points total).
• Activity Plans - Form Ml merged the EPA Checklist questions for activity
plans and notifications into a single section. The only differences between the
two Checklists were that the study included initial cleaning recommendations as
a required element (AHERA also required an initial cleaning), and did not
differentiate between written steps for notification and the actual notifications
themselves (39 points total).
• Resource Evaluation - Form Ml expanded on the EPA Checklist question
about the presence of a resource evaluation to include a question asking
whether all recommended activities were included in that resource evaluation
(10 points total).
• AHERA Designated Person - Form Ml merged the EPA Checklist questions
for the designated person and designated person sign-off. The optional
Management Planner sign-off was not addressed by this study (6 points total).
The EPA Checklist items "Assurance of Accreditation" and "ACBM Remaining after
Response Action" were not addressed by this evaluation. The first was an optional element, and
the expert technical consultants working on this project found the latter to be subject to such a
wide range of interpretations as to be difficult to grade uniformly.
Form Ml also differs from the EPA's Key Elements Checklist in that points are
assigned to the various completeness answers. The specific point values were determined based on
the expert judgment of Dale Keyes, Bill Ewing, and Steve Hays, consultants who worked closely
with Westat in the development and finalization of this form. The goal of awarding points for
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various answers was to establish a reasonable method of comparing Management Plans from
different schools. This goal was made more difficult due to the fact that some Plans relied on
previous inspections or other methods to allow them to exclude otherwise required information
from their original AHERA inspection report. Clearly a Management Plan following this aspect of
AHERA should not be penalized. Similarly, Plans that do not contain exclusion or previous
inspection information should not be viewed as incomplete for not availing themselves of this
element of AHERA. The prevalence of Plans with "Not Applicable" scores to specific questions is
shown throughout the tables in this section. The overall scoring algorithm handles "Not
Applicable" codes not by penalizing but by crediting the actual score and maximum point potential.
The approach we selected to resolve concerns about differing maximum possible
scores was to compare each overall completeness score with the theoretical maximum for a Plan
that contained and excluded the same AHERA-allowed elements. All scores were then
normalized to a 1-100 scoring system.
Table 4-1 shows the actual normalized scores for Management Plans in this study.
The first column in this table presents the overall scores, while each additional column presents the
range of scores for the subsections within the completeness scoring plan. All point scores for
actual normalized scores are rounded to the nearest number divisible by 10.
Table 4-1 shows that completeness scores were generally high [80% (.+ 6%) were 75
or above], as should be expected given the itemized requirements of AHERA combined with the
state reviews that have occurred since the initial plan submittals. Notable, however, is the fact that
over five (+. 4%) percent of the Plans, even with detailed AHERA guidelines and state reviews,
received an overall normalized score of 64 or below, grossly incomplete by almost any definition.
In both the relatively complete and relatively incomplete Management Plans, points were most
commonly lost for items which were not clearly defined in AHERA, or where state-required
AHERA forms and checklists failed to prompt for the specific information item. Figure 4-1 shows
graphically the distribution of overall scores.
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Table 4-1. Percent of Management Plans awarded various normalized scores for completeness points for Form Ml
%of
points
95-100
85-94
75-84
65-74
55-64
45-54
35-44
25-34
16-24
6-15
0-5
Total
Average per-
cent awarded
% of overall points
in this subsection
Percent of Management Plans awarded points
Overall
1%
41%
37%
15%
3%
<1%
2%
X
X
X
X
100%
51%
AM
Subsection
General
Inventory
72%
11%
2%
11%
1%
<1%
X
X
X
X
2%
100%
92%
6%
Exclusion/
Inspection
Information
3%
23%
33%
25%
11%
4%
X
X
X
X
X
100%
Response
action re-
commendation
44%
16%
20%
3%
1%
1%
X
X
X
X
15%
100%
77%
41%
77%
IB%
Activity
plans
11%
40%
25%
10%
3%
2%
3%
<1%
2%
X
3%
100%
79%
24%
Resource
evaluation
52%
X
25%
X
16%
1%
X
X
X
X
6%
100%
82%
6%
AOP
58%
X
23%
10%
X
4%
X
2%
X
X
3%
100%
86%
4%
M
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Figure 4-1 Normalized overall completeness scores for Management Plans
Percent with score
40
50
60 70 80
Normalized overall score
100
The average total overall normalized completeness score was 81 points (+. 2%). As
has previously been mentioned, the completeness portion of Form Ml was divided into six
subsections. Each of these subsections is discussed on the following pages.
General Inventory
A total of 10 points was available to be awarded in the General Inventory subsection
of Form Ml. The General Inventory subsection addressed the presence of an inventory; the
inclusion of the name and address of each building at a school; and whether each building was
identified as containing friable or nonfriable ACBM, assumed ACBM, or no AC8M. Appendix F,
Management Plan Completeness Item Results, shows the percent of Plans that were awarded each
point score for all of the questions on Form Ml, including those in the General Inventory
subsection. The problem most frequently found was that Management Plans did not indicate which
school building contained friable ACBM, nonfriable ACBM, assumed ACBM, or no ACBM.
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Table 4-1 (page 4-4) shows the normalized scores for answers to questions in the
General Inventory subsection of Form Ml. This table shows that, at 92 percent (.+. 4%), the
average percent complete of the General Inventory subsection was significantly above that for the
normalized average percent of points.
Exclusion/Inspection Information
The Exclusion/Inspection Information subsection of Form Ml contained a maximum
total of 70 points and was the single most important area for completeness on the form. This
subsection asked questions about the presence of exclusion/inspection information, including
locations and quantity of homogeneous materials, method of bulk sample collection, and analysis.
Table 4-1 shows the percent of respondents awarded various points for each score.
One hundred percent of Management Plans contained some information on
exclusions and/Or inspections, and a large majority of Plans received the maximum possible
number of points for many specific questions on Form Ml. For instance, 79 percent (±.6%) of
Management Plans contained all required assessments, although some Plans treated undamaged
TSI as nonfriable and, thus, did not assess those materials. (Positively, many Management Plans
assessed all materials regardless of friability, but this information was not captured in Form Ml.)
Focusing now on the specific questions in the Exclusion/Inspection Information
section where fewer than 70 percent of Management Plans received the maximum point score, the
following areas of frequent incompleteness emerge.
Locations of homogeneous areas. Only 58 percent (±_ 9%) of Management Plans
show the locations of all of the homogeneous areas in the building. These locations
were commonly not clearly described, especially where a material was present in
numerous locations within a building. Only 52 percent (.+. 13%) of Plans show the
approximate square or linear footage of all homogeneous areas.
Identification of material type. Fifty-five percent (±11%) of Plans did not categorize
homogeneous materials as TSI, surfacing material, or miscellaneous material in all
areas. Many of these Plans did, however, identify materials using more conversational
or descriptive terms such as VAT, or breaching.
Bulk sample locations. Seventy-six percent (±_ 8%) of Plans did not describe the
method of bulk sample location determination for any area in the school. Moreover,
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only 18 percent (.+. 6%) of Management Plans presented this information for all
sampling locations. Although most Plans contained a textual description of how bulk
sample locations were supposed to be selected, few showed how those procedures
were applied to a specific material.
TSI and bulk samples. Only 67 percent (+. 10%) of Plans described using a method
of determining sample locations fully or substantially in accordance with AHERA for
TSI. Performance on surfacing materials was even worse at 42 percent (+. 8%).
These numbers may not reflect actual field practices, however, as many Management
Plans simply do not describe the method of sampling used.
Date of analysis of bulk samples. Thirty-one percent (± 11%) of Plans present all
bulk sample results without a date of analysis.
Assessor of ACBM. Only 68 percent (±_ 8%) of Plans contain a signature of the
assessor of friable ACBM, and only 51 percent (+. 10%) show the date of such a
signature. In both cases, 15 percent (+. 4%) of Plans were ineligible to respond to
these questions.
Some other general weakness discovered by our reviewers include the following:
• Inspector signature and date were frequently missing from both sampling and
assessment records. This was primarily a result of using standardized field
forms which do not ask for these items. In the case of teams, this lack of
prompts makes it impossible to determine which person collected a sample and
which person made a material assessment.
• When previous inspection results were used in the original AHERA inspection,
the AHERA requirements were not usually met, e.g., materials were not given
homogeneous area identities, or bulk sampling information was not shown to
meet AHERA requirements.
• Materials for which bulk sampling analyses were negative for asbestos were
frequently not treated fully as homogeneous areas, e.g., they were not
quantified and locations were not specified.
• Some laboratories indicated a laboratory identification number on their report
with no reference to NVLAP or documentation of NVLAP accreditation.
Table 4-1 (page 4-4) shows the range of percent of points awarded for the
Exclusion/Inspection Information subsection of Form Ml. The scores awarded for this subsection
are remarkably similar to those awarded as overall scores. The average percent of points awarded
in the Exclusion/Inspection information subsection was 77 percent (+. 3%).
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Response Action Recommendations
The Response Action Recommendation subsection of Form Ml has a maximum of 30
pre-normalization points. Response action recommendations were almost always made for friable
materials determined to be ACBM.
Over 80 percent (±4%) of Management Plans contain some written
recommendations to the LEA for responding to all friable ACBM and all TSI. Given that 13
percent (± 3%) of Plans' answers to this question were not applicable, this is a particularly
encouraging finding. Twenty-six percent (+. 8%) of recommendations to LEAs for response
actions have no date. This is an omission.
Only 54 percent (+. 10%) of recommended response actions contain a recommended
schedule for beginning and ending all response actions. This is a relatively serious block to
completeness and can lose a Management Plan as many as five pre-normalized points. Some
Management Plan preparers put the burden of specifying schedules on the LEA, though the
Management Plan is required by AHERA to contain a schedule.
The large number of Plans scoring 80 percent (+. 6%) or better for the Response
Action Recommendation subsection (shown in Table 4-1, page 4-4) reflect the relatively complete
performance of Management Plans like those included in the study, in this subsection. By contrast,
15 percent (+. 4%) of Plans were awarded no points for this subsection. The average percent of
possible points awarded for this subsection is 77 (+. 4%).
Activity Plans
A total of 36 pre-normalization points maximum are available to be awarded in the
Activity Plan subsection of Form Ml. This makes it the second most heavily weighted subsection
after Exclusions/Inspection Information. Required activity plans were generally present in
Management Plans. They tended however to be standardized inserts that were not specific to the
school/building.
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Specific areas of the Management Plans that were weak include:
Initial and additional cleaning. Only 58 percent (+. 8%) of Management Planners
noted AHERA-required initial cleaning and discussed whether additional cleaning
was recommended. This occurred despite the fact that credit was given if this
cleaning was discussed in the O&M Plan. LEA written response to the cleaning
recommendations was frequently missing or lacking in a signature.
Notification. Thirty-one percent (+. 10%) of Management Plans did not describe the
steps by which workers and building occupants were notified about post-response
action activities including periodic surveillance and reinspections.
With regard to notification, a very generous scoring methodology was used for scoring
in this area. Even if a Management Plan contained no reference to notification, full points were
awarded if a copy of an actual notification or sample notification was included in the Management
Plan delivered to Westat. Using this definition of presence, most Management Plans contained
steps (or actual notifications) for announcing availability of the Management Plan. Points were
lost if the notification plan did not contain provisions for identifying response actions,
inspections/reinspections, and post-response actions. Some people argue that notification of
Management Plan availability satisfies the latter requirement.
Table 4-1 (page 4-4) presents the normalized scores for the Activity Plans subsection.
The average score was 79 (+_ 5%), though 11 percent (+_ 6%) of Management Plans were awarded
50 percent or fewer of the points possible for this subsection.
Resource Evaluation
The maximum number of non-normalized points awarded for the Resource
Evaluation subsection of Form Ml was 10. Resource evaluation was interpreted in two distinct
ways: one was the itemization costs associated with recommended asbestos activities over a given
time period, and the other involved the presence of statements about the school's plans for funding
the specified asbestos activities. Both were accepted in the scheme of the checklist scoring. Only
six percent (+, 6%) of Plans did not contain some evaluation of resources needed to carryout
ongoing asbestos-related activities in the school.
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Forty-two percent (+. 12%) of Management Plans did not take all recommended
response actions into account when performing the resource evaluation. Points were deducted if
even a few activities were not considered in this process, e.g., removal costs were commonly given
with no O&M or reinspection costs itemized.
Table 4-1 (page 4-4) presents the percent of Management Plans awarded various
percents of maximum points for this subsection. The average score was 82 percent (+. 7%).
AHERA Designated Person (ADP)
The ADP subsection of Form Ml presents Management Plan completeness with
regard to the AHERA designated person. The maximum number of non-normalized points for
this subsection was six.
Most Management Plans listed the pertinent information required for the AHERA
Designated Person. In 21 percent (+. 8%) of Plans, training received by the ADP was omitted and
in 28 percent (+. 10%) of Plans someone other than the ADP signed off that LEA responsibilities
under AHERA had been met. The lack of training information may reflect a lack of training or
merely a deficiency in reporting.
Table 4-1 (page 4-4) shows the percent of points awarded for the ADP subsection of
Form Ml. Only 19 percent (+. 9%) of Management Plans received less than 80 percent of the
points possible for this subsection. The average score was 86 percent (+_ 5%).
42 Up-to-Dateness
Research Area 2 also studied the up-to-dateness of Management Plans. Management
Plans are intended to be "living documents" and, as such, should have new asbestos related records
inserted into them as they are generated. The EPA Key Elements Checklist presents a number of
required records which should be included in the Plan, as available. Since the volume of these
records is sometimes large, it was decided to request only one of these required update records to
determine how current the school's records are. The degree of up-to-dateness of each Plan was
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evaluated by asking if clearance air monitoring results were submitted to Westat with the Plan and
response actions requiring clearance testing had been done. At the time each Plan was collected
from the school, ADPs were specifically asked to provide "copies of AHERA clearance air
monitoring results for response actions completed, including identification of areas cleared."
Answers to this question were compared to the ADP's answers to questions about the occurrence
of response actions in the school. Table 4-2 presents the percent of Management Plans in which
air monitoring results were found.
Table 4-2. Percent of Management Plans containing AHERA-required clearance air monitoring
results
Availability of air monitoring results
Air monitoring results available/
response action occurred1
Air monitoring results available/
no response action occurred
Air monitoring results not available/
response action occurred1
Percent of
Management Plans
38%
6%
56%
N = 55,907
Occurrence of response action was determined by presence of Form Wl for school.
Table 4-2 shows that while 6 percent (+. 5%) of Management Plans contain air
monitoring results that are not mandated by AHERA, 56 percent (+. 11%) of Plans are not kept
sufficiently up-to-date to include this important element. Three explanations for this are possible.
One is that air monitoring records are not kept with the Management Plan showing that the plan is
not up-to-date. The second is that some Plans were photocopied incorrectly, while the third, more
serious explanation is that AHERA required air monitoring may not have occurred at the time of
a response action. There is no way to determine the relative importance of these three
explanations for the poor performance of Plans on up-to-dateness.
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43
Usability of Management Plans
The third evaluation criterion was usability of the Management Plan. By usability we
mean factors which ease use of Management Plans as reference manuals and planning documents.
The EPA does not address usability in its Checklist, but acknowledges that the large amount of
information required in a Plan can be confusing to the lay person. Westat developed the concept
of usability in an attempt to assess factors which make information in a Management Plan easier
or more difficult for the reader to understand. These factors include whether materials can be
tracked through the Management Plan; document formatting points such as numbered pages,
summaries, table of contents, definitions, floor plans, etc.; and correct and consistent use of
AHERA terms such as homogeneous area, functional space, random sampling and exclusion. The
study Checklist also evaluated usability by analyzing what groups of people (based on
characteristics of education level, knowledge of building, and asbestos survey experience) would be
able to understand and use the Management Plan.
The first aspect of the effort to determine Management Plan usability looked at
specific features that would ease use of a Management Plan. Table 4-3 presents the results of this
portion of the usability analysis.
Table 4-3. Percent of Management Plans containing various features that increase usability1
Usability features
1.
2.
3.
4.
5.
6.
7.
8.
9.
Basic Table of Contents
Detailed Table of Contents
Headings for Table of Contents used
consistently in text
Numbered pages
Contains definitions section
Narrative that describes sections
Asbestos Control Program Organization Chart
Diagrams or floorplans showing sampling
locations, homogeneous areas, or ACM
Other items - includes lists of abbreviations,
tabbed section dividers, etc.
Yes
77%
36%
74%
62%
36%
46%
10%
59%
40%
No
23%
64%
26%
38%
64%
54%
90%
41%
60%
N = 83,840
1 Respondents may have listed more than 1 feature, therefore column totals add to more than 100%.
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While none of these elements is required by AHERA, all, with exception of the
Program Organization Chart and diagrams or floorplans are standard organizational and
presentational techniques used by writers of reports to facilitate use of a document. Yet many
Plans missed each of the following elements: 23 percent (+. 13%) missed the basic table of
contents, and 64 percent (+. 10%) missed the detailed table of contents and definition section.
Table 4-4 shows the percent of Management Plans that contained various
combinations of the first seven elements listed above. This table shows that none of the
Management Plans utilized all seven elements and that 24 percent (+. 13%) utilized only one or
none of these presentational techniques.
Table 4-4. Percent of Management Plans containing usability elements 1 - 7
Number of usability elements
No elements
1 element
2 elements
3 elements
4 elements
5 elements
6 elements
7 elements
Percent
7%
17%
10%
12%
19%
20%
15%
0%
N = 83,840
Other interesting insights into the usability of Management Plans are provided by
Table 4-5. This table shows the rate of occurrence of various features that detract from the
usefulness of Management Plans. As this table shows, that although each detracting feature
occurred relatively infrequently, in total 69 percent (+. 9%) of Plans overall had one or more
features that detract from their ease of use. In addition to the factors listed in Table 4-5, factors
include inspection report unclear, negative homogeneous areas not being quantified and not
assessing ACBM using AHERA categories.
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Table 4-5. Percent of Management Plans where features that decrease usability were present
Features that decrease usability
Standard forms such as state forms are used
but not explained
Problem with presentation of homogeneous area
information, (i.e., areas not numbered, or
inconsistent descriptions)
Floorplans are poor or lack keys
Computerized data not explained
Other problems
Yes
16%
13%
5%
5%
31%
No
84%
87%
95%
95%
69%
N = 83,840
A second important element in Management Plan usefulness is the consistent and
clear use of AHERA-defined terms such as homogeneous area and functional space. Table 4-6
presents the percent of Management Plans like those studied using various terms correctly.
Table 4-6. Percent of Management Plans using AHERA-defined terms correctly
AHERA-defined terms
Homogeneous area
Functional space
Exclusion
Random sampling
Yes
87%
44%
81%
82%
No
13%
56%
19%
18%
N
83,840
74,301 *
31,021 i
74,055 i
1Some Management Plans did not use this element
While only 13 percent (+. 6%) of Management Plans did not use the term
homogeneous area correctly, 56 percent (+. 9%) did not use the term functional space correctly.
With even one of these two key terms misused, it is hard to imagine that an inspection fulfilled the
requirements of an AHERA inspection as each of these terms is central to the AHERA inspection
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process. AHERA requires that material be sampled on the bases of its homogeneous area, while
it is assessed within its functional space. The concepts of exclusions and random sampling are also
important elements in AHERA, and yet 19 and 18 percent respectively of Management Plans used
these terms incorrectly.
Table 4-7 presents the percent of schools which defined a specific number of terms
correctly. This table also includes all "Not Applicable" responses as correctly defined terms. A
"Not Applicable" response may have been used if a school relied on earlier inspection results or if
for example, no suspect material was found in the school. A total of 37 percent (.+. 9%) of schools
defined all four terms, homogeneous area, functional space, exclusion, and random sampling
correctly. Only 1 percent (±_ 2%) of schools defined no terms correctly.
Table 4-7. Percent of schools which defined Management Plan terms correctly
Number of terms
defined correctly
4
3
2
1
None
Percent of
schools
37%
46%
12%
4%
1%
N - 83,840
The single most subjective element in our efforts to determine Management Plan
usability was in the analysis of the level of education and other components of background
required to easily make use of a Management Plan. By ease of use we mean use without training.
The findings presented in this table are troubling given that maintenance workers, custodians, and
parents of all educational levels are three of the primary intended users of Plans. Taking into
consideration ease of writing style and organization, consistency of presentation, frequency of use
of abbreviations and clarity of their definition, our Management Plan reviewers did make this
judgement. Table 4-8 presents the results of this effort.
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Table 4-8. Percent of Management Plans usable and understandable without instruction, by
persons of various educational attainments
Level of education
Less than high school diploma
High school diploma
More than high school diploma
Requires instruction to use
Percent of
Management Plans
5%
34%
39%
22%
N = 83,840
This table shows that 39 percent (.+. 5%) of Management Plans are judged to be
appropriately written for persons with some college background, and that an additional 22 percent
(± 6%) of Management Plans could only be used by persons who had received instructions in how
to use it, no matter what their educational level.
Similarly, Table 4-9 presents our reviewers attempts to judge the ease of use of Plans
by persons who know the school well. These persons would include custodians and the principal.
An additional evaluation was made to determine how easy each Plan would be for persons with
AHERA inspection experience who do not necessarily have prior knowledge of the school building
to use. Such persons include consultants hired to do remediations and state enforcement
personnel.
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Table 4-9. Percent of Management Plans judged easily usable without prior instruction, by
different types of persons
Potential Management Plan users
Persons with a knowledge of the
school building
Persons with AHERA asbestos
inspection experience
Usability
By all
people
7%
28%
By most
people
39%
48%
By some
people
39%
20%
N
By none/few
people
16%
5%
= 83,840
This table shows that 16 percent (+. 5%) of Plans would currently not be usable, or be
usable only by a few persons knowledgeable about the school building, and 39 percent (+, 8%) of
Management Plans would be understandable by some of these people. This means that 55 percent
(± 7%) of Management Plans would be understandable by less than half of people knowledgeable
about the building.
Table 4-9 also presents our expert's judgement as to the usability of Management
Plans by persons with a background in AHERA inspections. On the whole these persons were
assumed to be knowledgeable about asbestos inspections, and AHERA terminology and
requirements. The table shows that even for this knowledgeable audience 5 percent (±4%) of
Plans would be understandable by few to no users. Twenty percent (±5%) of Plans would not be
easily understood by less than half of persons with AHERA inspection experience. The fact that a
greater percentage of persons with AHERA experience would be able to use Plans than those with
knowledge of the building, suggests that Plans tend to be more deficient in explaining AHERA
terms and requirements than in describing buildings, locations, and materials.
4.4
Summary
Management Plans nationwide were evaluated in Research Area 2. Three evaluation
criteria were used: completeness, degree of up-to-dateness, and usability. Insights into all three
4-17
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areas were found in the evaluation, leading to the conclusion that Management Flans are, on the
whole, reasonably complete, kept moderately up-to-date, and rather disappointingly difficult to
use.
The completeness of each Management Plan was generally high, with 80 percent
(± 6%) of the Plans receiving a normalized score of 75 or higher. However, 5 percent (+. 4%) of
Management Plans received an overall normalized score of 50 or below, making it clear that these
Plans, even with Federal and State guidelines, were substantially incomplete. Categories of items,
based primarily on the EPA's Checklist, were analyzed to determine completeness.
The second criterion, degree of up-to-dateness was studied by looking at whether or
not clearance air monitoring results were submitted with the Management Plan. Significantly, 56
percent (±11%) of Plans which should have, do not contain this element. This may be due to a
photocopying error, the fact that air sampling may not have occurred at the time of a response
action, or as it relates to up-to-dateness, air sampling results may not be filed with the Plan.
The last criterion, usability, was felt to be important in determining how useful a Plan
would be and whether or not those who need to would be able to rely on the Plan as a reference.
This analysis looked at features which would ease use of a Management Plan, such as table of
contents, page numbering, and floorplans showing sampling locations, homogeneous areas, or
ACM. Also evaluated were various features which decrease usability, such as computerized data
not explained, or problems with the presentation of homogeneous area information. Sixty-nine
percent of Plans had one or more features that detract from ease of use. Four highly significant
AHERA defined terms were defined correctly in 37 percent (.+. 9%) Management Plans, while
exactly 3 of the 4 were defined correctly in 46 percent (+. 12%). The final element used in our
efforts to determine Plan usability was an attempt to determine the percentage of Plans usable and
understandable by persons of various educational attainments. We found that 39 percent (_±. 5%)
of Plans are written for persons with some college and that an additional 22 percent (+. 6%) could
be used only by people who had instructions in use.
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5. RESPONSE ACTION EVALUATION
The objective of Research Area 3 was to ascertain the types of response actions
conducted by schools and evaluate both their quality and appropriateness. Three specific
research questions were addressed:
• What response actions were recommended in the Management Plans?
• Are the recommended response actions appropriate, given the assessed
condition of the asbestos?
• Have the response actions performed in the school building been done
properly?
Data were collected for the first two questions through an evaluation of each
sampled school's Management Plan. The third question required analysis of data from the
reinspection of the school as well the Management Plan.
5.1 Response Actions Recommended in Management Plans
The first research question studied in Research Area 3 is, 'What response actions
were recommended in the Management Plans?' A comprehensive review of the Management
Plans for all response actions recommended for ACBM discovered during the original
AHERA inspection provided the data to address this question. Table 5-1 summarizes the
types of response actions recommended in the Management Plans, as projected from the
sample of 197 schools to the national population of schools like those in the survey. It is
important to keep in mind that this analysis addresses only recommended response actions;
the analysis of response actions actually performed appears in Section 5.3. All of the
information presented in this chapter is based on the estimated 83,840 schools nationally that
had performed an AHERA inspection, found asbestos-containing materials, and wrote a
Management Plan. An estimated 302,001 response actions were recommended in the
Management Plans, the vast majority of which were operations and maintenance (55%) or
repair of damaged area (33%). Only 10 percent of the recommended response actions
involved removal of some or all of the ACBM.
5-1
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Table 5-1. Estimated numbers and percentages of recommended response actions by
asbestos material type
Recommended Response Action
Operations & Maintenance
Repair Damaged Area
Remove Damaged Area
Remove All Material
Encapsulate
Remove Severely Damaged
Asbestos Material,
• Repair Minor Damage
Enclosure
All Response Actions
Asbestos Material Type
Miscellaneous
Number
111,996
2,636
1,663
3,247
635
524
307
121.003
Percent (1)
93%
2%
1%
3%
1%
<1%
<1%
100%
Surfacing
Number
3,677
1,183
1,700
2,138
1,069
0
0
9,787
Percent (1)
38%
12%
17%
22%
11%
0%
0%
100%
TSt
Number
50,642
95,474
8,634
6,467
2,149
5,468
2.392
171,226
nftvftf*n» H\
KOTCOm (1)
30%
56%
5%
4%
1%
3%
1%
100%
All
Materials
Number
166.315
99,293
11,997
11,852
3.853
5.992
2,699
302.001
Percent (1)
55%
33%
4%
4%
1%
2%
1%
100%
(1) Percentages may not add exactly to 100%, due to rounding.
The distribution of recommended response actions varied with the type of
ACBM. Repair of damaged materials was recommended for 56 percent of the occurrences of
TSI. In contrast, operations and maintenance was recommended for miscellaneous materials
in 93 percent of recommendations.
Table 5-2 looks at the recommended response actions on a school basis, rather
than a material basis. To illustrate the information in Table 5-2: The response action
"remove damaged area" was recommended for miscellaneous ACBM in 1,053 school
buildings, which is one percent of the estimated 166,665 school building with miscellaneous
ACBM. Table 5-2 shows the same patterns of percentage as Table 5-1. In particular,
removals (partial or complete) were recommended in 11 percent of the 179,093 school
buildings with ACBM. One new finding in Table 5-2 is the number of schools with no
recommended response action, despite the presence of ACBM. Half of the schools with
miscellaneous ACBM have no recommended response action.
5-2
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PEER REVIEW DRAFT
Table 5-2. Estimated numbers and percentages of school buildings with different
recommended response actions by asbestos material type
Recommended Response Action
Operations & Maintenance
Repair Damaged Area
Remove Damaged Area
Remove All Material
Encapsulate
Remove Severely Damaged
Asbestos Material,
Repair Minor Damage
Enclosure
None
Buildings with AC8M In Category
Asbestos Material Type
Miscellaneous
Number
79,058
2,636
1,053
2.816
635
524
307
83.966
166,665
PerciHil
47%
2%
1%
2%
<1%
<1%
<1%
50%
100%
Surfacing
Number
3,677
1,183
1,700
1,728
1,069
0
0
830
9,705
Percent
38%
12%
18%
18%
11%
0%
0%
9%
100%
TSI
Number
36,621
57,643
5,517
5.879
990
3.844
2.392
2,265
96,396
Percent
38%
60%
6%
6%
1%
4%
2%
2%
100%
All
Materials
Number
92.519
59.834
7,643
9,458
2,156
4,369
2,699
52.811
179,093
Percent
52%
33%
4%
5%
1%
2%
2%
29%
100%
Note: Because two or more different response actions can be recommended In a given school, the numbers and
percentages do not add down the columns.
52
Appropriateness of Response Actions Recommended
The second research question undertaken in Research Area 3 studied whether
the recommended response actions "are appropriate, given the assessed condition of the
asbestos." Data were collected for this question through review of response actions
recommended in the Management Plans as evaluated by expert Management Plan reviewers.
A response action was considered to be appropriate if it was in accordance with AHERA
requirements.
In addition to evaluating the appropriateness of the recommended response
actions, the Management Plan reviewers also assessed whether or not the response action
went beyond the minimum requirements of AHERA and whether the recommended action
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was generic or specific. Examples of response actions that go beyond AHERA requirements
include removal of material in good condition and putting nonfriable material in an
operations and maintenance program. Response action recommendations were considered to
be specific if specific areas of material or rooms were indicated for repair, removal or careful
surveillance. Examples of specific recommendations are "remove damaged acoustical ceiling
material in Room 107" or "repair damaged pipe insulation to the left of the boiler." Response
actions were considered to be generic if, for example, they recommended removal of all
damaged material without indicating the locations of the damaged material Examples of
generic recommendations are "repair damaged pipe elbow insulation "or" enclose or
encapsulate damaged ceiling tile." Generic recommendations provided less useful guidance to
the subject school than specific recommendations.
Table 5-3 summarizes the findings on a material basis. Nearly all (98%)
recommended response actions were appropriate, i.e., in accordance with AHERA. However,
only 39 percent of the recommended response actions went beyond AHERA. While few (8%)
of the response actions for TSI went beyond AHERA, most (83%) of the response actions for
miscellaneous materials did so. A large percentage of these were the inclusion of floor tile in
an operations and maintenance plan. An estimated four-fifths of the recommended response
actions were generic, across all three material types.
Table 53. Characteristics of recommended response actions by material type
Response Action Characteristic
Appropriate
Beyond AHERA
Specific
Generic
Total recommended actions
Asbestos Material Ty
Miscellaneous
117,902
97%
99.939
83%
15,579
13%
105,428
87%
121,008
Surfacing
9,768
100%
2,514
26%
2,122
22%
7,645
78%
9,768
pe
TSI
168,418
98%
14,203
8%
42,704
25%
128,446
75%
171,523
All
Materials
296,088
98%
116,656
39%
60,405
20%
241,519
80%
302,299
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A similar picture emerges when one looks at the patterns across the materials
within a school building. Figure 5-1 displays the distribution of the number of response
actions recommended for a school building, among buildings with ACBM. Twenty-nine
percent of these buildings had no response actions recommended. Another 28 percent had
only one recommended action; this finding supports the finding that only 20 percent of
recommended actions were specific.
Figure 5-2 displays the appropriateness of the response actions within schools.
Nearly all are appropriate. The nation's school buildings divide nearly equally into buildings
in which all the recommended actions go beyond AHERA (29%), none of the actions do
(37%), and some but not all go beyond AHERA (35%). Most Management Plans (70%)
contain only generic recommendations for response actions.
These findings indicate that Management Planners generally follow the AHERA
regulations, but tend not to go beyond the minimal requirements of AHERA. It may be that
knowledge of the limitations of school budgets may restrain the Planners from recommending
more response actions than AHERA requires.
53 Evaluation of Response Actions Actually Undertaken in Schools
The first two research questions dealt with response actions recommended in the
Management Plans. The third research question in Research Area 3 is, 'Have the response
actions actually performed in the school been done properly?' This question was studied
during the building reinspection. As each response action reported or discovered by the
reinspector was found, a visual determination of the adequacy of the response action was
performed. No attempt was made to evaluate how a response action was carried out. In
particular, air monitoring and dust samples were not taken. Thus, only the results of response
actions were evaluated.
5-5
-------
Figure 5-1 Estimated number of recommended response actions by school building,
among buildings with ACBM
30% T
25% -•
20% - -
Percent of school buildings 15% -•
10% --
5% -•
0%
345
Number ot response actions
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Figure 5-2 Differences in characteristics of recommended
response actions within school buildings (percent of buildings
with indicated characteristics)
Some not appropriate (2%)
All appropriate (98%)
None beyond
AHERA (37%)
Less than half
beyond AHERA (19%)
All beyond AHERA
(29%)
At least half beyond
AHERA (16%)
Some generic,
some specific (15%)
All specific (15%)
All generic (70%)
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The definition of an adequate response action varies with the type of response
action. An enclosure was considered to be adequate if it appeared to be impact resistant and
airtight. Otherwise, it was considered to be inadequate. An encapsulation was considered to
be adequate if the material was laminated and formed a complete barrier. A removal was
adequately performed if all the material was removed; that is there was no visual evidence of
remaining material. Finally, a repair was adequately performed if the material was both
laminated and airtight.
Assessing response actions "after the fact" proved to be a particularly challenging
endeavor for the field personnel, primarily for two major reasons. First, there is a lack of
industry-wide procedures. The task of visually assessing response actions after the fact is not
a routine procedure. Although assessment guidelines were developed for this study,
inspectors were required to make conceptual judgements in the field with which they had little
or no experience. For example, a previous removal activity was to be judged by the inspectors
as complete or incomplete even when reinsulation or other replacement material had been
applied. Second, there is a lack of specific industry-wide definitions. Although response
actions are broadly defined in various documents, including AHERA documents, many
specific response actions may be classified into one or more of these definitions. For example,
covering floor tile with carpet may be viewed as an enclosure (albeit a potentially poor one),
or as an encapsulation with glue upon which carpeting has been laid. Various response
actions described as "repair" may fall into one or more of the remaining three response action
categories of removal, encapsulation or enclosure. In addition, many response actions
conducted by schools involved one or more response actions simultaneously, e.g., removal of
severely damaged material and repair of material with only minor damage. Although specific
actions were classified into one of the four categories for the purpose of this study, school
personnel did not always use those same classifications. Further, many school personnel,
during the ADP interviews, described response actions applied to materials that were later
found to be non-ACBM. For example, ceiling tiles were frequently reported to have been
removed during pipe insulation removal. Although the ceiling tiles were most likely properly
removed as asbestos-contaminated materials, they were deleted from the list of materials
upon which response, actions were implemented for the purposes of this study's analysis.
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Reviews of Management Plans and interviews with ADPs resulted in 696
reported response actions in the sample. Of these, 632 could be confirmed by the reinspection
personnel. (An example of an unconfirmed action is a situation in which a specific repair was
reported in a specific area, but the re-inspector could find no evidence of a repair in that
room.) Application of the statistical weights yields an estimated 274,970 response actions
performed in school buildings, nationwide. Ninety percent, 246,260 response actions, could be
confirmed in a reinspection. The findings presented here apply only to confirmed response
actions.
Table 5-4 presents the findings on the numbers and adequacy of response actions,
by response action category and material type. An estimated three-fourths of the response
actions (181,076 actions) have been removals.
Most response actions (87%) were deemed to have been adequately performed,
both overall and for most combinations of material type and action categories. There are,
however, significant exceptions to this general statement. Only 3 percent of enclosures were
considered adequate. Nearly half of the response actions applied to miscellaneous materials
were considered inadequate, including all of the enclosures and repairs.
Tables 5-5 and 5-6 look at response actions on a building basis, by adequacy. An
estimated 37,673 school buildings (21 percent of all school buildings with ACBM) have had
visually confirmable response actions. Further, 28,870 buildings, 16 percent of buildings with
ACBM, have removals of some or all of the ACBM. Inadequate response actions were found
in only 17 percent of school buildings.
5.4 Summary
This section presents a brief summary of the findings with respect to response
actions. The most common response action recommended in the Management Plans was
operations and maintenance, followed by repair of damaged material. Eleven percent of the
Management Plans recommended removals of some or all of the ACBM. While nearly all
recommended response actions were appropriate, only 39 percent went beyond what was
required by AHERA. Further, only 20 percent provided specific remediation
5-9
-------
Table 5-4. Adequacy of response actions performed, by material type and response action category
Material Type
TSI
Surfacing
Miscellaneous
All Materials
Response Action Category
Enclosure
Number
of Actions
2,823
0
16,617
19,440
Percent
Adequate
19%
0%
0%
3%
Encapsulation
Number
of Actions
20,689
7,895
489
29,073
Percent
Adequate
92%
97%
100%
94%
Removal
Number
of Actions
140.541
5.792
34.743
181.076
Percent
Adequate
100%
100%
77%
96%
Re
Number
of Actions
15,949
0
721
16,670
iair
Percent
Adequate
82%
0%
0%
78%
All Response
Action Categories
Number
of Actions
1 80. 003
13,687
52.570
246,260
Percent
Adequate
96%
98%
52%
87%
Note: Actions involving less than 3 square feet or 3 linear feet of ACBM are excluded in accordance with AHERA regulations.
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PEER REVIEW DRAFT
Table 5-5. Differences in adequacy of response actions performed In school buildings, by
action
Response Action Type
Enclosure
Encapsulate
Remove
Repair
All Action Types
Number of School Buildings
Percent of Adequate Actions
0%
1,994
526
0
2,391
2,122
1% to 99%
524
654
244
0
3,992
100%
0
6,037
28,626
7,869
31,559
All
Actions
2,518
7,217
28,870
10,260
37,673
Response Action Type
Enclosure
Encapsulate
Remove
Repair
All Action Types
Percent of School Buildings
Percent of Adequate Actions
0%
79%
7%
0%
23%
6%
1% to 99%
21%
9%
1%
0%
11%
100%
0%
84%
99%
77%
84%
All
Actions
100%
100%
100%
100%
100%
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Table 5-6. Differences In adequacy of response actions performed In school buildings, by material
type
Asbestos Material Type
TSI
Surfacing
Miscellaneous
All Materials
Number of School Buildings
Percent of Adequate Actions
0%
1,008
0
1,922
2,122
1% to 99%
2,939
219
555
5,992
100%
30,343
3,389
4,386
37,559
All
Actions
34,290
3,608 •
6.863
37,673
Asbestos Material Type
TSI
Surfacing
Miscellaneous
All Materials
Percent of School Buildings
Percent of Adequate Actions
0%
3%
0%
28%
6%
1% to 99%
9%
6%
8%
11%
100%
88%
94%
64%
84%
All
Actions
700%
700%
700%
700%
5-12
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PEER REVIEW DRAFT
recommendations; 80 percent provided generic recommendations, limiting their utility to the
subject schools.
An estimated 246,000 response actions have been performed in nearly 38,000
school buildings. Eighty-four percent of the response actions were adequately performed, as
determined by visual inspections. However, very few enclosures were deemed adequate.
Removals were performed in 16 percent of school buildings.
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6. ORIGINAL AHERA INSPECTION EVALUATION
The objectives of Research Area 4, Original AHERA Inspection Evaluation, were to
evaluate the original AHERA inspection in each school building and to explore possible
associations between the quality of the inspections and the inspectors' backgrounds. A telephone
survey of the original AHERA inspectors was conducted to collect data on the inspectors'
backgrounds.
It is important to note that the analysis presented in this chapter is an evaluation of
the original AHERA inspection, not just the original AHERA inspector. The quality of an
inspection clearly depends on the ability of the inspector to conduct a thorough and accurate
inspection. However, it also depends on the size and complexity of the school building, the policies
and procedures of the inspector's employer, as well as any limitations that may have been imposed
by the LEA. Even a good inspector is more likely to err, for example, in a large building built in
stages over many years than in a small building. Inspection companies determine policies that can
influence the quality of their employees' work. For example, if an employer rewards its inspectors
more for working quickly than for conducting thorough inspections, the inspectors will tend to cut
corners in order to get the job done fast. In addition, the data for the inspection evaluation were
taken from Management Plans, which are often prepared by the inspection companies using pre-
prepared and automated outlines and report shells. These outlines and shells tend to induce
uniformity in the types of data reported and the manner in which the data are reported. If, for
example, a form is missing some aspect of an original AHERA inspection, then the inspection is
almost certain to be missing this aspect. Finally, we have been told that LEAs occasionally limit
the parts of the school or the range of material types to be inspected.
This chapter first describes and gives the rationale for the system developed to score
the original AHERA inspection. Statistics on the performance of the original AHERA inspections
relative to this yardstick are then presented. Descriptions of the original inspectors' education and
experience are then presented. Finally, statistical measures of the association between
characteristics of the original inspectors' backgrounds and the original AHERA inspection score
are presented.
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6.1 Scoring the Original Inspection
The Westat project team, in consultation with the expert consultants Dale Keyes,
William Ewing, and Steven Hays, and the EPA, developed a scoring system to evaluate the original
AHERA inspections. The system began with a score applied to every homogeneous suspect
material identified in the reinspection. The material score evaluated how well the original
inspector performed with respect to each individual material The individual material scores were
then aggregated into an overall school inspection score to provide an overall evaluation of the
inspection of the school.
6.1.1 Scoring Individual Materials
The project team and consultants identified six factors that measure dimensions of the
quality of the inspection and ranked them in their order of importance. The factors may be stated
as questions requiring "Yes" or "No" answers. In descending order of importance (in the research
team's professional judgment), the six factors are as follows.
1. Was the suspect material identified?
This factor measures the ability of the original AHERA inspection to find and report
all suspect homogeneous materials in a building. The research team ranked this
factor first because, if an original AHERA inspector failed to identify a particular
homogeneous material, then the other five factors would be irrelevant. Credit was
given if a material identified during the reinspection was reported, in any manner, in
the original AHERA inspection report. Extreme care was taken to account for
individual differences in inspection terminology, protocol, or reporting format, e.g.,
some inspections combined pipe run and pipe joint insulation as TSI or combined
9"x9" and 12"xl2" floor tile as VAT (vinyl asbestos floor tile).
2. Was the material assessed appropriately?
This factor measures the ability of the original AHERA inspection to provide an
assessment for each homogeneous material. Reporting assessment information, in
some manner, was ranked second in importance because it directly relates to the
potential for fiber release. Credit was given for a friable asbestos-containing material
if it was assessed in terms of amount of damage to the material. Many original
AHERA inspection reports assessed materials using additional criteria, such as
location, quantity, and occupancy, but these were not considered in awarding credit
for this score factor as AHERA does not require their use.
6-2
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AHERA does not require the assessment of nonfriable and nonasbestos materials;
points were automatically awarded for these materials.
As time had passed since the original AHERA inspection, a comparison of Westat
assessments to the original AHERA inspection assessments was not made because
they would be invalid.
3. Did the inspector identify at least 80 percent of the areas in the school with the
material?
This factor measures the ability of the original AHERA inspection to report all the
areas or rooms in a building where a suspect homogeneous material is present. This
information gives guidance to building occupants on where it is necessary to take
precautions against potential exposure to asbestos. Credit was given if the original
inspection reported a material to be present in at least 80 percent of the areas in
which re-inspectors found the material The 80 percent cutoff allowed for some
difference in area description between the two inspection reports. Original AHERA
inspection floorplans, tables, and text were all reviewed to determine areas where
materials were reported. Where there was reasonable doubt, such as material in
closets or restrooms in classrooms which were reported, the original AHERA
inspection was given credit for having found the material in that area.
This scoring procedure did not result in lost credit points for areas where asbestos
materials had been totally removed or otherwise abated, as re-inspectors would have
either not found the material or reported the replacement material.
4. Was at least 80 percent of the material quantified?
This factor measures the ability of the original AHERA inspection to report an
accurate quantity of each suspect homogeneous material in a building. Credit was
given if the original AHERA inspection reported a total quantity of a particular
material at least 80 percent of the total quantity found by the re-inspector. The 80
percent cutoff allowed for some variance in measurement and estimation. The total
quantities of each material in the building were compared, and not the quantities in
each individual area, since many original inspections reported only building totals.
In cases where a significant quantity of a material had been removed or otherwise
abated, the re-inspector would have found either less material or the same quantity of
a replacement material, and the original AHERA inspection did not lose credit.
5. Were the correct number of bulk samples taken?
This factor measures the ability of the original AHERA inspection to collect at least
the minimum number of bulk samples specified by AHERA for each homogeneous
material. Credit was given if the inspection assumed a material contained asbestos.
Credit was also given if less than the minimum number of samples were collected, but
at least one of the bulk sample analysis results was positive (greater than 1%
asbestos).
6-3
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6. Were the AHERA assessment categories 1 through 7 used appropriately?
This factor measures the ability of the original AHERA inspection to properly assign
an AHERA assessment category for each friable asbestos-containing homogeneous
material. Points were awarded for assigning the AHERA 1 through 7 category (either
numerically or in exact words) appropriate to the material type (TSI, surfacing
material, miscellaneous material) and the amount of damage reported or, where the
material was not damaged, the potential for damage reported.
AHERA does not require nonfriable and nonasbestos materials to be assessed; credit
was automatically given for these materials.
Since time has passed since the original AHERA inspection, a comparison of the
reinspection AHERA assessment category to the original inspection AHERA
assessment category was not made as such a comparison is invalid.
The project team and expert consultants assigned point values to each factor
consistent with their judgment of its relative importance. Roughly, each factor was deemed to be
twice as important as the next most important factor. This formula was modified for Factor 1 for
the following reasons. It is impossible to score points on Factors 2 through 6 if the material is not
identified. Therefore, if an original inspector failed to identify a material, a score of zero would be
assigned both for Factor 1 and for the material. If Factor 1 were twice as important as Factor 2,
then the maximum score would be 64 points and 33 points would be attached to merely identifying
the material and achieving no points for any of the other five factors. The research team felt that
fewer points should be attached to this level of achievement; we settled on nine points as a
reasonable value. This made the maximum material score equal to 40 points.
Alternatively, one may view the inspection as starting out with the maximum possible
score, 40 points, and losing points for each "No" answer. The points deducted for negative answers
were:
1. Was the suspect material identified?
40 points deducted if not
2. Was the material assessed properly?
16 points deducted if not
3. Did the inspector identify at least 80 percent of the areas in the school with the
material?
8 points deducted if not.
4. Was at least 80 percent of the material quantified?
4 points deducted if not.
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PEER REVIEW DRAFT
S. Were the correct number of bulk samples taken?
2 points deducted if not.
6. Were the AHERA assessment categories 1 through 7 used appropriately?
1 point deducted if not
Table 6-1 which is found on the following page, displays the full material scoring plan.
It shows the material score resulting from every possible combination of "Yes" and "No" answers to
the six factors. Thus, a material (1) identified in the Management Plan, (2) assessed appropriately
by the AHERA inspector, (3) found in at least 80 percent of the areas where it was located, (4)
quantified within 80 percent of the correct quantity, (5) with less than the correct number of bulk
samples taken, and (6) with the AHERA 1-7 categories not applied would receive a score of 37.
Before proceeding to aggregate the individual material scores into school inspection
scores, it is informative to examine some statistics on the material scores. Table 6-2 presents the
estimated national percentage of "Yes" answers to each of the six factors. The findings in Table 6-
2 are consistent with the findings in Chapter 3. Seventy percent (±5%) of all homogeneous
suspect materials were identified by the original inspectors. Once a material was identified, nearly
all inspectors assessed it appropriately and took the correct number of bulk samples. About three-
fifths of materials (±8%) were adequately located and quantified. Less than half of the original
inspectors used the AHERA 1-7 categories.
Table 6-2. Inspection quality by scoring factor
Factor
1. Material identified?
2. Material assessed appropriately?
3. Identified 80% of areas?
4. Quantified 80% of material?
5. Correct number of bulk samples?
6. Used AHERA categories appropriately?
Percent "Yes"
among all materials
70%
67%
42%
41%
68%
31%
Percent "Yes"
among identified materials
100%
96%
60%
59%
97%
45%
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PEER REVIEW DRAFT
Table 6-1. AHERA Inspection Evaluation: Material Scoring Plan
Material
score
40
39
38
37
36
35
34
33
32
31
30
29
28
27
26
25
23
21
19
17
15
13
11
9
0
1. Suspect
material
Identified
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
2. Material
assessed
appropriately
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
3. At Least
80% of
areas
Identified
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
Yes
Yes
Yes
Yes
No
No
No
No
4. At Least
80% of
material
quantified
Yes
Yes
Yes
Yes
No
No
No
No
Yes
Yes
Yes
Yes
No
No
No
No
Yes
Yes
No
No
Yes
Yes
No
No
5. Correct
number of
samples
taken
Yes
Yes
No
No
Yes
Yes
No
No
Yes
Yes
No
No
Yes
Yes
No
No
Yes
No
Yes
No
Yes
No
Yes
No
6. AHERA
categories
1-7 used
appropriately
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
Yes
No
No
No
No
No
No
No
No
No
,;,;> , -, - , **•-'"',
Points deducted for a "No".
40
16
8
4
2
1
NOTES: 1. Scores of 24,22,20,18,16,14,12,10, and 8-1 are, by definition, Impossible
for Individual materials.
2. The shading on the line for a zero score reflects the fact that, If the material
is not identified, then none of the other factors are relevant
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Figure 6-1 displays the estimated national distribution of individual material scores.
Thirty percent of materials (±8%) were scored 37 or higher. Another 37 percent (±7%) scored
between 25 and 36 points, reflecting a failure to adequately locate and quantify material, that was
identified and assessed appropriately.
Figure 6-2 displays the average material inspection scores by material type. The data
in Figure 6-2 reflect the data in Chapter 3. All types of TSI have nearly the same average score,
28-32 points. Materials that were frequently unidentified, such as vibration dampening cloth
(VDC), or underquantified or inadequately located have lower average scores.
6.12 School Inspection Score
The individual material scores were combined into a single school score by first
computing a weighted average of the material scores, with the weights being the square roots of
the respective amounts of material A discussion of the rationale for this weighting follows an
illustrative calculation. Suppose a school had two materials, 10 square feet of duct insulation and
5,000 square feet of surfacing material. Suppose further that the inspector scored 23 on the duct
insulation and 36 on the surfacing material The school average score would then be
(23V3.16^ 4- (36X70.7) = 35 points.
(3.16) + (70.7)
A number of possible methods of combining the individual material scores into a single school
score were considered. A simple unweighted average is easy to compute and understand. It gives
equal weight to every material from a few square feet of valve insulation, say, to several thousand
square feet of surfacing material In the above example, the unweighted average would be 30
points. This weighting is consistent with the viewpoint that it is important to identify and assess all
instances of ACBM. The custodial and maintenance workers need to know the locations of all the
ACBM in order to know when to protect themselves and others from potential fiber releases. An
alternate viewpoint is that large quantities of ACBM are more important than small quantities.
There are, for example, more people potentially exposed to more asbestos from friable surfacing
material in an auditorium than from small amounts of duct insulation. This viewpoint would lead
to weighting each material score by the respective quantity. In the above example, 5,000 square
6-7
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30% T
25% -
20%
Percent in score range 15% ••
10%
Figure 6-1. Distribution of inspection scores on individual materials
9-23
25-28
29-32
Score Range
33-36
37-39
40
-------
Figure 6-2. Mean inspection score by material type
Mean Score
35 T
30 -
25 ••
20 -
15 -
10 -
5 -
Breeching Boiler
Fittings Pipe Tank Surfacing Ceiling Tile Fire Doors Floor Tile Linoleum Transite VDC
Material Type
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PEER REVIEW DRAFT
feet of surfacing material would carry 500 times the weight of 10 square feet of duct insulation and
the size-weighted average would be 36 points. Table 6-3 summarizes the distribution of the school
inspection scores under different weighting functions. Weighting the material scores tends to
elevate the scores, indicating that inspectors performed better on the large quantity materials than
the small quantity materials.
Table 6-3. Comparison of different material weightings for computing school inspection scores
Material weight
Reinspection quantity
Square root of resinsp. quantity
No weight
Percentiles of school
inspection scores
25th
28
25
18
: "" "*•-. _^ ' % f vF*' ' "•/ fff f fW / f * , s^-x ,' *% ^V. s> ?
~K -K - -,* : , »^i&. fr**^/t*f'i >:.<*** , -: -* *% /, \&
., .^..v..x .5* . .. * -- :. %; x-& - */&'&, ,::&'*'„-, v ,^ \ ,*- \
Friable materials only, square root of reinsp. quantity
25
50th
31
31
25
75th
35
35
31
';? , ' ' :
{••* ',' ^ , ':
31
36
Weighting that compromises between these two viewpoints was sought because it was
felt that both viewpoints have merit. A mathematical function often used to compromise between
unweighted averages and weights proportional to size is the square root of the size. The square
root function dampens the influence of large areas of material relative to small areas. In the
example above, 5,000 square feet of surfacing material would carry 22.4 times the weight of 10
square feet of duct insulation, since the square root of 500 is 22.4.
Figure 6-3 displays the distribution of the school inspection scores using the square
roots of the quantities as weights. Most inspections scored 25 points or higher, up to 40 points, but
there is a long tail of poorer scores, down to 0 points. It is important to remember that a perfect
score of 40 still allows for some error in the inspection. For instance, an inspector may miss up to
20 percent of the areas containing each material and 20 percent of the material and still score a 40
for each material, leading to 40 points for the school average.
6-10
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Figure 6-3. Estimated national distribution of school inspection scores
12.0% -r
10.0% --
% with score 6.0% --
0 1 3 7 9 10 12 15 16 17 18 19 20 21 22 23 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40
School Inspection Score
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In order to summarize and evaluate the school inspections, the scores were grouped
into three ranges, with descriptive phrases associated with each range. The ranges are listed
below, along with the interpretation of each range for an "average" material These interpretations
also helped to motivate the specification of the ranges.
Range: 37-40. "Thorough"
On average, achieved yes's on the 4 most important factors, but may have
received no's on one or both of the other 2 factors.
Range: 29-36. "Some deficiencies"
On average, achieved yes's on the 2 most important factors, but either failed
to accurately quantify the material or adequately locate it.
Range: 0-28. "Severe deficiencies"
On average, failed to identify the material, or assess it appropriately, or
quantify or locate it.
It is important to note that these ranges are for school-wide averages scores.
Individual materials in a school will typically have both higher and lower scores. In particular, it is
mathematically possible for an inspector to inspect a school with only four materials, miss the
smallest one entirely (zero score), and still achieve a school score of 29 (with perfect 40's on the
other three materials), which is an inspection with "some deficiencies". Table 6-4 shows the
estimated percentages of inspections in each range; it shows the distribution of score ranges if only
friable materials are considered in the inspection.
Table 6-4. Estimated percent of inspections in each range
Range
Thorough
Some deficiencies
Severe deficiencies
Percent of schools-
includes all materials
16%
(±5%)
46%
(±10%)
38%
(±11%)
Percent of schools-
friable materials only
25%
(±10%)
34%
(±5%)
41%
(±10)
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The introduction to this section stated that a large school would be more difficult to
inspect that a small one. Table 6-5 displays the estimated association between the school
inspection scores and the number of materials in the school The percentage of thorough
inspections declines as the number of materials increases, from 29 percent (± 12%) in schools with
1 to 5 materials, to 8 percent (±8%) in schools with 9 or more materials. Similarly, the percent of
severely deficient scores increases as the number of materials increases.
Table 6-6 sheds light on one of the causes of less than thorough scores: materials
missed entirely (zero material score). Inspections with thorough scores identified all materials in
the school nearly hah7 the time and rarefy missed more than one material. In contrast, inspections
with severely deficient scores rarely identified all materials in the school and missed two or more
materials 80 percent of the time.
62 Analysis of Original Inspector's Background
The research question investigated in this analysis was, 'What is the relationship
between the quality of the original AHERA inspection, as shown by a comparison between the
reinspection findings and the data reported in the Management Plan, and the inspector's training,
education and experience?' Data were collected on the original AHERA inspectors' backgrounds
through a telephone survey with the original AHERA inspectors. The questions were asked in a
manner that permitted the reconstruction of the inspectors' background at the time he/she
conducted the original AHERA inspection in each school in the sample. The original AHERA
inspector questionnaire is Form Ol, found in Appendix A.
This section presents an analysis of the findings from the inspector interviews and
their association with the school inspection scores. Table 6-7 presents a profile of the population
of asbestos inspectors at the time they conducted the original AHERA inspections in schools. All
had AHERA accreditation, had been conducting asbestos inspections for a median 14 months, and
had inspected a median 45 schools. Over half had finished college and large minorities had
experience in building trades, environmental occupations, architecture or engineering. On the
other hand, few were professional engineers (PE), certified industrial hygienists (CIH), registered
architects (RA), or certified safety professionals (CSP).
6-13
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Table 6-5. Association between number of suspect materials in a school and the school
Inspection score
Estimated number of schools
School Inspection score range
37 - 40, Thorough
29 - 36, Some deficiencies
0 - 28, Severe deficiencies
Total
Number of materials in school
1-5
8,004
1 1 ,638
8,011
27,653
6 -8
3,405
16.898
13,195
33,498
9 & over
1,758
10,299
10,632
22,689
Total
13.167
38,835
31,838
83,840
Estimated percent of schools
School Inspection score range
37 - 40, Thorough
29 - 36, Some deficiencies
0 - 28, Severe deficiencies
Total
Number of materials in school
1 -5
29%
42%
29%
100%
6 -8
10%
50%
39%
700%
9 & over
8%
45%
47%
700%
Total
16%
46%
38%
100%
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Table 6-6. Association between number of missed materials In a school and the school
Inspection score
Estimated number of schools
School inspection score range
37 - 40, Thorough
29 - 36, Some deficiencies
0 - 28, Severe deficiencies
Total
Number of missed materials In school
0
5,950
8.153
1,158
15,261
1
6,783
11,517
5,326
23,626
2 & over
434
19,164
25,355
44,953
Total
13,167
38,834
31,839
83,840
Estimated percent of schools
School Inspection score range
37 - 40, Thorough
29 • 36, Some deficiencies
0 - 28, Severe deficiencies
Total
Number of missed materials in school
0
45%
21%
4%
18%
1
52%
30%
17%
28%
2 & over
3%
49%
80%
54%
Total
1 00%
100%
100%
1 00%
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Table 6-7. Selected characteristics of original AHERA inspectors at the time of the subject
school inspection
Characteristic
Ever received AHERA accreditation
Median time since accreditation
Ever taken a refresher course
Ever taken non-AHERA training in asbestos
Median time since first asbestos inspection
Median number of buildings inspected
Median number of school buildings inspected
Building trades experience
Environmental laboratory experience
Experience in environmental health
Occupational health or industrial hygiene
Architectural or engineering experience
Highest educational level
High school diploma or GED
Some College
Bachelor's degree
Master's degree
Possesses PE, CIH, RA, CSP
Quantity
100%
13 months
51%
65%
14 months
60 buildings
45 schools
38%
30% .
46%
34%
19%
21%
50%
9%
11%
We now summarize the results of bivariate analyses between the school inspection
scores and selected dichotomous attributes of the inspectors. Table 6-8 presents the median
inspection scores for inspectors who possessed and inspectors who did not possess selected
characteristics at the time they inspected the subject schools. None of the differences in Table 6-8
are statistically significant. Taken individually, the possession of the attributes in Table 6-8 have
little effect on the median school inspection scores.
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Table 6-8. Median school inspection scores by selected characteristics of the AHERA inspector
Characteristic
Accredited
Ever taken a refresher course
Ever taken non-AHERA training in asbestos
Building trades experience
Environmental laboratory experience
Experience in environmental health
Occupational health or industrial hygiene
Architectural or engineering experience
Highest educational level
High school diploma or GED
Some college
Bachelor's degree
Master's degree
Possesses PE, CIH, RA, or CSP
Median score
Possessed
30
30
30
30
29
29
28
31
29
29
30
29
Not possessed
—
29
28
28
29
29
30
—
29
Table 6-9 presents Pearson correlation coefficients between the school inspection
scores and selected ordinal or quantitative attributes of the inspector at the time of the subject
inspection. Only one of the correlations is statistically significant at the five percent level: the
highest educational level achieved by the inspector. The correlation is negative, which means that
the better educated inspectors achieved lower scores than less educated inspectors. Multiple
regression analyses were conducted to analyze the relationships between the school inspection
scores and many dimensions of the inspectors' backgrounds. None produced statistically
significant relationships.
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Table 6-9. Pearson correlation coefficients between school inspection scores and selected
original AHERA inspector attribute level
Attributes
Months since AHERA accreditation
Months since first asbestos inspection
Number of buildings inspected
Number of schools inspected
Highest level of education
Year of Masters degree
Year of Bachelors degree
Mean
level
16
22
135
98
-
1974
1980
Correlation
with score
0.06
0.05
0.05
0.01
-0.20 (1)
-0.45
-0.09
(1) Significant at the 0.05 level
The widespread lack of statistically significant associations between the school
inspection scores and the original AHERA inspectors' backgrounds is somewhat surprising. One
possible explanation for this finding is that the influence of employers' policies and practices cancel
out much of the variation between individual inspectors which, in turn, negates the effects of the
inspectors' backgrounds.
While we lack statistical data in support of this explanation, considerable anecdotal
evidence was obtained during the review of the Management Plans. Often, different Management
Plans from the same inspection company were similar in organization, content and presentation;
they therefore showed similar strengths and weakness in the reporting of the original AHERA
inspections.
6«3 Summary
A scoring system was developed to evaluate the original AHERA inspectors' overall
performance. The system evaluated the original AHERA inspector's ability to identify a suspect
material, assess it appropriately, record the areas where it was located in the school, quantify if
6-18
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within acceptable standards of accuracy, take the correct number of bulk samples, and use the
AHERA assessment categories. Each suspect material in a school building was scored on a scale
from 0 to 40 according to the original AHERA inspector's performance on that material. Material
scores were averaged to obtain a school average inspection score. The school average scores were
grouped into ranges that characterize the original AHERA inspector's performance. Thorough
inspections were performed in 16 percent of schools, inspections with some deficiencies were
performed in 46 percent of schools, and inspections with severe deficiencies were performed in the
remaining 38 percent of schools.
The primary causes of deficient inspections were failure to identify all suspect
material in a school, failure to either record the locations of the ACBM, and failure to quantify it
within acceptable standards of accuracy.
Analysis of the association between the school inspection score and the inspectors'
training, education and experience revealed almost no statistical association between the
inspection score and any characteristic of the inspectors' backgrounds. This somewhat surprising
finding may be due to the fact that many inspection companies use pre-prepared and automated
outlines and report shells for the management plans. These outlines and shells tend to induce
uniformity in the apparent quality of the reported inspections, which, in turn, masks the effects of
the inspectors' backgrounds.
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7. PROCESS OF NOTIFICATION
Research Area 5 examines the process by which parents and teaching staff were
notified of the asbestos status of their schools. The research questions to be answered include
questions about who has been notified, the method of notification, response to notification, and
projections as to different parental and teacher reactions to various types of notifications.
Two different research methods were used for this Research Area. The first method
was quantitative data collection (telephone and in-person interviews with principals, active parents,
and teachers from our sampled schools). The statistical data collected in answer to the research
questions for Research Area 5 contain three very distinct voices. The first voice is principals,
speaking about notifications of parents by the school and LEA. The second voice is that of active
parents (51% were PTA officers, 25% were PTA officers who also held another role, 9% were
parent volunteers, and 10% held another active parent role in the school) speaking about
notifications received by all parents at the school. The third voice is that of active teachers (47%
were a teacher's union representative, 23% were teacher's union representatives who also served
in another role, 10% were teachers who volunteered their time on extracurricular school activities,
8% were committee members and 12% served their school in another role in addition to teaching)
recounting the experience of all teachers at the school with regard to notification. Statistically
speaking, each of these parents and teachers was serving as a spokesperson for his/her school,
rather than representing other parents and teachers nationally.
In the case of principals and parents reporting about notification to parents, the facts
that underlie the statistics are the same, though recall bias has led to different statistics. Many
parents throughout the survey answered "Don't know" (DK) to questions, despite our attempts to
prompt an answer through probes and other standard survey techniques. It is also possible that
principals may have overreported notifications to show their school's compliance with this aspect
of AHERA. In general, however, we believe that principals, who have recourse to files and other
records, are probably presenting the most reliable information on notification of parents.
In the case of teachers, the only source of information we have about notification is
the teachers themselves. Teachers, like parents, are subject to a recall bias though, in general, the
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percent of teachers who answered "don't know" to questions was smaller than that for parents.
This difference was statistically significant at the 95 percent confidence level.
The second research method used for data collection in this Research Area was
qualitative. Focus group interviews with parents and teachers were held in St. Louis, Missouri;
Boston, Massachusetts; Seattle, Washington; and New Orleans, Louisiana. These participants
were selected by the separate focus group facility recruiters, each using their own recruitment
method. Parents were active in the school and had a child in any of grades 1 through 12 in a
school built prior to 1975. The sample included only those schools built before 1975 to increase
the chance that the school had ACBM at the time of the original AHERA inspection. Teachers
had taught any of grades 1 through 12 at a single school for two or more years and the school was
built before 1975. Detailed analysis of the results of the focus groups are presented in Appendix
D. The results of each type of data collection are presented below for each of the research
questions.
7.1 Persons Notified
The initial question in Research Area 5 was, 'Who has been notified?' The approach
to this question includes a statistical review of parents', teachers', and principals' answers to the
question as well as the recollections of parents and teachers who participated in focus groups.
Survey Results
Statistical data to answer the research question 'Who has been notified?' was
collected through in-person interviews with principals and telephone interviews with active parents
and teachers in the schools studied. One parent and one teacher from each school in the study
were interviewed. Perhaps the most interesting finding of this aspect of the study was the
surprisingly large number of parents [23% (+. 6%)] and principals [10% (+. 5%)] who did not
know if notifications about AHERA had been sent to parents (Table 7-1). In combination with
those parents who reported that there was no notification, half of the schools like those in the
study did not notify parents at all, or did not do so in a way that they remembered being notified.
Moreover, nine percent (±. 4%) of principals admitted that their schools did not send notifications
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to parents. (Thus, a total of 19% of principals either did not know if notification had been made
or knew that it had not.) With regard to teachers, 18 percent (+. 9%) reported that they were
never notified.
Table 7-1. Percent of schools notifying parents and teachers about activities pertaining to
asbestos since December 1987
Principals report about
notification of parents
Parents report about
notification of parents
Teachers report about
notification of teachers
Yes
82%
49%
76%
No
9%
27%
18%
DK
10%
23%
5%
N = 83,840
AHERA calls for notification not just once, but rather, at least once each school year.
Table 7-2 presents an attempt to determine how many parents and teachers have received
notifications more than once.
Table 7-2. Percent of schools notifying parents and teachers once and more than once1
Principals report about
notification of parents
(N = 76,396)
Parents report about
notification of parents
(N = 60,851)
Teachers report about
notification of teachers
(N = 68,338)
Only
once
23%
10%
21%
More
than once
66%
51%
62%
DK
10%
38%
17%
l
*No" and "Don't know* responses to question about notification excluded
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Table 7-2 shows that of schools in which notification occurred, 66 percent (+_ 10%) of
school principals reported that they notified parents more than once, though parents recalled
being notified more than once in only 51 percent (+. 8%) of schools. This comparison is
statistically significant at the 95 percent confidence level. Teachers in 62 percent (+. 8%) of such
schools recalled being notified more than once.
Parents' and Teachers' Focus Group Results
Very few of the parents in the focus groups recalled being notified of the asbestos
status of their school as required by the AHERA regulation. The exception was parents in St.
Louis, where all remembered being notified. A somewhat greater number of teachers than parents
remembered being notified across the four locations.
In all four groups, both teachers and parents in Catholic schools recalled both being
notified and the contents of the notification more than teachers and parents in any of the pubk'c
school systems, with the exception of one group.
It is important to note, however, that during the in-depth discussion of different types
of notifications, many participants stated that notifications could easily be overlooked by parents if
they were either unclearly or bureaucratically worded or if they were delivered (or more frequently
not delivered) to them by their child or through a method other than by mail.
12 Method of Notification
The second question asked by EPA in Research Area 5 was 'Were these people
notified through a letter, meeting, article in a school newspaper, or in another way?'
Survey Results
Table 7-3 shows the percent of schools in which each category of respondent recalled
notification occurring, when specific methods were used to notify parents. According to principals,
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the most common method of notification was through letters. Fifty-two percent (.+. 9%) of schools
that notified parents did so in a regular letter or notice sent to parents. An additional 52 percent
(+. 10%) of this type of school notified parents in a special letter or notice about asbestos in the
school. Interestingly, parents recalled being notified by both of these methods in approximately 40
percent of the schools [42% (+. 9%) and 41% (+. 8%)]. While this represents a 10 percent
difference in level of parents recalling this type of notification compared to that of principals, the
relationship is not statistically significant at the 95 percent confidence level.
Table 7-3. Percent of schools using specific methods to notify parents and teachers l>2
Notified in regular letter/
notice
Notified by special letter/
notice
Notified at regular FTA
meeting
Notified at regular teacher's
meeting
Notified at special (PTA/
teacher) meeting
Notified by official press
release
Notified in some other way
Principals about
notification
of parents
52%
52%
32%
NA
6%
23%
18%
AT = 76,396
Parents about
notification
of parents
42%
41%
25%
NA
5%
20%
9%
N = 60,851
Teachers about
notification
of teachers
33%
54%
12%
57%
3%
19%
20%
N = 68,338
1 Columns do not total 100% as multiple responses were allowed.
2"No" and "Don't know" responses to question about notification excluded.
The second most common method of notification was through a regular PTA meeting.
Thirty-two percent of principals (+. 10%) recalled notifying parents in this way, while the parents
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in 25 percent (+_ 10%) of schools in which they recalled notification occurring, recalled this type of
notification.
An additional area of research applicable to the method of notification is the contents
of the notifications. Table 7-4 presents information on the presence of various important elements
in notifications to parents and teachers, for those who recalled being notified. The study team
developed a list of these important elements as a means of determining the completeness of
notifications.
Table 7-4 begins to show very serious differences between what principals recalled
sending to parents as notification and what parents recalled. While 84 percent (+. 7%) of schools
(according to principals) notified parents of the availability of a Management Plan, only 27 percent
(+. 7%) of schools (according to parents) sent this information out to parents. This relationship is
statistically significant at the 95 percent confidence level. Admittedly, although there are some
ambiguities in the notification section of the AHERA legislation, the study team felt that the
regulation does require notification of parents of the existence and availability of the Management
Plan for review.
A different pattern exists, however, with parent and principal recall on whether the
notification included the location of ACBM, the occurrence of response, actions, and general
asbestos information. For these three items, in schools where notification occurred, the
percentage of parents who recalled being notified was much closer to the percent of principals who
recalled sending these elements. In all three cases, however, the difference between principals and
parents is statistically significant at the 98 percent confidence level.
Table 7-4 also presents teachers' comments on the contents of the notifications they
received. Teachers in only 28 percent (±_ 6%) of schools recalled receiving information on the
availability of the Management Plan. This was the only notification element studied for which
teachers recalled being notified less frequently than did parents.
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Table 7-4. Percent of schools with various contents in notification as reported by principals, parents, and teachers1*2
Key element
Principals report
about parents
Yes No DK
Parents report
about parents
Yes No DK
Teachers report
about teachers
Yes No DK
Availability of management plan
Notice of initial AHERA inspection
Location of ACM
Occurrence of response actions
General asbestos information
84% 6% 10%
76% 13% 10%
38% 52% 10%
46% 44% 10%
36% 53% 10%
27% 12% 60%
40% 8% 52%
32% 18% 49%
37% 15% 47%
35% 19% 46%
28% 30% 42%
45% 24% 31%
52% 23% 24%
57% 17% 26%
52% 22% 26%
N = 76,396
N = 60,851
N = 68,338
'Columns do not total 100% as multiple responses were allowed.
2"No" and "Don't know" responses to questions about notification excluded.
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Parents' and Teachers' Focus Group Results
Of the parents and teachers participating in the focus groups who recalled being
notified, all were notified by letter or memo from the school district or school.
Many parents and teachers who did not recall being notified, however, expressed
some knowledge about the asbestos status of their school through non-AHERA notifications.
Some focus group participants recalled being notified under the Asbestos in Schools Rule1, while
others had learned through such methods as serving on the school board, hearing or reading about
an asbestos removal or, most frequently, through hearsay. In particular, many of the teachers who
expressed some knowledge of the asbestos status of their schools had learned this through word of
mouth or personal encounters with asbestos inspectors.
73 Response to Notification
The third question to be answered in Research Area 5 was, 'After notification
occurred, did parents review the Management Plan, attend meetings to discuss asbestos in the
school, or respond to notification with any other action?'
Survey Results
One of the important areas of concern for the EPA in drafting the notification
element of AHERA was how parents, and to a lesser degree teachers, would react to notification.
This question encompassed three factors: frequency of reaction, intensity of reaction, and types of
actions taken in response to notification. This section attempts to address all three EPA concerns.
Table 7-5 shows the percent of schools with notifications where parents and teachers
reacted to notifications. As this table shows, 73 percent (+. 8%) of schools had no parents reacting
according to principals, while 55 percent (+. 8%) of schools had no parents reacting according to
parents, and 80 percent (+, 7%) of schools had no teachers reacting according to teachers.
11982, EPA Asbestos in Schools Rule.
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Moreover, most of those schools where either parents or teachers did react, had only a few who
responded [14% (+. 4%) of parents according to principals, and 7% (.+. 4%) of parents according
to parents.] The parents or teachers in a school reacted very rarely.
Table 7-5. Percent of schools with notifications where parents and teachers reacted to
notification, as reported by principals, parents, and teachers1
None A few Some Many All DK
Principals report about
parents' reactions
(N =76,396)
Parents report about
parents' reactions
(N=60,851)
Teachers report about
teachers' reactions
(N* 68,338)
73% 14% 2% 0% <1% 10%
55% 7% 4% 1% <1% 33%
80% 6% 4% 3% <1% 7%
**No* and 'Don't know" responses to question about notification excluded.
Table 7-6 illustrates the types of actions notified parents and teachers have taken in
response to notification. The most frequent actions were requesting to review the Plan, and
requesting additional information about asbestos and the inspection [5% (+. 4%) and 7% (±_ 5%)
of parents as reported by principals]. Other reactions included requests for information on the
costs of asbestos remediation, and positive reactions such as "positive comments that school is taking
care of the problem." The most extensive reaction was in response to an 'illegal removal of tile, a
call chain was begun to inform parents of what was going on,' and to force the company removing
the tile to stop. This occurred in less than 1 percent of schools nationally.
Among the teachers, the reactions were quite similar to those of the parents, though
more teachers had no reaction and fewer didn't know if there was teacher reaction. The only
difference between parent and teacher reaction was that at least one teacher requested a transfer
from the room in which he/she taught in less than 1 percent of schools in our sample.
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Table 7-6. Percent of schools where parents and teachers took specific actions in response to notification
1
Key element
Request to review Management Plan
Request for additional information
Request for special meeting to
discuss asbestos
Request to add asbestos to meeting
agenda
Request to change child/teacher
classroom
Other reactions
Principals report
about parents
Yes No DK
6% 84% 10%
7% 83% 10%
1% 89% 10%
2% 88% 10%
0% 90% 10%
7% 78% 14%
N = 76,396
Parents report
about parents
Yes No DK
4% 34% 61%
4% 35% 60%
2% 54% 43%
3% 56% 40%
0% 64% 36%
7% 56% 37%
N = 60,851
Teachers report
about teachers
Yes No DK
3% 70% 27%
12% 63% 24%
1% 84% 15%
4% 81% 15%
<1% 87% 13%
4% 82% 13%
N - 68,338
lMNo" and "Don't know" responses to questions about notification excluded.
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The final point of EPA interest was the level of concern, as compared to the number
of people, expressing concern, felt by parents and teachers. Table 7-7 shows the percent of schools
in which parents and teachers expressed different levels of concern about their school's asbestos
situation. The differences among the responses for the three groups in this table are not
statistically significant at the 95 percent confidence level. In general, it can be said that parents in
55 percent (±. 8%) of schools expressed no concern and 80 percent (.+. 7%) of teachers expressed
no concern. Overall, less than 3 percent (±_ 3%) expressed considerable concern. The remainder
expressed little/some concern.
Table 7-7. Percent of schools where various degrees of concern were expressed by parents and
teachers as reported by principals, parents, and teachers
Principals report about
parents' reactions
(N =76,396)
Parents report about
parents' reactions
(N" 60,851)
Teachers report about
teachers' reactions
(N* 68,338)
No
concern
73%
56%
80%
Some
concern
9%
3%
3%
Considerable
concern
7%
9%
10%
DK
10%
32%
7%
Parents' and Teachers' Focus Group Results
The parent and teacher focus group responses fall into two categories. The first
category includes parental and teacher reaction to the actual notifications that they received. The
second category includes parental and teacher projections of their reactions to three different
notification letters and various techniques of notification discussed in the focus groups (see
Appendix D).
Few participants recalled being notified, but for those who did, reactions were just
about nonexistent: None of the parents or teachers present called their principal or AHERA
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designated person, or reviewed their school's Management Plan. In short, none of the 40
participants in these focus groups described any actions resulting from their current knowledge
about asbestos in their schools, and the few who had been notified under AHERA were no
exception.
By contrast, projected reactions to the examples of notifications were somewhat more
intense. Participants in each group were shown the same four examples of notifications. These
examples were presented in the same order in each group, and each represented a different level
of notification. Many participants projected that they would call the principal or AHERA
designated person in response to each of the example notifications. In many cases, the teachers'
and parents' involvement in the school was such that their own assertion that they would place a
call in response to the notification was not surprising. (Several participants were heads of PTAs or
PTOs and one participant was on the local equivalent of the school board.) Nevertheless, the
striking difference between actual responses to notifications and projected reactions leads one to
conclude that the participants possibly projected more strenuous reactions than they would
actually undertake.
Despite this seeming inconsistency of the projected reactions to notification as
compared to actual reactions, only a handful of participants said that they would review their
school's Management Plan after receiving any of the notifications. About an even number of
teachers and parents said that they would review the Plan, and these responses occurred about
equally frequently in response to each of the three sample notifications.
No participants predicted parental or staff reaction to our examples of notifications
more strenuous than making a phone call, visiting the AHERA designated person, or perhaps
reviewing the school's Management Plan. The strongest reaction suggested by only a very few
participants was the possibility that some parent might request that a child be removed from a
particular classroom. None of the participants made any comments about physically removing the
asbestos-containing building materials, undertaking a lawsuit, or taking action other than
information collection.
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7.4 Alternative Notification Contents
Parents' and Teachers' Focus Group Results
Focus group discussion was the only data collection technique used to research the
question 'What might parent and staff reactions be to differently worded notification letters?'. The
discussion centered on four examples of notifications (see Appendix D) as well as participant ideas
on ideal contents of a notification.
Three examples of notification were in the form of letters or memos from the school
to the parents. The briefest and least detailed of these (West Township Example) was found to be
"unclear" and to be intentionally hiding the actual findings of the school. Only a handful of
participants expressed satisfaction with the level of detail in this example.
The second example (South Community Example) was received more positively than
the previous example. Specific problems with this example ranged from "too much detail" to "too
little detail". Many participants in the groups said that if they received this notification they would
still call either the AHERA designated person or their school's principal to learn specific
information on where asbestos-containing material was located and its condition.
Response to the third example (North Community Example) was much less similar
among the groups than reactions to the other two notifications. While participants in all of the
groups thought it was too long, there were differences between the groups on the value of the
detail in this letter. Reactions to the level of detail ranged from generally positive to very mixed.
Some participants thought the letter was informative and helpful. Others thought that some of the
detail in this example was unnecessary and even irritating:
In general, parents and teachers who had a lot of confidence in their school district
thought that the presentation of the list of ACBM materials in the North Community Example was
unnecessary, while those with less confidence thought that the list of ACBM should be included.
The more participating group members were more accepting of the length and level of detail
presented in this example.
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Discussion about the fourth example (Appletree Example) focused more on the
method of dissemination (i.e., newsletter vs. letter or memo) than on its contents. Nevertheless,
most participants strenuously objected to the "oversimplified'' and "cursory" nature of the text.
Reaction to disseminating notification information through a newsletter as opposed to a letter or
memo was less strong, though most participants preferred the letter or memo format. These
participants thought that information in a newsletter might "get lost visually" while a letter devoted
to a topic would not.
Ideal Contents
Discussion of ideal contents for a notification letter also occurred. During the
discussion, several groups suggested the following items as recommended contents of a
notification:
• Location of asbestos-containing building materials and a plan of action to
respond to the asbestos;
• Time frame for response actions;
• Definition of friability;
• Availability of a school-based asbestos resource person;
• Explanation of the health risks of asbestos; and
• A simple cover letter attached to a more detailed technical or material-by-
material report.
7.5 Summary
The goal of Research Area 5 was to look into parent and teacher reactions to
notification. This topic was studied with remarkably consistent results through focus groups and
interviews with principals, parents, and teachers. In general, while principals recalled notifying
parents about the presence of a Management Plan, both parents and teachers very often did not
recall either being notified or the contents of the notification. The most common methods of
notification used were letters, and in the focus groups we learned that both parents and teachers
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believe that this is the most effective method of notification, particularly if the letters are sent by
mail rather than hand-delivered.
Both the survey and the focus groups showed that parent reactions to notifications
tended to be slight. Of the principals who could recall whether parents reacted to notification, 81
percent reported that parents had no reaction at all to nodification. In the focus groups, almost no
one recalled reacting to notification, and only a handful of participants predicted that they would
react to any of the model notifications presented to them. Among those who did react, or who
predicted that they would react, the range of actions was very small and included only such
activities as reviewing the Management Plan, calling the AHERA designated person for additional
information, and requesting that asbestos be added to a meeting agenda.
Through the use of focus groups we also explored preferences for types of
notifications. Both parents and teachers were eager for a much more thorough level of
notification than they have experienced to date. Specifically, they wanted a school-based
notification mailed to each parent. They wanted this letter to contain the name and telephone
number of the AHERA designated person, and a description of any planned response actions and
the associated timetable, and brief but informative health risk information.
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8. MAINTENANCE AND CUSTODIAL WORKERS TRAINING AND EXPERIENCE
Research Area 6 studies the level of training and types of work responsibilities of
maintenance and custodial personnel.
Two different research methods were used for this Research Area. These methods
included in-person interviews with AHERA designated persons in our sample and a qualitative
data collection effort. The qualitative effort consisted of focus group interviews in St. Louis,
Missouri; Boston, Massachusetts; Seattle, Washington; New Orleans, Louisiana; and Bethesda,
Maryland with maintenance workers and custodians from schools where asbestos was present.
Participants were recruited using lists of maintenance workers and custodians obtained from locals
of several employee unions, including the American Federation of State, County, and Municipal
Employees and the Service Employees International Union. In addition, the study team contacted
Catholic and other private schools to obtain names of potential participants.
Participants in these group discussions, as in most focus groups were not randomly
sampled. Rather in each group we attempted to have a mix of maintenance workers and
custodians, and a mix of types of schools. On the other hand, we attempted to decrease the
possibility of a union sending only those with strong opinions on asbestos by requesting long lists of
names from each union and inviting workers to the group ourselves.
Maintenance workers are those workers responsible for repair and maintenance of
systems such as plumbing, heating ventilation, and air conditioning. Custodians are responsible for
janitorial jobs, and in some cases, minor maintenance such as changing light bulbs. AHERA calls
for all members of a school's maintenance and custodial staff who may work in a building that
contains ACBM to receive awareness training of at least 2 hours, whether or not they are required
to work with ACBM. Moreover, AHERA requires that all staff who conduct any activities that will
result in the disturbance of ACBM receive 14 hours of additional training beyond that required for
awareness (a total of 16 hours). Some experts believe that a custodian responsible for sweeping
and dusting in an area with ACBM should receive the full 16 hours of training, while others believe
that contact with ACBM must be direct to require 16 hours of training. The results of the data
collection effort are presented below for each of the research questions.
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8.1 Training of Maintenance and Custodial Workers
The first question to be answered in Research Area 6 is, 'Are custodians and
maintenance personnel trained to work with and around asbestos?' Data were collected on this
topic through both an in-person survey of AHERA designated persons and through focus groups
with maintenance and custodial workers.
Surrey Results
In order to answer this research question interviews were conducted with the
AHERA designated person from each of the schools in our sample. In districts where more than
one school was included in the study, each ADP was asked questions about maintenance worker
and custodian training for each school in the study.
Westat understands that the training reported by the ADPs may not accurately reflect
the level of training actually received by maintenance workers and custodians for several reasons.
First, ADPs may have an incentive to over-report the number of actual training courses to show a
greater level of compliance with the AHERA regulation than actually occurred. Second, due to
absenteeism, not all maintenance workers or custodians in a school will be trained by any given
course (i.e., there may be a difference between the percent of schools that offer training and the
percent of maintenance workers and custodians actually trained). Finally, there are questions
about what maintenance workers and custodians retain from their training courses, and whether
school staff who does not recall being trained, or does not retain any significant portion of the
contents of a course, can be called 'trained.'
All of these concerns are valid. It is possible that a research methodology where
AHERA designated persons, maintenance workers, and custodians were all interviewed on the
topic of training received would have produced more reliable and complete data than that
produced by interviewing AHERA designated persons only. However, one of the results of early
discussions held with schools on the study design was that many schools were unwilling to have
their maintenance workers and custodians interviewed. School superintendents asked about this
said that they would be happy to have their schools involved in the study if it involved participating
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in a reinspection, review of Management Plans, interviews with AHERA designated persons, and
principals, but that they would refuse to have support staff such as maintenance workers and
custodians "represent" their school district to the world.
In order not to jeopardize the response rate for the overall evaluation, and keeping in
mind the comments of school administrative staff described earlier, the decision was made to
interview AHERA designated persons as the sole representative of school and district training
practices for schools and districts in our sample of 197 schools.
All of the information presented in this section is based on the estimated 83,840
schools nationally that had performed an AHERA inspection, found asbestos-containing materials,
and wrote a Management Plan, or based on various subsets of this type of school, such as schools
that met the study criteria and provided training to maintenance workers.
Table 8-1 shows that 87 percent (+. 9%) of schools like those in the study had offered
maintenance workers asbestos-related training in the post-AHERA period. The case can certainly
be made that schools should be responsible for insuring that this type of worker is trained, but in
fact, almost all schools who used outside vendors for maintenance work [7% (+.6%) of schools]
did not know if the workers had received any training about ACBM or its locations in their school.
Outside vendors considered for this study were companies which provided maintenance and/or
custodial services to the school. This did not include people such as telephone cable installers.
Table 8-1. Percent of schools offering maintenance and custodial worker training since October
1987
Training offered
Yes
No
School does not have
this type of employee
N=
Schools with
maintenance workers
87%
7%
7%
83,840
Schools with
custodians
95%
3%
2%
83,840
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The AHERA regulation requires 16 hours of training for staff with traditional
maintenance worker responsibilities in schools in which asbestos-containing materials were found.
Not all of the staff who the AHERA designated persons called maintenance workers perform
traditional maintenance worker activities around ACBM, and could potentially require less
training under AHERA. Nevertheless, as Table 8-2 shows only 26 percent (±_ 5%) of schools that
trained their maintenance workers provided 16 or more hours of training. The N used in tables
throughout this section varies. This reflects differences in training and employment patterns for
these two different types of school support staff. Tables 8-2 through 8-7 present data only for
those schools who train their staff, Tables 8-8 and 8-9 present data only for schools where training
was offered and included a description of the locations of ACBM in the school.
School performance on training for custodial workers was not statistically different
than that for maintenance workers at the 95 percent confidence level. As shown in Table 8-1, 95
percent (+. 6%) had conducted one or more training classes for custodial workers since October
1987.
Table 8-2 illustrates the duration of training offered to custodians and maintenance
workers. It shows that of the estimated 79,330 schools that have conducted custodial worker
training for their workers, 95 percent (+. 6%) of the most recent courses offered to custodians
were two hours or longer, which is to say that nine out of ten schools' custodial training courses are
in compliance with the AHERA guidelines for awareness training. Awareness training is required
for those workers who would not come into contact with or disturb ACBM. However, 5 percent
(± 6%) of the courses were under two hours, indicating that a small percentage of schools do not
meet the minimum AHERA awareness training requirements. Anecdotally we can say that
custodians in many schools nationally have jobs requiring that they work actively around ACBM.
According to AHERA these workers should have received 16 hours of training. Only 13% (+. 8%)
of custodians have received this level of training. The difference between the duration of custodial
and maintenance worker training received is statistically different at the 95 percent confidence
level for training of 2 hours and training that lasted 16 hours or longer.
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Table 8-2. Percent of schools offering various lengths of maintenance and custodial worker
training since October 1987
Length of training
Less than 2 hours
2 hours
3-15 hours
16 or more
N =
School with
maintenance workers
2%
42%
30%
26%!
72,647
Schools with
custodians
5%
66%
16%
13%!
79,330
recommended minimum duration of training for this type of worker when job responsibilities require
him/her to come in contact with ACBM.
Some of the schools that reported not having offered training may not have employed
staff requiring training under AHERA. This would be if their job responsibilities do not call for
them to work around ACBM or if all ACBM discovered in the school has been removed. This
information can not be learned from the AHERA evaluation.
Table 8-3 shows the percent of schools which have provided training to maintenance
and custodial workers employed by the LEA. As shown in Table 3-3, a total of 85 percent (±13%)
of the schools meeting the three study criteria have conducted both a maintenance worker and a
custodial training since October of 1987. Importantly, 3 percent (±8%) of schools have not
trained either their maintenance or custodial workers at all.
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Table 8-3. Percent of schools providing training to maintenance and custodial workers since
October 1987
LEA-employed
Trained
Maintenance Worker
Maintenance Worker,
Custodial Worker
Custodial Worker
Custodial Worker
Not trained
Maintenance Worker
Custodial Worker
Maintenance Worker,
Custodial Worker
Outside vendor
Custodial Worker
Maintenance Worker
Maintenance Worker
Maintenance Worker,
Custodial Worker
Percent
1%
85%
4%
6%
1%
3%
1%
Light is also shed on the training received by maintenance workers and custodians by
the frequency and schedule on which training is offered. Table 8-4 shows the schedule on which
training is offered to maintenance workers and custodians in schools where workers are LEA
employees and which meet the other study criteria. The largest number of schools offer training
annually [41% (.+. 12%) for both maintenance workers and custodians], on an as needed basis
[25% (± 9%) and 26% (± 8%) respectively], or upon hiring a new employee [11% (+. 8%) and
10% (+, 7%) respectively]. The differences between the responses for maintenance workers and
custodians are not statistically significant at the 95 percent confidence interval for any of the
responses in Table 8-4.
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Table 8-4. Percent of schools with different training intervals for maintenance workers and
custodians
Training interval
Once a month
Once every 2 months
Once every 6 months
Once a a year
As needed
Upon hiring a new employee
None at this time
On another schedule
N=
Schools training
maintenance workers
2%
3%
2%
41%
25%
11%
7%
10%
72,647
Schools training
custodians
1%
3%
3%
41%
26%
10%
7%
8%
79,330
A final set of insights into the training offered to maintenance workers and custodians
by schools is offered by Table 8-5. This table presents an overview of the provisions schools have
made for training newly hired maintenance workers and custodians. It shows that schools have
made almost identical provisions for training newly hired maintenance workers and custodians. In
general about one-quarter of schools train within two weeks of hire. Finally, approximately 15
percent (±5%) of schools offer training within one year of hire, soon after hire but at an unstated
interval, or have no provisions for training new workers. Fifteen percent (±7%) also provide
training on some other schedule or through another method such as using an outside consultant.
None of the differences between custodial and maintenance training shown in Table 8-5 are
statistically significant at the 95 percent confidence level.
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Table 8-5. Percent of schools with different provisions for training newly hired maintenance
workers and custodians
Training provisions
Trained within one month of hire
Trained between 32 days and 6 months
Trained between 183 days and 1 year
After hire run through a 2-hour
session, audio tape, or video tape
No provisions as there are no new
workers or no provisions
Other method
N=
Schools training
maintenance workers
22%
24%
13%
14%
12%
15%
72,647
Schools training
custodians
23%
25%
15%
13%
11%
13%
79,330
Maintenance and Custodial Personnel Focus Group Results
A majority of the maintenance workers who participated in the focus groups reported
receiving the AHERA required hours of training, given their specific job responsibilities. These
maintenance workers received two to four days of training with the exception of several whose job
responsibilities do not indicate a need for anything other than a two- to four-hour "awareness" type
course, which they received. Several maintenance workers received only a two- or three-hour
awareness course. However, given their stated job responsibilities and that they did work around
and potentially disturb ACBM, this training was not adequate and they should have received the
16-hour course. A few maintenance workers received no training at all, simply being told not to
work near asbestos. Since these workers were working in buildings with ACBM, they should have
received a 2-hour training at a minimum.
The job responsibilities of the few maintenance workers who did not receive any
training as well as those responsibilities for some maintenance workers who received only
awareness training, show clearly that the school districts concerned are not in compliance with
AHERA, as these workers reported working around ACBM.
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Most custodians have received two to four hours of training within the past 24 months
and have thus met the required level of awareness training. One custodian was sent to a one-week
course with the idea that he would be working with asbestos, but his job responsibilities do not
currently require this knowledge. However, many of the custodians also worked around ACBM
and thus had not received the required 16 hour minimum training.
The few custodians who received no training at all were aware of asbestos and very
concerned about it. They wanted to get some information about asbestos, and as one of these
custodians said about training, "That [training] lets you know more how to take care of yourself. To
not know where it [asbestos] is, to not be told, then you 're in danger all the time."
8.2 Curriculum of Training
The second question in Research Area 6 is, 'What topics were included in this
training?' This topic was researched both through in-person interviews with AHERA designated
persons and through focus group discussions with maintenance and custodial personnel.
Survey Results
The survey of AHERA designated persons asked several different questions about the
content and location of the training offered to maintenance and custodial workers. While few
ADPs consulted their written records prior to answering these questions (they were not asked to
do so), there is no reason to believe that there was a systematic bias in responses.
Answers to the question "Was the most recent asbestos-related training for
maintenance workers/custodians conducted at the school or off site" are presented in Table 8-6.
Location of training could be considered an important factor in the adequacy of AHERA training.
If training is to include a description of where ACBM is located in a specific building and perhaps
be augmented by a building reinspection to point out locations, then training on site is desirable.
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Table 8-6. Percent of schools where the location of training sessions for LEA-employed
maintenance and custodial workers was on-site, off-site, or both
Training location
At the school
Off-site
Both
Af=
Schools with
maintenance training
21%
77%
1%
72,647
Schools with
custodial training
. 26%
73%
1%
79,330
Of the most recent custodial training courses offered by schools, 26 percent (±_ 9%)
were taught at the school, while 73 percent (+. 9%) were offered off site. The remainder were
offered in both locations. The differences between custodial and maintenance worker training
shown in Table 8-6 are not statistically significant at the 95 percent confidence level.
This table shows that approximately 75 percent (+. 12%) of schools which meet the
study criteria, and in which the staff are LEA employees, offer training to maintenance workers
and custodians at a location other than the school. The difference between the maintenance
worker and custodial percentages in Table 3-6 are not statistically significant at the 95 percent
confidence level.
Table 8-7 shows the percent of schools in which the staff are LEA employees where
maintenance worker and custodial training included a description of the locations where asbestos-
containing materials were found. This table shows that as much as 28 percent (+_ 10%) of this type
of schools did not provide the locations of ACBM to their maintenance workers. Similarly, as
much as 19 percent (+. 9%) of the schools in which custodians were trained, did not describe the
locations of ACBM to their custodians. The differences between custodians and maintenance
worker training shown in Table 8-7 are not statistically significant at the 95 percent confidence
level.
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Table 8-7. Percent of schools where training offered to LEA-employed maintenance workers and
custodians contained a description of where asbestos-containing building materials
were found hi the school.
ACBM location described
Training includes a description
of where asbestos was found
Training does not include a
description of where asbestos
was found
N=
Schools with
maintenance training
71%
28%
72,647
Schools with
custodian training
80%
19%
79,350
Table 8-8 shows the three most common methods of presenting the location of ACBM
used by schools where training is offered. These methods do not total to 100 percent as schools
often use more than one training method. By far, the most common method of presentation is
through a verbal description of the locations of ACBM in the school. Ninety-two percent (i.4%)
of the schools used this method in training maintenance workers while 91 percent used it for
training custodians (±, 5%). The next most common method is through presentation of the
floorplan of the building [81% (+. 10%) for maintenance workers and 75% (+. 11%) for
custodians], followed by an actual walkthrough of the school to point out ABCM. Approximately
half of the schools offer training through a walkthrough to both types of workers.
Table 8-8. Percent of schools where training offered to LEA-employed maintenance workers and
custodians included a description of the location of asbestos, by method of
presentation
Involve a building walkthrough
Presentation of the floorplan
of the building
Verbal description
N=
Maintenance workers
55%
81%
92%
5^,902
Custodians
47%
75%
91%
63,894
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Table 8-9 shows the combinations of presentation techniques used by schools which
meet the study criteria, and which employ and train maintenance workers or custodians. The
three most frequent combinations of methods of presenting information on locations of asbestos-
containing materials for both maintenance workers and custodians are:
• Building walkthrough, floorplans, and verbal description [52% (+. 18%) for
maintenance workers and 43% (+. 15%) for custodians];
• Floorplans and verbal description [26% (+_ 14%) for maintenance workers and
27% (+. 11%) for custodians]; and
• Verbal description only [13% (+. 8%) for maintenance workers and 19%
(+. 10%) for custodians].
None of the responses in Table 8-9 are significantly different at the 95 percent
confidence level between maintenance workers and custodians.
Table 8-9. Percent of schools where training presented information on locations of asbestos-
containing building materials
Building walkthrough, floorplan,
and verbal description
Building walkthrough and floorplans
Building walkthrough and verbal
description
Building walkthrough only
Floorplans and verbal description
Floorplans only
Verbal description only
None of the above methods
N=
Maintenance workers
52%
0%
1%
1%
26%
2%
13%
4%
51,902
Custodians
43%
0%
3%
<1%
27%
5%
18%
3%
63,894
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Maintenance and Custodial Worker Focus Group Results
Course content was consistent for most people who were trained. Maintenance
workers who received the AHERA required level of training were given general awareness and
health effects, and most were shown some safety procedures to follow when working around
asbestos, specifically glove bag removal procedures. In one location, custodian-engineers, whose
job responsibilities are like those of maintenance workers, had received extensive training prior to
AHERA. Their post-AHERA training included little more than the history of asbestos and why it
is used, and very little on health effects or procedures to be used around asbestos. This particular
training does not appear to serve the intent of the AHERA legislation. In all cases when films,
videos, or slides were used, a knowledgeable person was present to answer questions. In a very few
situations the location of ACBM was discussed during the training.
Most maintenance workers felt that the course content was at a minimum adequate,
and in some cases, quite comprehensive. As one said, "Iknow enough not to handle it." It appears
that the curriculum meets the requirements outlined by AHERA, though the lack of knowledge
about specific locations of ACBM calls into question the adequacy of the training for promoting
good work practices.
Almost all of the custodians who received training were shown training movies or
videos. However, the participants stated that they did not believe they retained much of the
information given in training. One exception was a custodian who was shown what asbestos looked
like and the equipment to be used around ACBM by the designated person. The custodians were
quite aware of asbestos, but they felt they did not know enough about health effects and how to
locate the asbestos in their schools. The training curriculum appears to have created some
awareness of ACBM as required by AHERA, but retention of information was poor and the
custodians expressed almost a universal lack of knowledge about asbestos. In fact, many of the
custodians worked around ACBM and reported having to disturb/clean ACBM. These workers
did not receive 16 hours of training as is required for these activities.
Approximately half the maintenance workers received training on respirator use,
learning how to perform positive and negative pressure testing. None of these people were fit
tested by the Occupational Health and Safety Administration (OSHA) definition of the term, and
virtually none met OSHA's medical examination and other requirements for respirator use. No
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custodians, whatever their responsibilities around ACBM, reported having received respirator
training or access to a respirator.
83 Tasks Required of Maintenance and Custodial Workers
The third question in Research Area 6 is, 'What tasks relative to asbestos or suspect
ACBM are regularly required of maintenance and custodial personnel, and do these tasks
correspond to the level of training received?' This topic was researched solely through the use of
focus group discussions with maintenance and custodial personnel.
Maintenance and Custodial Personnel Focus Group Results
Similar tasks are frequently performed by both maintenance and custodial workers. A
series of questions about specific situations involving asbestos were posed to the group
participants.
The first question dealt with cleaning up after a roof leak had damaged asbestos.
Well over half the workers had cleaned up after roof leaks, but only a few knew whether or not
asbestos had been damaged. In one case, a maintenance worker used what he called glove bag
procedures (though this would not be an approved cleanup procedure for this type of leak), and in
another a custodian cleaned up using standard dry cleaning procedures even though co-workers
had told her earlier that asbestos was present. In general, no special procedures are followed in
this situation. This is because it is usually considered a cleaning and maintenance emergency (not
an ACBM emergency.) The goal then is to deal with these incidents immediately, especially if
children are present.
The second question involved working above ceiling tiles where asbestos was located.
Less than half of the participants have performed tasks in this situation. No special procedures
were followed, and when it was known that asbestos was present, the situations were usually
viewed as emergencies and work was performed in spite of the presence of ACBM. A few
maintenance workers appeared to be aware of asbestos in this situation and stated that they
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"stayed away" from any ACM. However, these few did remove ceiling tile where ACM was present
and worked above the tile.
Question Three dealt with cleaning in a boiler room where asbestos was located.
Approximately one-third of the participants have cleaned up areas in boiler rooms where asbestos
is present. A couple of workers used special procedures (suits, respirators, controlled disposal).
However, the other workers do not follow any special procedures, in some cases wet mopping the
area and in others, dry sweeping and dusting.
The fourth question dealt with working in a location where a pipe insulated with
asbestos had leaked, damaging less than three linear feet. This situation occurred only in three
focus group locations. In one, appropriate procedures were followed in most cases. However, in
one school special crews that came in to repair the damage created additional damaged ACBM
and did not clean up. There were a few cases where maintenance workers have repaired
insulation, and simply threw it away, not following any recommended procedures. One custodian
reported cleaning up a pipe leak, and when a plumber was called, the plumber would not touch the
pipe as it was insulated with ACBM. In several location, focus group participants reported that
ACBM cleanup or repair was performed by a special LEA-employed asbestos team. This study
did not attempt to collect data on the training or activities of these teams.
There were no cases of greater than three linear feet of damaged ACBM having been
damaged or repaired.
There are other types of jobs performed around asbestos, most of which concern vinyl
asbestos tile (VAT). In a few cases, appropriate procedures seem to be followed in buffing the
tiles. However, there are many schools and specific situations where VAT is dry buffed. Also, in
most cases when the tile is damaged and crumbling, it is simply picked up and thrown away.
Several participants who reported having removed VAT without using any special procedures
believed their use of heat guns was good work practice.
Other jobs around asbestos are dry sweeping floors next to pipes insulated with
ACBM, removing ceiling tiles, and minor maintenance work around boilers, such as removing an
asbestos insulation plug to drain the boiler. Also, plaster repair work around ACBM was reported.
In most cases, appropriate techniques were not used in these circumstances.
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Much work is done around asbestos without following appropriate work procedures.
In many cases this is due to what is considered to be an emergency situation, (not an asbestos
emergency, but a maintenance emergency) and in other cases it is because workers have not been
told what appropriate procedures are or whether or not the material contains asbestos. One
participant said, "They callyou in, you don't know what you're getting into, [or] how to prepare for it."
An additional interesting finding of the focus groups was that many maintenance and
custodial workers are concerned about the security of their jobs if they "say anything about
asbestos" or if they take the time to follow appropriate working practices around asbestos. Only
one of the maintenance workers, and none of the custodial workers, had specifically faced the loss
of his job over asbestos issues, however.
Several maintenance workers have respirators available, but only in a few cases have
they been used. In some cases, the respirators are available for anyone to use, and in others they
are assigned to one particular user. • Moreover, none of the respirators issued meet OSHA
standards for fit testing or administrative controls for issuance. In one school system, maintenance
workers obtained school funds and purchased the respirator. Even among those who have been
issued respirators, most maintenance workers have chosen not to use a respirator.
A majority of the maintenance workers were aware of Management Plans, and several
had either used their school's Plan to determine the location of ACBM or simply had familiarized
themselves with the content. Some found the Plans difficult to work with, and others felt them to
be relatively easy to understand. Only a very few custodians had any awareness of a Management
Plan. Only one person thought there might be an Operations and Maintenance (O&M) plan
specific to his school in a Management Plan. The other participants followed what they considered
a verbal O&M plan when special precautions were taken around ACBM.
Not all areas with ACBM were labeled in the schools whose maintenance and
custodial staff participated in the focus groups. In particular, there was concern that a label does
not show clearly which material in an area contains asbestos.
The maintenance and custodial workers who participated in these groups have a
strong sense of pride in their jobs, especially as they relate to providing a safe and clean
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environment for the children. They are all concerned about the children's safety, perhaps in many
cases more than their own. There is a sense of frustration and fear in some cases of not knowing
whether or not what they are doing on a daily basis is hurting or helping reduce risk to the school
population. In some cases, if a problem concerning asbestos is brought to a supervisor's attention,
it is handled appropriately. In many more cases, there is concern for job security.
8.4 Summary
Chapter 8 has responded to questions involving maintenance workers and custodians
training and responsibilities in the wake of AHERA. The ADPs reported that 87 percent (+. 9%)
of maintenance workers and 95 percent (±_ 6%) of custodians are trained by schools, but that 74
percent (.+. 5%) of maintenance workers trained are trained for less than the 16 hours called for by
AHERA for workers who work around or disturb ACBM. By contrast, only 5 percent (.+. 6%) of
custodians are trained for less than the two hours required by AHERA for basic awareness.
However, if custodians work around or disturb ACBM, 83 percent (+. 8%) have received less than
16 hours of training. All of these comparisons are statistically significant at the 95 percent
confidence level.
The visions of reality presented by ADPs in interviews with them and by maintenance
workers and custodians in focus groups contain certain differences. In general, ADPs presented a
picture of training promptly given, though frequently shorter than AHERA stipulates for staff who
work directly with asbestos. ADPs also presented a vision of training that included extensive and
often multiple presentation of the locations of ACBM.
In contrast, several participants in the focus groups did not remember being trained,
or if they did, felt that it was no more than "showing a video." The untrained workers, as well as
some of the trained workers also expressed concern about not knowing where ACBM was located
in their schools, or how to handle it properly.
The focus group results show that the majority of maintenance workers received the
16-hour AHERA-specified training, and most custodial workers have received a two-hour
awareness training. Curricula were generally consistent for both groups. The participants in these
five focus groups appeared to be aware of asbestos. However, quite a few did not really know
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much about it, nor where it was located in their schools. Most wanted more information and
training, especially about health effects and how to recognize asbestos. While the training that is
provided appears to meet the requirements of AHERA for maintenance workers, most custodians
who work around ACBM did not receive 16 hours of training. A significant number of participants
felt that they did not have the knowledge and information they needed to do their jobs safely. The
larger issue is that not all maintenance and custodial workers are being trained as required by
AHERA.
The final questions in this research area relate to tasks maintenance workers and
custodians are responsible for around ACBM. Even though training appears to be adequate time-
wise for the majority of maintenance workers and most custodial workers, the focus group findings
in this area show that frequent unprotected and inappropriate work practices are being used by
both types of workers in schools in the five communities in which focus groups were held. On the
whole, these inappropriate work practices were performed to clean up fiber release episodes of
less than 3 linear or square feet, or as routine maintenance/custodial activities. Because the
workers are unaware that a material might contain asbestos, because of inadequate or no training,
or because of pressure to act immediately in an "emergency" situation, exposure to asbestos is
occurring and appropriate procedures are being followed in only a few cases. Most workers did
not express concern that they might be disturbing asbestos and creating a health hazard when they
removed suspended ceiling tiles or brushed against insulated pipes. ACBM was seen as being
disturbed only when it was sawed, cut, or in some other way visibly damaged.
Respirators were unavailable to custodians and when available to maintenance
workers, were so often on a shared basis. Even when available respirators are rarely used.
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9. OTHER FINDINGS
Chapters 3 through 8 of this final report have described the findings of the
evaluation stemming from the six research areas specified by the EPA. As Westat performed
the data analysis for these research areas, however, three types of findings outside the official
design of the evaluation emerged.
The first of these areas emerged from an analysis of the results of the screener
questionnaire, and sheds some light on possible levels of compliance with AHERA in schools
nationwide. The second area involves the types of clearance air monitoring tests used by
schools that have a Management Plan, and the third area reports on the condition of ACBM
in schools currently.
9.1 Possible Compliance with AHERA
Chapters 3 through 8 report findings on how well LEAs, and the inspectors and
Management Planners they hired, have complied with AHERA, given that they attempted to
comply. We now turn to estimation of the number of LEAs that did not even attempted to
comply with AHERA. Data for this estimation come from the telephone screening interview
we conducted with 1,041 ADPs primarily to determine the school's eligibility for the study. As
such, the data only indicate possible noncompliance inferred from the ADP's responses. We
have no direct proof of deliberate noncompliance by any LEA.
The structure of the screening questionnaire called for terminating the questions
about a school or school building as soon as a negative answer was given to any question. A
negative answer indicated that the school or school building was ineligible. A summary of the
structure of this questionnaire follows:
School questions
(asked for each school in the screener sample)
1. Does the school currently have classes in any of grades 1-12?
2. Does the school have an asbestos Management Plan?
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Building Questions
(asked for each building the ADP told us was at the school)
3. Was the building built before October of 1988?
4. Has the school building been inspected for asbestos since December 1987?
As previously mentioned, a "No" answer to any of these questions stopped the
interviewer from asking any additional questions about the school for school-level questions,
or the building for building-level questions. Questions 1 and 3 above do not relate to a
school's compliance with AHERA; however, negative answers to Questions 2 and 4 indicate
possible non-compliance with AHERA. Table 9-1 below shows the weighted frequency of
answers to these questions and the percent of schools not contacted at the screener stage, the
percent of schools refusing to participate in the screener, and the percent eligible for the
study.
Table 9-1. Estimated national percent of schools with selected responses to screening
interview
Schools
Not contacted
Refusal at screener
No Management Plan
Building not inspected
Some
All
Eligible
Refused inspection
Ineligible for reasons not
associated with compliance
Reported percent
of schools
4%
6%
1%
3%
1%
72%
14%
1This is the percentage in the sample, not the estimated national percent.
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A lower bound for the incidence of possible noncompliance can be constructed
from the data in Table 9-1. The estimate is 4 percent of schools nationally are out of
compliance with AHERA in that they have not prepared a Management Plan, or that they
have not inspected all of their school buildings for ACBM. This is a low estimate of possible
non-compliance because noncontacted schools and schools that refused at the screener stage
are not included in this estimate at all. These two types of respondents together account for
10 percent of all schools and it must be assumed that an unknown nonzero percentage of these
schools have not complied with AHERA. Moreover, while we assume that most respondents
answered our questions honestly and accurately, only 76 percent of schools we invited to
participate in the evaluation did so. Some of the schools that refused said that they did not
have the staff to allow us to visit, while others were in LEA's that had several other schools in
the study, and therefore may have decided that had "done their bit for the evaluation". It is
possible, however, that some of the schools that refused when invited to participate in the
study had not complied with either the inspection or Management Plan preparation aspect of
the regulation.
Table 9-2 presents four separate estimates for the overall rate of noncompliance
with the Management Plan and inspection portions of AHERA. They vary in their underlying
assumptions about the extent of noncompliance with AHERA among the noncontacts,
screener refusals and inspection refusals. The lowest estimate is the 4 percent discussed
above; it assumes that all noncontacts and refusals are in compliance. This estimate increases
to 7 percent if the percent of schools out of compliance with this aspect of AHERA is
assumed to be the same in the not contacted and refusals as it was in the rest of the
population. A mid-level estimate of 17 percent noncompliance with inspection and
Management Plan components of AHERA follows from the assumption that half of the not
contacted schools and schools that refused at the screener and field stages are not in
compliance. The upper bound estimate is set by assuming that all of the schools not contacted
and refusals at the screener stage and all of the refusals at the field stage are not in
compliance with these elements of AHERA. Our estimate of this upper bound is 31 percent.
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Table 9-2. Estimates of noncompliance with the Management Plan and inspection portions
of AHERA under various assumptions
Assumption
Percent of
schools estimated
Noncontacts and refusals at screener
all in compliance
Noncontacts and refusals at screener
and field stages in compliance at same
rate as other screener schools
Noncontacts and refusals at screener
and field stages hah7 not in compliance
All of the noncontacts and refusals
at screener and field stages not in
compliance
4%
17%
31%
The data generated for the AHERA screening are not able to determine which of
these estimates is closest to accurate, nor are we able to put confidence intervals on these
estimates. It seems possible, however that the best estimate is somewhere in the middle of the
range, perhaps between 1 and 17 percent.
-9.2
Clearance Air Monitoring Tests Performed
Table 9-3 presents our findings on the types of air-sampling presented in the
estimated 15,614 Management Plans that presented this type of findings. This information is
interesting for the light it sheds on the types of clearance air sampling testing used in schools
nationwide.
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Table 9-3. Percent of Management Plans that contained air sampling results that used
Transmission Electron Microscopy (TEM) and Phase Contrast Microscopy
(PCM) for their tests
TEM
PCM
Yes
8%
95%
No
91%
5%
N = 15,614
This table shows that only 8 percent of schools presenting air clearance results
have performed TEM. AHERA requires TEM to be used for clearance testing for all but the
smallest abatement projects. TEM is more costly than PCM, but is superior to PCM in
identifying and quantifying airborne asbestos. The increasing use of TEM was phased in
between 1987 and 1990. Table 9-2 shows that TEM is still not being used extensively.
93 Current Assessment of Suspect Material hi Schools
This section presents findings on the assessment of the asbestos in schools at the
time of the reinspections in the Spring of 1990. During the reinspection of schools in for the
AHERA evaluation, the condition of each suspect material was assessed. This assessment
placed each material into the seven assessment categories specified by AHERA. The seven
categories are as follows:
1. Damaged or significantly damaged TSI ACM.
la. Damaged TSI ACM.
Ib. Significantly damaged TSI ACM.
2. Damaged friable surfacing ACM.
3. Significantly damaged friable surfacing ACM.
4. Damaged or significantly damaged friable miscellaneous ACM.
4a. Damaged damaged friable miscellaneous ACM.
4b. Significantly damaged friable miscellaneous ACM.
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5. ACBM with potential for damage.
6. ACBM with potential for significant damage.
7. Any remaining friable ACBM or friable suspected ACBM.
In addition, Westat divided AHERA categories 1 and 4 into two subcategories
each (la, Ib, 4a, and 4b) to differentiate between damaged and significantly damaged ACBM.
This is done for surfacing materials in AHERA categories 2 and 3. This, more detailed
assessment strategy will be called the expanded 1-7 AHERA assessment categories.
The Westat assessment protocol called for an assessment of each suspect
material in each area where it was encountered. The following questions were answered in
conducting each assessment:
• Is the material friable?
• Which of the following best describes its current level of local damage;
<1%, 1-25%, or > 25%?
• Which of the following best describes its current level of dispersed damage;
<1%, 1-10%, or > 10%?
• Is there a potential for water damage?
• Is there a potential for damage because this is a general access area?
• Is the potential for damage through maintenance access low or high?
• Is the potential for damage through air velocity none, low or high?
• Is the potential for damage through the effects of vibration low or high?
Each possible combination of answers to these questions, in combination with
specification of the material category (TSI, surfacing or miscellaneous) leads to both an
AHERA 1-7 and an expanded assessment. For example, suppose a miscellaneous friable
material is locally damaged in the 1-25% range and has dispersed damage in the < 1% range.
Then it is in AHERA assessment category 4 and expanded category 4a. If, instead, the
material has both local and dispersed damage in the < 1% range, and has no threat of damage
from water or because it is a general access area, has only a low potential for damage through
maintenance activity, and only a low risk of damage through air velocity or the effects of
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vibration the material is in AHERA category 7. Appendix L contains tables that show how
assessment scores were assigned to each combination of responses.
Using the method described in the introduction to Chapter 3, each suspect
material discovered in the reinspection was compared with the materials discovered at the
time of the original AHERA inspection, and Westat determined if each material was ACBM
or not. Table 9-4 shows the quantity of ACBM in thousands of square and linear feet, as
appropriate, in each of the AHERA categories at the time of the reinspection. It also shows
the quantity in each of the expanded categories. Table 9-5 presents the corresponding
percentages. The "Not applicable" rows in Tables 9-5 and 9-6 refer to material not assessed
because it was non-friable.
Table 9-4 shows that categories 4 and 6 have the largest number of square feet:
category 4 (damaged or significantly damaged friable miscellaneous ACM) has 231 million
square feet of ACBM and category 6 (ACBM with potential for significant damage) has 237
million square feet. Most material in AHERA category 4 is in expanded category 4a
(Damaged damaged friable miscellaneous ACM). AHERA category 6 permits miscellaneous
materials, and the quantity of material in it is also potentially inflated by the large quantities
of floor tile and ceiling tile in schools.
Table 9-5 looks at this question from the perspective of the percent of ACBM in
each AHERA category at the time of reinspection. This table shows that overall 6 percent of
ACBM measured in square feet (3% of TSI, 1% of surfacing and 2% of miscellaneous) is
currently significantly damaged. It also shows that just over 8 percent of ACBM (< 1% of TSI,
a very small quantity of surfacing and 8% of miscellaneous) measured in square feet is
currently in damaged condition.
9-7
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Table 9-4 Amount of ACBM material In each AHERA category at time of reinspection, by material type and unit of measurement
AHERA category
1
la
1b
2
3
4
4a
4b
5
6
7
Damaged or significantly
damaged TSI ACBM
Damaged TSI ACBM
Significantly damaged TSI ACBM
Damaged friable surfacing ACBM
Significantly damaged friable
surfacing ACBM
Damaged or significantly damaged
friable miscellaneous ACBM
Damaged friable miscellaneous ACBM
Significantly damaged friable
miscellaneous ACBM
ACBM with potential for damage
ACBM with potential for
significant damage
Any remaining friable ACBM or
friable suspected ACBM
All categorized materials
Not applicable
All materials
Amount of ACBM materials (000)
Quantity In linear feet
Miscellaneous
..
„
mr
..
..
TSI
24,693
12,632
12.061
13,843
20,928
59.567
59,567
All
materials
24.693
12.632
12.061
..
13,843
20.928
61.104
..
61.104
Quantity In square feet
Miscellaneous
231.299
182,531
48,768
144,147
206,428
581,874
1,486,351
2,070,795
Surfacing
„
13.694
19.760
17.678
57,945
11.255
69,200
TSI
63.006
3.417
59.589
5,124
12.928
81.344
81,344
All
materials
63,006
3,417
59.589
„
13,694
231,299
182,531
48,768
169,031
237.034
721.162
1,497,665
2,221,339
- The sample size was too small for reliable estimation.
A blank Indicates an empty cell.
-------
Table 9-5 Percent of ACBM material in each AHERA category at time of relnspection, by material type and unit of measurement
AHERA category
1
la
1b
2
3
4
4a
4b
5
6
7
Damaged or significantly
damaged TSI ACBM
Damaged TSI ACBM
Significantly damaged TSI ACBM
Damaged friable surfacing ACBM
Significantly damaged friable
surfacing ACBM
Damaged or significantly damaged
friable miscellaneous ACBM
Damaged friable miscellaneous ACBM
Significantly damaged friable
miscellaneous ACBM
ACBM with potential for damage
ACBM with potential for
significant damage
Any remaining friable ACBM or
friable suspected ACBM
All categorized materials
Not applicable
All materials
Percent of ACBM materials
Quantity In linear feet
Miscellaneous
..
„
..
..
..
TSI
41%
21%
20%
23%
35%
100%
100%
All
materials
40%
21%
20%
..
23%
34%
100%
..
100%
Quantity In square feet
Miscellaneous
11%
9%
2%
7%
10%
28%
72%
100%
Surfacing
._
20%
29%
26%
84%
16%
100%
TSI
77%
4%
73%
6%
16%
100%
100%
All
materials
3%
<1%
3%
mm
1%
10%
8%
2%
8%
11%
32%
67%
100%
- The sample size was too small for reliable estimation.
A blank Is an empty cell.
-------
PEER REVIEW DRAFT
10. STATISTICAL PROPERTIES OF THE SAMPLE
10.1 Response Rates for the AHERA Evaluation
10.1.1 Building Access Results
The sampling protocol for this study was described briefly in Chapter 2 and is
described in more detail in Appendix K, section K.1.1. That chapter explained that the sample of
schools and buildings for AHERA was selected in several stages. PSUs were selected at the first
stage, an initial screening sample of schools was selected within the sampled PSUs at the second
stage, a primary sample of schools was selected from those schools eligible after screening at the
third stage, and buildings were selected from participating schools at the fourth stage. Table 10-1
below summarizes the participation status of the schools in the screener sample and primary
sample.
Table 10-1. Participation status of schools in the sample
Stage of sampling
Screener Sample
Primary Sample
Total
1,041
200
Eligible
750
151
Ineligible
193
1
Refusal
63
48
No contact
35
0
Note that one school in the primary sample was ineligible (because it did not contain
any of grades 1 through 12), even though it had been screened as eligible. In the AHERA
evaluation, substitutes were identified to replace 47 of the 48 refusing schools in the primary
sample, for a final sample of 198 schools. Substitutes were taken from the same PSU or
PSU/remediation status category as the original selection; there was no available substitute in one
case. Either one or two buildings were selected from each participating school, for a total of 207
sampled buildings.
The same sample of schools and buildings was used in several research areas (RAs).
For RA4 and part of RAS, information about the sampled schools was collected from "samples" of
10-1
-------
PEER REVIEW DRAFT
parents, teachers, and original inspectors. Table 10-2 shows the number of sampled schools
providing useable data for RA4 and part of RA5.
Table 10-2. Final completion status for schools in RA4 and RA5
Research Area
4 Original Inspectors
5-Parent Notification
5-Teacher
Notification
Total
198
198
198
Useable
134
157
164
Unable to
locate
64
41
34
Refused
4
1
5
No potential
respondent
named
1
10
6
Ineligible
0
3
4
Deceased
1
0
0
The "refused" cases for RA5 are those in which the principal declined to supply names
of potential parent and teacher respondents during the interview. The "no potential respondent
named" cases are those in which no parent and teacher names were received after the interviewer
left postcards with the principal for this purpose. Finally, the "ineligible" cases in RA5 were
parents or teachers who were not involved with the school during the time of asbestos notification.
Nonresponse may occur at any stage of sampling and is different for the different
RAs. The overall response rate for a given RA is the product of the response rates at each stage
of sampling. Substitute schools are not considered responding when determining the response
rate. With this in mind, the response rates for the different research areas in the AHERA
evaluation are given below in Table 10-3.
10-2
-------
PEER REVIEW DRAFT
Table 10-3. Response rates for AHERA (%)
Research area
1
2
3
4
5-Principals
5-Parents
5-Teachers
6
Screener
sample
90.6
90.6
90.6
90.6
90.6
90.6
90.6
90.6
Primary
sample
76.0
76.0
76.0
76.0
76.0
76.0
76.0
76.0
Building
sample
100.0
X
100.0
X
X
X
X
X
Original
inspector, parent
or teacher sample
X
X
X
67.7
X
793
82.8
X
Overall
68.8
68.8
68.8
46.6
68.8
54.6
57.0
68.8
The response rate is an Indicator of the quality of the data. To the extent that the
nonresponding schools are different than the responding ones, estimates produced from the data
are biased and may not accurately reflect the characteristics of the population. In the next section,
we will compare the distribution of the responding and nonresponding schools at each stage of
sampling, to judge how well our sampled schools can represent the overall school population.
10.12
Potential for Bias
Table 10-4 summarizes the numbers of sampled schools at each stage of sampling by
Census region, urbanicity, type of control, and enrollment size class. The table offers descriptive
information only. Comparing the different stages of sampling (i.e., different columns in the table)
is inappropriate. In fact, differences are expected for three reasons:
1) Schools were not selected with equal probability at the screening stage or the
primary sampling stage. An equal-probability sample was attempted during
screening but was not attained in some of the small PSUs. This means that
schools with different demographic characteristics were selected at different
rates, which causes the proportion of schools in a given category to vary at each
stage of sampling. For example, note that rural schools account for 37 percent
of the universe but only 21 percent of the screener sample. This is partly due to
the fact that rural schools were sampled at lower rates than urban and suburban
schools. As another example, note that private schools account for 9 percent of
the eligible schools but only 3 percent of the primary sample. Due to the
10-3
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PEER REVIEW DRAFT
Table 10-4. The schools in the AHERA evaluation by certain demographic variables at various
stages of sampling
Census region:1
Northeast
South
Midwest
West
Urbanitity.
Urban
Suburban
Rural
Type of control:
Public and other
Catholic
Private
Enrollment size class:
<300
300-999
1,000 +
QED Universe
counts
N . %"
20,178 19.1
33,284 315
30,529 28.9
21,810 20.6
105301 100.0
25,750 243
41^03 38.9
38,848 36.7
105,801 100.0
81,956 77.5
9,009 85
14,836 14.0
105,801 100.0
45,448 43.0
53,000 50.1
105,801 7.0
105,801 100.0
Screener
sample
N ~ %
204 19.6
380 36,5
282 27.1
175 16.8
1041 100.0
321 30.8
500 48.0
220 21.1
1041 100.0
778 74.7
95 9.1
168 16.1
1041 100.0
426 40.9
535 51.4
80 7.7
1041 100.0
Elig. After
screening
N. %
159 212
272 363
201 26.8
118 15.7
750 100.0
222 29.6
370 493
158 21.1
750 100.0
611 815
70 93
69 9.2
750 100.0
258 34.4
426 56.8
66 8.8
750 100.0
Primary
sample
N %
48 24.0
68 34.0
54 27.0
30 15.0
200 100.0
66 33.0
92 46.0
42 21.0
200 100.0
171 855
23 115
6 3.0
200 100.0
62 31.0
119 595
19 95
200 100.0
Final
sample
.N %
47 23.7
68 34.3
54 273
29 14.6
198 100.0
65 32.8
92 465
41 20.7
198 100.0
169 85.4
23 11.6
6 3.0
198 100.0
59 29.8
121 61.1
18 9.1
198 100.0
1 Northeast: ME, VT, NH, MA, CT, NY, PA, NJ, RI
South: MD, DE, DC, WV, VA, KY, NC, TN, AR, OK, TX, LA, MS, AL, GA, SC, FL
Midwest: ND, MN, WI, MI, SD, IA, IL, IN, OH, NE, KS, MO
West: WA, ID, MT, OR, WY, CA, NV, UT, CO, AZ, NM, AK, HI
10-4
-------
PEER REVIEW DRAFT
limited sample size and the importance of controlling for other variables
during sampling, type of control was not a controlling variable when selecting
the primary sample. Thus private schools were sampled at a lower rate that
other types of schools.
2) Recall that 30 PSUs were sampled before selecting the schools for screening.
The difference between the universe counts and the screener sample in part
reflects the kinds of schools in the selected PSUs.
3) Schools had different rates of eligibility for the AHERA evaluation depending
on their demographic characteristics. For instance, public schools and medium-
sized schools tended to be eligible more often than other types of schools. On
the other hand, private schools and small schools tended to be ineligible more
often than others.
The above issues are directly related to the sampling methods used in the AHERA
evaluation. They represent the trade offs between cost, precision, and bias that one must make
when designing and implementing any research effort. While the above issues may affect the
sampling errors associated with the results of the AHERA evaluation (see section 10.2.3), they do
not incurr a potential for bias. In fact, the sampling methods used for the evaluation are unbiased
with one possible exception. Recall from Section 2.1.2 that not all private schools are included in
the QED file used for sampling. Because the excluded private schools represent only about 2
percent of all schools in the nation, this exclusion is unlikely to cause significant bias. In addition,
private schools tend to be small and therefore do not account for large part of the total ACBM
present. We now look at the potential for nonresponse bias in the AHERA evaluation.
Table 10-5 compares the distribution of the responding schools in the primary sample
versus the nonresponding schools in the primary sample. With the possible exception of type of
control, the distribution of the nonresponding schools is not significantly different from that of the
responding schools for the characteristics shown in the table. Although the final sample includes
47 substitute schools, it seems comparable to the primary sample on Census region, urbanicity,
type of control, and enrollment size class. To the extent that these characteristics are related to
the estimates produced by the AHERA evaluation, and to the extent that the responding schools
do not differ from the nonresponding ones on the items of interest, the nonresponse bias in the
final sample will be minimal. Unfortunately, it is difficult to determine the exact nature of this bias
without collecting extensive information on the nonresponding schools, which is not possible. In
addition, note that the "final sample" described above includes the responding schools for most
10-5
-------
PEER REVIEW DRAFT
research areas, but not all of these schools had useable data for RA4, RA5-parents, and RA5-
teachers. Thus there is increased potential for bias in these research areas.
Table 10-5. The schools in the primary sample by response status and certain demographic
variables
Census region:!
Northeast
South
Midwest
West
Urbanicity:
Urban
Suburban
Rural
Type of control:
Public and other
Catholic
Private
Enrollment size class:
<300
300-999
1,000 +
Primary sample
responding
N
34
53
41
23
151
51
72
28
151
127
22
2
151
41
97
13
151
%
22.5
35.1
212
152
100
33.8
47.7
18.5
100.0
84.1
14.6
13
100.0
272
642
8.6
100.0
Primary sample
non-responding
N
14
15
13
7
49
15
20
14
49
44
1
4
49
21
22
6
49
%
28.6
30.6
26.5
143
100.0
30.6
40.8
28.6
100.0
89.8
2.0
8.2
100.0
42.9
44.9
12.2
100.0
1 Northeast ME, VT, NH, MA, CT, NY, PA, NJ, RI
South: MD, DE, DC, WV, VA, KY, NC, TN, AR, OK, TX, LA, MS, AL, GA, SC, FL
Midwest ND, MM, WI, Ml, SD, IA, IL, IN, OH, NE, KS, MO
West WA, ID, MX, OR, WY, CA, NV, UT, CO, AZ, NM, AK, HI
10-6
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PEER REVIEW DRAFT
102 Methodology for Weighting, Imputation, and Variance Estimation
102.1 Weighting Methodology for the AHERA Evaluation
As we stated in Section 2.1, schools were selected for inclusion in the AHERA
evaluation in three stages. Thirty PSUs were selected at the first stage, 1,041 schools were selected
for screening at the second stage, and 200 schools were selected from those eligible after screening
at the third stage. In addition to this final sample of 200 schools, back-up and replacement
samples were selected to allow substitutions of nonresponding schools if necessary. The AHERA
evaluation is composed of six distinct research areas which study issues either at the school or
building level. One or two buildings were selected from each of the final, backup, and
replacement schools to facilitate work in the research areas with building level analyses. In some
cases, buildings were later resampled in the field.
In probability sampling like that used to select the schools and buildings for the
AHERA evaluation, weighting the sample is intended to accomplish two ends. First, sample
weights reflect the fact that not all schools and buildings participating in the evaluation studies
were sampled with the same probability. Second, sample weights reduce bias by compensating for
differing patterns of nonresponse. Estimates based on weighted data apply to the population from
which the sample was drawn, while estimates based on unweighted data describe only the sampled
units. The data for each of the six research areas in the AHERA evaluation were weighted using
the procedures explained in Appendix K.
10.2.2 Imputation for the AHERA Evaluation
There are usually two kinds of nonresponse in a survey. Case nonresponse occurs
when potential respondents do not provide any usable data. These respondents may not
participate in the survey at all, or they may appear to participate but not provide any usable data,
for example, by choosing "Don't know" for every item. On the other hand, item nonresponse
occurs when respondents complete most of the survey except for a few items.
Sample estimates are usually adjusted to compensate for both kinds of nonresponse
so that they more accurately reflect the corresponding population totals. Case nonresponse is
10-7
-------
PEER REVIEW DRAFT
generally handled during data weighting. Potential respondents are grouped into cells based on
variables thought to be related to the estimates of interest. Then the responding cases are used to
represent the nonresponding ones within each cell. For example, suppose that 40 schools were
selected from a certain PSU to be in a national study, but only 30 participated. Assuming that the
schools were selected with equal probability, estimates based on the 30 schools would be multiplied
by 1.33 (40 (30) to account for the nonresponding schools in that PSU. Similar adjustments would
be made in the remaining PSUs so that estimates produced from all responding schools would
reflect the corresponding values for entire country. The extent of case nonresponse in the
AHERA evaluation and the procedures used to compensate for it are described in Sections 10.1
and 10.2.1, respectively.
To make up for item nonresponse in surveys, the missing data are often imputed
during the analysis stage. Two commonly used methods of imputation are "cold deck" and "hot
deck". Cold deck methods use outside information from previous surveys to impute for missing
items, and hot deck methods use the information available from the current sample for
imputation. In general, hot deck methods were used in the AHERA evaluation. Some
questionnaire items needed no imputation at all. When imputation was performed, the amount of
imputation ranged from less than 1 percent to 18 percent for any given item. A detailed
description of the imputation methods used in the AHERA evaluation is contained in Appendix K.
10.2.3 Variance Estimation
The results in the AHERA evaluation are estimates based on a sample of schools
selected from the population of eligible schools across the country. When probability methods are
used to select the schools, different samples will yield different results. The differences between
sample results and the corresponding population values are called sampling errors, and may be
quantified by calculating standard errors and forming confidence intervals. For example, a 95
percent confidence interval may be interpreted as follows:
Suppose that samples of the same size and design are drawn repeatedly from a given population
and estimates of interest, such as totals or percents, are calculated for each sample. A 95 percent
confidence interval may be calculated for each sample as the sample estimate plus or minus 2
standard errors. 95 percent of these intervals would include the population value of the statistic
of interest.
10-8
-------
PEER REVIEW DRAFT
Intervals with different "levels of confidence" may be constructed by multiplying the
standard error by different factors. For example, a 90 percent confidence interval is calculated as
the sample estimate plus or minus 1.6 times the standard error. Thus one cannot determine a
population value exactly from a sample, but the sample estimate and its standard error can be used
to determine a range of values in which the population value is expected to lie with a high degree
of confidence.
Sampling errors are often presented in relative terms by using a quantity called the
coefficient of variation. The coefficient of variation (CV) is the standard error of an estimate
divided by the estimate. The CV expresses the standard error in relative terms without regard to
the magnitude of the statistic itself. For example, consider the results below (they are used only as
an example and do not represent actual results):
Statistic of Interest Sample Estimate Standard Error 95% Confidence Interval CV(%)
Total sq.ft. of ACM found 20,000,000 450,000 19,100,0001020,900,000 2.2S
in schools nationwide
Percent of schools nationwide 70 3 60 to 80 4.29
that found any ACM
The first confidence interval may seem less precise than the second (i.e., exhibit
greater relative variability) because the numbers involved are so large. However, note that the
coefficient of variation in the first case is 2.25 percent versus 4.29 percent in the second case, so
the estimate for the first statistic is actually more precise than the second (i.e., exhibits less relative
variability).
The methods used for variance estimation are described in detail in Appendix K.
Ninety-five percent confidence intervals and coefficients of variation for the AHERA
results may be found in Appendix I. Note that sample estimates by themselves provide no
information about the reliability of the estimates. However, these estimates together with the
information in Appendix I provide useful information about the precision of the estimates that is
necessary for the meaningful interpretation of the survey results.
10-9
-------
PEER REVIEW DRAFT
APPENDIX A
AHERA EVALUATION DATA COLLECTION FORMS
A-l
-------
AHERA SCHOOL SCREENER
S-1. VERIFY LABEL ON FRONT PAGE BY READING TO THE AHERA DESIGNATED
PERSON THE SCHOOL NAME. ADDRESS. AND PHONE NUMBER. AND THE
PRINCIPAL NAME. MAKE THE NECESSARY CHANGES.
limo^^«o««hyouton«rnetr»bufcfinoithatm«k»up(NAMEOFSCHOOL). HfNAME
OF SCHOOL) ha* two anjeturet thannp, «n Interior waJL count thto n • thigto buBdhg. If
thb school has two ttructum connected fifjfe by •bove-ground or underground walkways,
phase count I at two Mparatt buddings.
S-2.
Don (NAME OF SCHOOL) currently have classes In any of grades 1 through 127
YES 1
NO 2 (AFTER PROBING. TERMINATE
AND PROCEED TO NEXT SCHOOL.
IF THERE 13 ONE)
DK 8
S-3.
Doe* this school have m
age
nt plan?
YES ....
NO.
DK..
1
2 (TERMMATE AND PROCEED
TO NEXT SCHOOL, f THERE IS ONE)
B
84.
PIMM mm* •> bufldTnoj «t (NAME OF
SCHOOL). Mud«ilp«nimnt«nd
temporary bindings. Feel free to refer
pun. MOW would txlMlpful. (PROBE
WHEN ALL ARE LISTED: Arattwramy
oHMCbuMlnai?)
01.
02.
03.
04.
84.
WM (NAME OF
BULDMQ/
SCHOOL) bu«l
befoie October
1988?
YES . 1»
NO . 2
KIOTO
NEXT
BULDMQ)
YES — 1,
DK 8'~*
NO 2
1
(GOTO
NEXT
BULDMQ)
YES 1,
DK 8* "*
NO. 2
(GOTO
NEXT
BULDMQ)
YES 1)
DK 8' "*
NO 2
1
(00 TO
NEXT
BULDNQ)
84.
HM (NAME OF
BULDMQ/
SCHOOL) bMn
Inspected for
nbntoi dno*
DMMTibw 1987?
YES... 1 -»
DK — S (84)
NO 2
(QOTO
NEXT
BULDMQ)
YES... 1 •*
DK ...... S (84)
NO .... 2
(QOTO
NEXT
BULDMQ)
YES... 1 -»
DK ...... 8 (84)
NO ..... 2
(GOTO
NEXT
BULDMQ)
YES 1 -»
OK 8 (84)
NO .... 2
(QOTO
NEXT
BULDMQ)
8-7.
Odtr»ln»p*o-
•ondboow
•sbMlos-oon-
or Hispid ACM
ki (NAME OF
BULDMQ/
SCHOOL)?
YES ..... U
DK ..... 8' "*
NO . 2
1
(QOTO
NEXT
BULDMQ)
YES 1i
DK — e'~*
NO 2
(GOTO
NEXT
BULDMQ)
YES 1i
DK 8>~
M0- I
(QOTO
NEXT
BULDMQ)
YES 1)
DK 8* "*
NO. — 2
4
(00 TO
NEXT
BULDMQ)
84.
Antrwnilud*nlaln
(NAME OF BULDMQ/
SCHOOL) on • raeute
buto?
YES ™ l»
NO 2
1
(QOTO
NEXT
YES ..... 1 1
DK-~~ 8*"*
NO ._ 2
(QOTO
NEXT
BULDMQ)
YES 1»
OK..... 8-1"*
NO 2
I
(QOTO
NEXT
BULDMQ)
YES 1»
DK 8->~*
NO 2
(GOTO
NEXT
BULDMQ)
84.
1 im going to md you • M of budding
ita omgortM, and ok you to otuslfy
(NAME OF BULONQ/SCHOOL) Mo
Ofwofttwm. b DM id* of (NAME OF
BULDMQ/SCHOOL) . . .
i. ton tan 10.000 tq.lt, ... 1N
b. 10XO) to 49,999 tq. ft. ... 2
e. 50.00010 99.999 sq.ft.. or 3
d. 100.000 «q. It or mora? .. 4
• OK 8 .
*. tot* ttun lOXlOOiq.fL. ... 1 >
b. 10,000 to 49.999 K| 11 2
0. 50.000 to 89.999 «q. It, or 3
d. 100,000 iq. ft. or mon? .. 4
«. OK ... 8 i
S
t ka than tOXXXJtq.lt, ... ^
b. 10,000 to 49,999 iq. ft 2
C. 50,000 to89.999KI.lt. or 3
d. 100.000 K| ft or rnora? .. 4
• DK . 8 i
s
>. ton ttun 10X00 *q. ft.. ... 1 ^
b. 10.000 to 49,999 iq. ft 2
0. 50.000 to 89.999 K|. It, w 3
d. 100X100 iq. ft or mora? .. 4
• OK 8 .
s
~
-
>-*
-
S-10.
on 3 or mom Inur «Mt or 3 or mora tqun tMt of nwMrtil In (NAME OF
YES NO DK
•. R^n()v«o«i«bMlo«-eoiitaMnabi*flnamn«lh«ito«^. 1 2 8 1
or buUdingm«t»rt»l«i»um»d to contain ub««to« 1 2 8
e. p^movat of asbestos-con UtlninQ budding material or
buUdtng material assumed to contain asbestos 128
b. Encapsulation of asbestos*
-------
[AFFIX LABEL HERE]
U.S. ENVIRONMENTAL PROTECTION AGENCY
AHERA EVALUATION STUDIES
FORM A1: AHERA Designated Person Interview
March 1990
Westat, Inc.
1650 Research Boulevard
Rockville, MD 20850
-------
AHERA
Form A1: AHERA Designated Person Interview
Start time:
am
~pm
L1. IS THIS THE FIRST SCHOOL IN THIS LEA DISCUSSED WITH THE RESPONDENT?
YES 1
NO 2 [SKIP TO BOX 3]
BOX1
Hello, (AHERA DESIGNATED PERSON'S NAME) my name is (YOUR NAME). I'm with Westat, a
survey research firm near Washington, D.C. The U.S. Environmental Protection Agency has asked us
to conduct an evaluation of certain aspects of the AHERA regulations. Information about each school
contacted will be kept confidential, although the results of this study will be aggregated by region and
sent to Congress in a report.
BOX 2
(NUMBER OF BUILDINGS SELECTED) building(s) from (SCHOOL NAME) (was/were) randomly
selected for inclusion in this study. We have no reason to suspect that there are any problems
associated with asbestos in (this/these) building(s).
I have come to you for information relating to asbestos management in the school. After this
interview, we would like to conduct a building inspection in the school. You are welcome to
participate in this inspection if you would like.
During this interview, I will be asking you questions about the school, the school buildings, the school
asbestos management plan, and any asbestos response actions that may have been taken in the
school. Please feel free to refer to the school's asbestos management plan at any time to answer my
questions.
l_2. Before we get started, I would like to be sure that we have recorded your name correctly.
Is the correct spelling (SAY TITLE AND SPELL AHERA DESIGNATED PERSON'S NAME]?
YES
NO..
1
2
(CORRECT SPELLING).
-------
Form A1 (continued)
BOX 3
I'd like to start by asking you a few general questions about (SCHOOL NAME).
1
L3. Please classify the school into one of the following categories:
Public school?
Private school associated with
a religion?
Private school not associated with
a religion?
Another type of school?
(SPECIFY)
1
2
3
4
BOX 4
Now I'd like to verify which grades will be taught during the current school year at (SCHOOL NAME).
When answering this question, please give me information for the school year beginning in the fall of
1989 and ending in the spring of 1990. Do not Include summer school or night school.
L4. According to our records, some classes will be conducted in grades 1 through 12 during
the current school year. Is that correct?
YES.
NO..
OK...
1
2
8
\ [TERMINATE
J INTERVIEW]
I
Page 2
-------
Form Al (continued)
L5. As we mentioned in our letter to you, I will need to take away a copy of (SCHOOL NAME)'s
asbestos management plan. Can you please give me a copy of the management plan
now?
WHEN THE RESPONDENT GIVES YOU A MANAGEMENT PLAN: May I take this copy, or
may I photocopy it here? Westat will be happy to reimburse you for the cost of
photocopying these materials. If you will give me an invoice I will have the payment
processed. You should receive a check from Westat within the next 2 weeks.
I need to verify that I have the following information as part of (SCHOOL NAME)'s
asbestos management plan. Do the materials that you have given me include:
YES
a. The building inspector's
report from the school's AHERA
inspection for asbestos? : 1 [VERIFY]
b. Response action recommendations
made as a result of the school's
AHERA inspection? 1 [VERIFY]
c. Operations and maintenance (O&M)
plan for the school in response to
AHERA? 1 [VERIFY]
d. Copies of documentation from all
notifications to parents about asbestos
In response to AHERA? 1 [VERIFY]
e. Copies of AHERA clearance air
monitoring results for response
actions completed, including
Identification of areas cleared? 1 [VERIFY]
LOCATION
NO, BUT
WILL
PROVIDE
LATER
NO,
DID NOT
PROVIDE
ATTEMPT TO OBTAIN THE MATERIALS LISTED ABOVE FROM THE RESPONDENT
BEFORE CONTINUING WITH THE INTERVIEW.
IF YOU NEED TO PHOTOCOPY THE MATERIALS. PROCEED WITH THE INTERVIEW
AND DO THE PHOTOCOPYING AT THE END.
Pages
-------
Form A1 (continued)
BOX 5
now have a few questions about custodial and maintenance staff in [SCHOOL NAME].
L6. Since October 1987, has asbestos-related training been held for:
YES NO DK
a. Custodians in this school? i7 2 8
b. Maintenance workers in this school? 1 2 8
BOX 6
IF BOTH SHADED NUMBERS ARE CIRCLED IN L6, CONTINUE.
IF ONLY ONE SHADED NUMBER IS CIRCLED IN L6, SKIP TO L20, PAGE 6.
IF NO SHADED NUMBER IS CIRCLED IN L6, SKIP TO L26, PAGE 8.
L7. Was the most recent asbestos training session conducted for both custodians and
maintenance workers, or were they trained at separate sessions?
SAME SESSION 1 [SKIP TO L20, PGI
SEPARATE SESSIONS 2
DK 8
L8. Was the most recent asbestos-related training for custodians conducted at the school or
off site?
AT THE SCHOOL 1
OFF SITE 2
BOTH 3
DK 8
L9. How many hours long was the most recent asbestos-related training for custodians?
(HOURS)
DK 98
L10. Did this training for custodians include a description of where asbestos-containing
materials were found in the school?
YES 1
wcZZZZZZTZZZZ I } ISKIPTOL^
Page 4
-------
Form A1 (continued)
L11. Did the description of these locations involve:
YES NO DK
a. A building walkthrough? 1 2 8
b. A presentation of floorplans of the building, with
the areas containing asbestos marked? 1 2 8
c. A verbal description? 1 2 8
d. Some other description? 1 2 8
(SPECIFY)
L12. Are these training sessions held:
Once a month 1
Once every 6 months 2
Once a year 3
On another schedule 8
(SPECIFY)
L13. What are the provisions for training new custodians hired after the start of the school year?
RECORD VERBATIM:
L14. Was the most recent asbestos-related training for maintenance workers conducted at the
school or off site?
AT THE SCHOOL 1
OFF SITE 2
BOTH 3
DK 8
L15. How many hours long was the most recent asbestos-related training for maintenance
workers?
(HOURS)
DK 98
PageS
-------
Form A1 (continued)
L1 6. Did this training for maintenance workers include a description of where asbestos-
containing materials were found in the school?
YES [[[ 1
' .......... '.'""."I'"... . .. ." "Z 8 } ISKIPTOL18]
L1 7. Old the description of these locations involve:
YES NO. DK
a. A buUding walkthrough? ............................................ 1 2 8
b. A presentation of floorplans of the building, with
the areas containing asbestos marked? ................... 1 2 8
c. A verbal description? ................................................. 1 2 8
d. some other description .............................................. 1 2 8
(SPECIFY) _
L18. Are these training sessions held:
Once a month 1
Once every 6 months. 2
Once a year 3
On another schedule 8
(SPECIFY)
L19. What are the provisions for training new maintenance workers hired after the start of the
school year?
RECORD VERBATIM:
[SKIP TO L26]
L20. Was the most recent asbestos-related training for custodial and maintenance staff
conducted at the school or off site?
AT THE SCHOOL 1
OFF SITE 2
BOTH 3
-------
Form A1 (continued)
L21. How many hours long was the most recent asbestos-related training for custodial and
maintenance staff?
(HOURS)
DK [[[ 98
L22. Did this training include a description of where asbestos-containing materials were found
in the school?
YES ................................... . ................... 1
DKrzirrirrzizrii I
}
L23. Did the description of these locations involve:
YES NO DK
a. A building walkthrough? ............................................ 1 2 8
b. A presentation of floorplans of the building, with
the areas containing asbestos marked? ................... 1 2 8
c. A verbal description? ................................................. 1 2 8
d. Some other description? ........................................... 1 2 8
(SPECIFY) _
L24. Are these training sessions held:
Once a month 1
Once every 6 months 2
Once a year 3
On another schedule 8
(SPECIFY)
L25. What are the provisions for training new workers hired after the start of the school year?
-------
Form A1 (continued)
L26. Are maintenance services within this school performed by:
a. School maintenance staff?
b. Private contractors?
c. Employees of the LEA not based in the school?
d. Some other arrangement?
(SPECIFY)
YES NO DK
2 8
2 8
2 8
2 8
BOX?
To make sure that we have correctly recorded the information you gave our telephone interviewer, I
would like to verify some information about the buildings that make up [SCHOOL NAME].
SKIP TO BUILDING FACTS SHEET ON YOUR CASE FOLDER. VERIFY ALL FACTS ABOUT ALL
BUILDINGS LISTED ON THE SHEET. IF THERE IS A CORRECTION. MAKE IT ON THE PHOTOCOPY
OF THE SCREENER. DO NOT WRITE ON THE BUILDING FACTS SHEET.
L27. Are there additional permanent or temporary buildings that are part of (SCHOOL NAME),
that are not included on this list?
YES.
NO
DK.
1
2
8
[FILL IN ON
PHOTOCOPY OF
SCREENER]
BOX 8
REVIEW THE PHOTOCOPY OF THE SCREENER FOR THIS BUILDING AND DETERMINE IF THERE
HAS BEEN A CHANGE IN ELIGIBILITY FOR ANY OF THE BUILDINGS AT THIS SCHOOL THIS
INCLUDES BOTH SELECTED AND NON-SELECTED BUILDINGS. IF THERE HAS BEEN A CHANGE
IN ELIGIBILITY, SELECT THE BUILDING(S) TO BE INCLUDED IN THE STUDY. IF YOU MUST
RESELECT, EXPLAIN TO THE ADP THAT YOU ARE -VERIFYING WHICH BUILDING SHOULD BE
VISITED.' TELL THE ADP THAT YOU ARE •SELECTING- ONLY IF THE BUILDING ORIGINALLY
SELECTED CHANGES. IT IS POSSIBLE YOU WILL SELECT THE SAME BUILDING THAT WAS
ORIGINALLY SELECTED.
BOX 9
GO TO FORM A2.
End time:
am
•pm
Pages
-------
OMB No. 2070-0034
Expires 6/30/90
[AFFIX LABEL HERE]
U.S. ENVIRONMENTAL PROTECTION AGENCY
AHERA EVALUATION STUDIES
FORM A2: Building Information
March 1990
Public reporting burden for this collection of information is estimated to average 30 minutes, including time for
hearing instructions, reporting information, and reviewing information.
Send comments regarding the burden estimate or any other aspect of this collection of information, including
suggestions for reducing this burden, to:
Chief, Information Policy Branch
U.S. Environmental Protection Agency
401 M Street, S.W. (PM-223)
Washington, DC 20460
and
Office of Management and Budget
Paperwork Reduction Project (2070-0034)
Washington, DC 20503
Westat, Inc.
1650 Research Boulevard
Rockville, MD 20850
-------
AHERA
FormA2: Building Information
Start time:
am
~pm
A1. HOW MANY BUILDINGS ARE LISTED ON THE INFORMATION LABEL?
ONE(1).
TWO (2).
1 [SKIP TO BOX 2]
2
BOX1
Two buildings from (SCHOOL NAME) were selected for inclusion in this study. I am going to ask you
a series of questions about each of those buildings.
The following questions are about (BUILDING1 NAME/BUILDING2 NAME).
SKIP TO BOX 3.
BOX 2
We've selected [BUILDING NAME] from this school for this study. The following questions are about
that building.
BEFORE YOU CONTINUE. BE SURE THAT YOU AND THE RESPONDENT HAVE THE SAME
UNDERSTANDING OF WHAT YOU MEAN WHEN YOU REFER TO THE BUILDING.
BOX 3
As we mentioned in our letter to you, I need to obtain two copies of the floorplans for all floors of that
building from you. We will use these floorplans to prepare for the building inspection. Do you have
those available for me now?
WHEN THE RESPONDENT GIVES YOU FLOORPLANS: May I take these copies, or may I photocopy
them here?
YOU NEED TO HAVE TWO COPIES OF THE FLOORPLAN. MARK EACH PAGE OF ONE COPY AS
'MASTER' ON THE TOP CENTER OF THE PAGE AND AFFIX SCHOOL ID LABEL TO THE TOP RIGHT
HAND CORNER. USE THIS 'MASTER" COPY FOR ALL MARKINGS.
-------
Form A2 (continued)
BOX 4
VERIFY THAT THE FLOORPLANS HAVE THE FOLLOWING INFORMATION. IF ANY INFORMATION
IS MISSING. ASK THE RESPONDENT TO SUPPLY IT. CHECK OFF EACH ITEM AS YOU OBTAIN IT.
1.
D
LAYOUT OF ALL FLOORS. [PROBE FOR ATTIC.
BASEMENT]
IF THE RESPONDENT CANNOT SUPPLY FLOORPLANS FOR ALL FLOORS OR AREAS. LIST IN BOX
5 THE FLOORS OR AREAS FOR WHICH YOU DO NOT HAVE FLOORPLANS.
OBTAIN OR DRAW FLOORPLAN FOR ALL FLOORS OR AREAS LISTED IN BOX 5.
2. Q NORTH/SOUTH DIRECTION ARROW.
WRITE NORTH/SOUTH DIRECTION ARROW ON ANY FLOORPLAN ON WHICH IT IS MISSING.
WRITE IN THE LOWER RIGHT HAND CORNER IN PENCIL
3.
n
APPROXIMATE EXTERIOR DIMENSIONS OF EACH
FLOOR. GET BOTH LENGTH AND WIDTH, IF AVAILABLE.
IF EXTERIOR DIMENSIONS ARE NOT ALREADY PRINTED ON THE FLOORPLAN(S). ADD THEM TO
THE FLOORPLAN(S) IN PENCIL FOR EACH FLOOR. UNLESS FLOORS ARE IDENTICAL
CONTINUE WITH BOX 6.
BOX 5
LIST ALL FLOORS OR AREAS FOR WHICH THE RESPONDENT COULD NOT SUPPLY
FLOORPLANS:
CONTINUE WITH THE SECOND ITEM IN THE CHECKLIST IN BOX 4.
Page 2
-------
Form A2 (continued)
BOX 6
Now I have a few questions about the age of (BUILDING NAME).
A2. Were all sections of this building constructed at the same time?
YES 1 [SKIP TO A4]
NO 2
DK 8
A3. SHOW THE RESPONDENT THE FLOORPLAN OF THE FIRST FLOOR OF THE BUILDING.
Please indicate each section of the building constructed at a separate time on this
floorplan. Begin with the original section, and include all new floors or mechanical areas.
Now please tell me the name of the section, and the year in which construction was
completed.
SECTION NAME YEAR COMPLETED DK
I I I I I 9998
(ORIGINAL SECTION)
9998
9998
9998
9998
BOX 7
SKIP TO BOX 8.
Page3
-------
Form A2 (continued)
A4. SHOW THE RESPONDENT THE FLOORPLAN OF THE FIRST FLOOR OF THE BUILDING.
Now I am interested in the different wings of the building. Please indicate on the floorplan
each wing of the building, beginning with main part of the building. Now please tell me the
name of the wing and the year in which construction was completed.
WING NAME
(MAIN PART)
YEAR COMPLETED
I—I—I—I—I
DK
9998
9998
9998
9998
9998
BOX 8
MARK IN RED INK, ON THE MASTER FLOORPLAN OF THE BUILDING. EACH SECTION/WING AND
THE DATE IT WAS COMPLETED. MAKE SURE THAT THE SECTIONS/WINGS ARE NOT SEPARATE
BUILDINGS BY OUR DEFINITION.
PRINT EACH SECTION/WING NAME IN PENCIL ON THE FLOORPLAN OFF TO THE SIDE. DRAW
AN ARROW FROM THE NAME OF THE SECTION/WING TO THE SECTION/WING. CIRCLE EACH
NAME TO CLEARLY IDENTIFY IT.
IF THE SCHOOL DOES NOT HAVE A NAME FOR THE SECTION/WING. NAME IT BY COMPASS
DIRECTION (E.G., 'EAST WING", "NORTH SECTION', ETC.).
BOX 9
I need to locate specific areas on the floorplan. For each type of room that I read, please indicate
whether this building has that type of room, and locate It on the floorplan for me?
AS. Does this bunding have... ?
a.
b.
c.
d.
YES
boilerrooms?
rooftop HVAC units?
other mechanical or
electric rooms?
(SPECIFY)
1
1
1
[MARK ON FLOORPLAN]
[MARK ON FLOORPLAN]
[MARK ON FLOORPLAN]
NO. DK
2
2
2
8
8
8
Page 4
_,
-------
Form A2 (continued)
A6. Is this building served by other HVAC units outside of the building?
YES 1
0° rZrZ........ 8 1SKIP TO BOX
A7. Do these outside HVAC units serve:
Just this building?.
T°
AS. Where are these outside HVAC units located?
RECORD VERBATIM:
BOX 10
Now I have some more specific questions about the heating, ventilation, and air conditioning systems
in this building.
A9. Is the heating system the same in all sections of the building?
YES 1
Q^ZZZZZZZZZZZ 8 I" ISKIPTOA11]
A10. What type of heating system does the building have?
RECORD VERBATIM:
[SKIP TO A12]
Pages
-------
Form A2 (continued)
A11. Please list each type of heating system and the section or wing of the building it serves
[RECORD VERBATIM]
LOCATION HEATING SYSTEM
A12. Does this building have air conditioning?
YES 1
NO 2 1
DK ' ' " ' g J [SKIP TO BOX 11]
A13. Is the air conditioning system the same in the entire building?
YES 1
NO 2 \
DK 8 J
Pages
-------
Form A2 (continued)
A14. What type of air conditioning system does the building have?
(RECORD VERBATIM.)
.[SKIP TO BOX 11]
A15. Would you please list each type of air conditioning system and the section or wing of the
building it serves. [RECORD VERBATIM]
LOCATION AIR CONDITIONING SYSTEM
Page?
-------
Form A2 (continued)
BOX 11
The next questions are about air plenums. By air plenums, I mean a space above a dropped ceiling
through which heated or air conditioned air passes.
A16. Does this building have air plenums?
YES.
NO..
DK...
1
2
j [SKIP TO BOX 12]
A17. Do all parts of this building have air plenums?
YES.
NO..
DK...
1 [SKIP TO BOX 12]
2
8 [SKIP TO BOX 12]
A18. Please list all sections or wings and floors of the building that have air plenums.
SECTION/WING NAME
FLOOR
SECTION/WING NAME
FLOOR
SECTION/WING NAME
FLOOR
SECTION/WING NAME
FLOOR
SECTION/WING NAME
FLOOR
-------
Form A2 (continued)
BOX 12
The next questions are about major renovations that have been done in any part of this building since
its original construction.
A19. For each of the following types of renovation, please indicate whether this building has
undergone any renovations of that type, and show me on this floorplan where they were
done.
Since the original construction of any parts of the building has anyone:
YES
a. Tom down walls? 1 [OUTLINE ON
FLOORPLAN WITH
[PROBE FOR ADDITIONAL] YELLOW MARKER
AND DESCRIBE]
b. Changed the height of any
ceilings? 1 [OUTLINE ON
FLOORPLAN WITH
[PROBE FOR ADDITIONAL] YELLOW MARKER
AND DESCRIBE]
c. Changed the routing of any
pipes? 1 [OUTLINE ON
[PROBE FOR ADDITIONAL]
FLOORPLAN WITH
YELLOW MARKER
AND DESCRIBE]
d. Hidden any walls behind new
construction? 1 [OUTLINE ON
FLOORPLAN WITH
[PROBE FOR ADDITIONAL] YELLOW MARKER
AND DESCRIBE]
e. Sealed off any doors? 1 [OUTLINE ON
FLOORPLAN WITH
[PROBE FOR ADDITIONAL] YELLOW MARKER
AND DESCRIBE]
f. Done any other type of
renovations that required
more than 1 week of work? 1 [OUTLINE ON
FLOORPLAN WITH
YELLOW MARKER
AND DESCRIBE]
NQ
2
DK
8
8
(SPECIFY)
[PROBE FOR ADDITIONAL]
Page 9
-------
Form A2 (continued)
BOX 13
Now I would like to ask you a few questions about asbestos remediation that has been done in
(BUILDING NAME) in response to AHERA.
A20. Since December 1987, have any of the following types of asbestos remediation been
performed on 3 or more linear feet, or 3 or more square feet, of asbestos-containing
building material, or suspect material, in (BUILDING NAME)?
YES NO DK
a Removal 128
b. Encapsulation % 1 2 8
c. Enclosure 1" 2 8
d. Repair J, 2 8
BOX 14
IF ANY SHADED NUMBERS ARE CIRCLED IN A20, CONTINUE. OTHERWISE, SKIP TO BOX 16.
BOX 15
I would like to ask you a few questions about each type of remediation that has been performed in this
building.
SKIP TO FORM W1.
BOX 16
Those are all of the questions that I have.
We have scheduled an appointment on (APPOINTMENT DATE) at (APPOINTMENT TIME) for one of
our inspectors to Inspect (SCHOOL NAME) for asbestos. Will you be able to participate in all or pan
of the inspection?
CHECK THE "YES" BOX ON THE CALL RECORD NEXT TO 'AHERA DESIGNATED PERSON WILL
PARTICIPATE IN BUILDING INSPECTION' IF THE RESPONDENT WISHES TO PARTICIPATE IN THE
INSPECTION. OTHERWISE. CHECK THE 'NO" BOX
IF THE AHERA DESIGNATED PERSON WILL ATTEND, SKIP TO BOX 17.
A21. Please give me the name and position of the person who will accompany us on the
inspection?
NAME
POSITION
NAME
POSITION
Page 10
-------
Form A2 (continued)
BOX 17
We will send you the results of the inspection as soon as possible after we visit the building.
Thank you very much for your cooperation with this study.
COMMENTS
End time:
am
Page 11
-------
OMB No. 2070-0034
Expires 6/30/90
[AFFIX LABEL HERE]
U.S. ENVIRONMENTAL PROTECTION AGENCY
AHERA EVALUATION STUDIES
FORM P1: Principal Interview
March 1990
Public reporting burden for this collection of information is estimated to average 15 minutes, including time for
hearing instructions, reporting information, and reviewing information.
Send comments regarding the burden estimate or any other aspect of this collection of information, including
suggestions for reducing this burden, to:
Chief, Information Policy Branch
U.S. Environmental Protection Agency
401 M Street, S.W. (PM-223)
Washington, DC 20460
and
Office of Management and Budget
Paperwork Reduction Project (2070-0034)
Washington, DC 20503
Westat, Inc.
1650 Research Boulevard
Rockville, MD 20850
-------
AHERA
Form P1: Principal Interview
Start time:
am
"pm
BOX1
Hello, (PRINCIPAL NAME), my name is (YOUR NAME). I work with Westat. a survey research firm in
Rockville, Maryland. I am here regarding an AHERA survey that we are conducting for the
Environmental Protection Agency. As we explained in our letter to you, the EPA has asked Westat to
conduct a study to evaluate AHERA in randomly selected schools in the United States.
For this study, (BUILDING NAME(S)) will be re-inspected, including a room-by-room walkthrough.
Any suspect material found will be categorized, but no physical samples will be taken. No classes will
be interrupted.
Your help is essential because we cannot use anyone else in your place. The information you provide
will not be identified with you or your school.
P1. Before we get started. I would like to be sure that we have recorded your name correctly.
Is the correct spelling [SAY TITLE AND SPELL PRINCIPAL'S NAME]?
YES
NO ..
1
2
(CORRECT SPELLING)
BOX 2
The following questions are about the number of students attending (NAME OF SCHOOL) during this
school year, and which grades are being taught during this school year. When answering these
questions, please give me information for the school year beginning in the fall of 1989 and ending in
the spring of 1990. Oo not include summer school or night school.
P2. Approximately how many students are attending (NAME OF SCHOOL) during this school
year?
(NUMBER OF STUDENTS)
DK
9998
Pagei
-------
Form P1 (continued)
P3. For what grades are you conducting classes this school year? [PROBE: Any others?]
a. PRESCHOOL 1
b. KINDERGARTEN 1
c. FIRST GRADE 1
d. SECOND GRADE t
e. THIRD GRADE 1 .
f. FOURTH GRADE 1.
g. FIFTH GRADE 1
h. SIXTH GRADE 1
i. SEVENTH GRADE 1
j. EIGHTH GRADE 1
k. NINTH GRADE 1
I. TENTH GRADE 1
m. ELEVENTH GRADE 1
n. TWELFTH GRADE 1
o. SPECIAL EDUCATION 1
p. VOCATIONAL CLASSES 1
q. JUNIOR COLLEGE 1
r. COLLEGE 1
s. OTHER (SPECIFY): - 1
I DK. 8
BOX 3
IF ANY SHADED NUMBERS ARE CIRCLED IN P3, CONTINUE. OTHERWISE, TERMINATE
INTERVIEW.
BOX 4
The next few questions are about notifications to parents of students in this school regarding activities
relating to asbestos that have been performed in this school since December 1987. Please feel free to
refer to your copies of notifications.
P4. Since December 1987, has the school or school board administration ever notified parents
of students about any activities pertaining to asbestos in this school, such as a letter to
parents, a meeting, or an article in the school newspaper?
YES 1
NO 2 \ [SKIP
DK 8 J PG.8]
Page 2
-------
Form P1 (continued)
P5. Since December 1987. have parents been notified more than once about activities
pertaining to asbestos in this school?
YES 1 [SKIP TO P14]
NO 2
DK 8
P6. In what month and year, since December 1987, were parents notified of activities
pertaining to asbestos?
.198
(MONTH) (YEAR)
DK 9898
P7. Were parents notified by the school:
In a letter, notice, or publication
regularly sent to parents (such as
a school newsletter)? 1
By a special letter, notice or
publication sent to parents
specifically to inform them of
school activities regarding
asbestos? 2
During a regular parent-teacher
meeting, such as PTA meeting? 3
During a meeting called specifically
to discuss asbestos in this school? 4
In an official press release? 5
In some other ways? (SPECIFY):
DK 8
6
BOX 5
IF ANY SHADED NUMBERS ARE CIRCLED IN P7, CONTINUE. OTHERWISE, SKIP TO P9.
P8. Regarding the school meeting or meetings held, were minutes or written records later
published or distributed?
YES 1
NO 2
DK 8
-------
Form P1 (continued)
P9. Did the notification contain:
NO DK
a. Information about the availability
of a management plan? 1 2 8
b. An announcement about the performance
of the initial AHERA building inspection? 1 2 8
c. A list of materials containing asbestos
found in the school as well as the
location of these materials, at the time
of the initial inspection? 1 2 8
d. An announcement of response actions, such as
removal, encapsulation, enclosure of building
materials containing asbestos or
suspected to contain asbestos? 1 2 8
e. An announcement of other actions regarding
asbestos in the school? (SPECIFY):
1.2 8
f. General information about asbestos? 1 2 8
P10. Did you receive any reaction to the notification from parents such as:
a. Requests to see the management plan? 11 2 8
b. Requests for additional information? : J| 2 8
c. Requests for a special meeting ||
to discuss asbestos in this school? || 2 8
d. Requests to add the topic of vi |
asbestos in this school to the agenda |||
of a regular PTA or similar organization ||
meeting? 1| 2 8
e. Withdrawal of children from classes • -f
in this school? \M 2 8
P11. Were there any other reactions from parents?
YES Ip
(SPECIFY)
NO
DK.
2
8
BOX 6
IF NO SHADED NUMBERS ARE CIRCLED IN P10 OR P11, SKIP TO BOX 9, PAGE 8.
OTHERWISE, CONTINUE.
Page 4
-------
Form P1 (continued)
P12. Would you say a few, some, many or all parents responded in some way to the notification
pertaining to asbestos?
A FEW PARENTS 1
SOME PARENTS 2
MANY PARENTS 3
ALL PARENTS 4
DK 2 [SKIP TO BOX 9,
PG. 8]
P13. For parents who responded to the notification, would you say they expressed little
concern, some concern, or considerable concern?
LITTLE CONCERN 1
SOME CONCERN 2 . fSKIP TO BOX 91
CONSIDERABLE CONCERN 3 J™ TO BOX 9J
DK 8 J PG'8l
P14. How many times were parents notified about activities in this school pertaining to asbestos
since December 1987?
L
(NUMBER OF TIMES)
DK 98
P15. Beginning with the first notification, please give me the month and year in which parents
were notified about activities in this school pertaining to asbestos since December, 1987.
[VERIFY THAT ALL DATES LISTED ARE SINCE DECEMBER 1987]
a. __.198_
(MONTH) (YEAR)
DK
9898
fc|_J_J.19B|_J
(MONTH) (YEAR)
9898
C.
(MONTH) (YEAR)
9898
d.
(MONTH) (YEAR)
9898
(MONTH) (YEAR)
9898
Pages
-------
Form P1 (continued)
P16. Were parents ever notified by the school:
YES NO DK
a. In a letter, notice, or publication
regularly sent to parents (such as
a school newsletter)? 1 2 8
b. By a special letter, notice, or
publication sent to parents
specifically to inform them of
school activities regarding
asbestos? 1 2 8
c. During a regular parent-teacher
meeting, such as PTA meeting? 12 8
d. During a meeting called specifically
to discuss asbestos in this school? 12 8
e. In an official press release? 1 2 8
f. In some other ways? (SPECIF/):
1 2 8
BOX 7
IF ANY SHADED NUMBERS ARE CIRCLED IN P16, CONTINUE. OTHERWISE, SKIP TO P18
P17. Regarding the school meeting or meetings held, were minutes or written records later
published or distributed by the school?
YES 1
NO 2
DK 8
P18. Did any of the notifications contain:
YES NQ DK
a. Information about the availability
of a management plan? 1 2 8
b. An announcement about the performance
of the initial AHERA building inspection? 1 2 8
c. A list of materials containing asbestos
found in the school as well as the
location of these materials, at the time
of the initial inspection? 1 2 8
d. An announcement of response actions,
such as removal, encapsulation, or enclosure
of building materials containing asbestos, or
suspected to contain asbestos? 1 2 8
e. An announcement of other actions regarding
asbestos in the school? (SPECIFY):
1 2 8
f. General information about asbestos? 12 8
Page 6
-------
Form P1 (continued)
P19. Did you receive any reactions to the notifications from parents such as:
YES NO DK
a. Requests to see the management plan? <|| 2 8
b. Requests for additional information? ,;|| 2 8
c. Requests for a special meeting Iff
to discuss asbestos in this school? : || 2 8
d. Requests to add the topic of J if
asbestos in this school to the agenda llf
of a regular PTA or similar organization :M
meeting? i || 2 8
e. Withdrawal of children from classes ill
in this school? II 2 8
P20. Were there any other reactions from parents?
YES 11
(SPECIFY)
NO 2
DK 8
BOX 8
IF NO SHADED NUMBERS ARE CIRCLED IN P19 OR P20, SKIP TO BOX 9, PAGE 8.
OTHERWISE, CONTINUE.
P21. Would you say a few, some, many or all parents responded in some way to the
notifications pertaining to asbestos?
A FEW PARENTS 1
SOME PARENTS 2
MANY PARENTS 3
ALL PARENTS 4
DK 8 [SKIP TO BOX 9J
P22. From parents who responded to the notifications, would you say they expressed little
concern, some concern, or considerable concern?
LITTLE CONCERN 1
SOME CONCERN 2
CONSIDERABLE CONCERN 3.
DK 8
Page?
-------
Form P1 (continued)
BOX 9
We will need to contact other people such as representatives of teachers' unions and parents' groups
to interview them for another part of this research effort. The following questions refer to these
people.
P23. Do the teachers employed in this school belong to a union?
g j (SKIP TO P26J
YES 1
NO 2
P24. Please give me the name and title of the teachers' union representative (or association
representative) for the 1989-1990 school year. [IF MORE THAN ONE TEACHER UNION
REPRESENTATIVE, RECORD ADDITIONAL NAMES]
NAME TITLE
a.
b.
c.
d.
e. '
REFUSED 7
DK 8
BOX 10
IF P24 IS "REFUSED* OR 'DON'T KNOW," OFFER POSTCARD TO PRINCIPAL. IS POSTCARD GIVEN?
YES... 1 [SKIPTOP28] NO ....2 [SKIPTOP26]
Pages
-------
Form P1 (continued)
25. Please give me {EACH TEACHER'S
the area code.
a. ( \
(EVENING PHONE #}
b. ( \
(EVENING PHONE #)
c. ( )
(EVENING PHONE #)
d. ( }
(EVENING PHONE #)
e. ( )
(EVENING PHONE #)
SKIP TO P28
NAME]'s evening telephone number.
REFUSED
DK
REFUSED
DK
REFUSED
DK
REFUSED
DK
REFUSED
DK
BOX 11
beginning
EOS
1}
1}
1}
1}
1}
with
rCARD
YES
NO..
YES
NO..
YES
NO.
YES
NO.
YES
NO.
FILLED OUT
1
2
1
2
1
2
1
2
1
2
P26. Please give me the name and title of a teacher who holds a leadership role at the school,
similar to a teachers' union building representative (or association representative), for the
1989-1990 school year.
a.
b.
c.
d.
e.
NAME
TITLE
THERE ISNT ONE.
REFUSED
DK
6
7
8
[SKIP TO P28]
BOX 12
IF P26 IS 'REFUSED1 OR 'DONT KNOW,1 OFFER POSTCARD TO PRINCIPAL IS POSTCARD GIVEN?
YES...1 [SKIPTOP28J NO ....2 (SKIPTOP281
Page 9
-------
Form P1 (continued)
P27. Please give me [EACH TEACHER'S NAMEj's evening telephone number, beginning with
the area code.
POSTCARD FILLED OUT
a. ( \ REFUSED 7\ YES 1
(EVENING PHONE #) DK 8J NO 2
b. ( ) REFUSED 7\ YES 1
(EVENING PHONE #) DK 8/ NO 2.
c. ( ) REFUSED 7\ YES 1
(EVENING PHONE #) DK 8 NO 2
1}
d. ( ) REFUSED 7\ YES 1
(EVENING PHONE #) DK 8J NO 2
e. ( 1 REFUSED 7\ YES 1
(EVENING PHONE #) DK 8J NO 2
P28. Is there a PTA or another type of parent group at this school?
YES 1
DK.!!!""!!"!!!"""!""!II!"I"Z'T I } *SKIPT0P31J
P29. Please give me the name and title of the PTA or other similar parent group president or
head for this school year. Please give me the name of one other officer for this school
year?
NAME TITLE
a.
b.
REFUSED 7
DK 8
BOX 13
IF P29 IS "REFUSED* OR "DONT KNOW," OFFER POSTCARD TO PRINCIPAL IS POSTCARD GIVEN?
YES... 1 [SKIPTOP31J NO ....2 [SKIPTOP31]
Page 10
-------
Form P1 (continued)
P30.
Please give [EACH PARENT'S NAMEj's evening telephone number, beginning with the
area code.
POSTCARD FILLED OUT
GO
a. ( ) - REFUSED
(EVENING PHONE #) DK
b. ( ) - REFUSED
(EVENING PHONE #) DK
BOX 14
TO CLOSING STATEMENT
7\ YES 1
aJ NO 2
7\ YES 1
aJ NO 2
P31. Please give me the name and evening phone number of a parent who is actively involved
in the activities of this school and who is not a paid employee of the school.
(NAME)
(EVENING PHONE #)
REFUSED.
DK
REFUSED.
DK
POSTCARD FILLED OUT
YES 1
NO 2
YES 1
NO 2
CLOSING STATEMENT
Thank you very much for your support and cooperation with this questionnaire as well as for permitting us to do
the building walkthrough. The findings of the walkthrough inspection will be sent to the AHERA designated
person for this school.
End time:
am
•pm
Page 11
-------
AHERA
FORM W1: Response Action Assessment
label here)
Room Name or Number
(HIGHLIGHT ROORPLAN IN BLUE]
Area ID | | J
Complete I Impact
barrier resistant
Respondent
Description ol material
and response action
Confir-
mation ol
response
action
Reason lor
non*coTnlrmetlon
Response
actions
l>3 LINEAR OR
SQUARE FEET)
ADP
Insp.
1
2
Other 3
(SPECIFY)
Yes 1
No 2
TSI 1
Surf. 2
Misc. 3
Enclosure 1
Encapsulation 2
Removal 3
Repair 4
ADP
Insp.
Other 3
(SPECIFY)
Yes 1
No 2
TSI 1
Surf. 2
Misc. 3
Enclosure 1
Encapsulation 2
Removal 3
Repair 4
ADP
Insp.
Other 3
(SPECIFY)
Yes 1
No 2
TSI t
Surf. 2
Misc. 3
Enclosure 1
Encapsulation 2
Removal 3
Repair 4
ADP
Insp.
1
2
Other 3
(SPECIFY)
Yes 1
No 2
TSI 1
Surf. 2
Misc. 3
Enclosure 1
Encapsulation 2
Removal 3
Repair 4
(NEXT FORM W1 OR RETURN TO FORM A2J
FILL IN: PAGE
OF
FOR THIS AREA
-------
AHERA
FORM W2: Area Identification
(Affix label here]
Area ID
(MARK
FIOORPLAN
1 10
1 M
1 U
1 (3
1 l«
1 15
1 IB
1 17
1 18
1 I9
Room number
or name (LIST
ALL AREAS INCLUDED]
Area
Section
name
-
Level
Basement 1
Floor (SPECIFY) 2
Other (SPECIFY) 3
B«Mm«nl 1
Floor (SPECIFY) 2
Other (SPECIFY) 3
Basement 1
Boor (SPECIFY) 2
Other (SPECIFY) 3
Basement 1
Floor (SPECIFY) 2
Other (SPECIFY) 3
Basement 1
Floor (SPECIFY) 2
Other (SPECIFY) 3
Basement 1
Floor (SPECIFY) 2
Other (SPECIFY) 3
Basement 1
Floor (SPECIFY) 2
Other (SPECIFY) 3
Basement 1
ROOT (SPECIFY) 2
Other (SPECIFY) 3
Basement 1
Floor (SPECIFY) 2
Other (SPECIFY) 3
Basement t
Poor (SPECIFY) 2
Other (SPECIFY) 3
Area use code
1 1 1
(SPECIFY)
ill
(SPECIFY)
1 1 1
(SPECIFY)
1 1 1
(SPECIFY)
1 1 1
(SPECIFY)
1 1 1
(SPECIFY)
1 1 1
(SPECIFY)
1 1 1
(SPECIFY)
1 1 1
(SPECIFY)
1 1 1
(SPECIFY)
Number of suspect
homogeneous materials
JIF >0. FORM W3)
TSI
Surf.
Misc. _
TSI
Surf.
Mso.
TSI
Surf.
Mso.
TSI
Surf.
Mso.
TSI
Surf.
Mso.
TSI
Surf.
Misc.
TSI
Surf.
Misc.
TSI
Surf.
Misc.
TSI
Surf.
Msc.
TSI
Surf.
Misc.
Response actions
(REVIEW
FLOORPLAN
IF YES. FORM W1I
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
FILL IN: PAGE OF FOR THIS BUILDING
-------
AHERA
AREA USE CODE
FOR FORM W2
EXTERIOR AREAS
Portico 01
Covered connecting walkway .... 02
Other exterior area (SPECIFY) .... 19
INTERIOR AREAS
Auditorium (fixed chairs) 21
Classroom (includes closet) 22
Classroom group (classroom &
one or more of bathroom
& office 23
Dining room (cafeteria) 24
Dormitory bedroom 25
Garage, underground 26
Gymnasium 27
Gymnasium equipment room 28
Hallway, interior 29
Janitor's closet 30
Kitchen 31
Laboratory 32
Library/Media center 33
Lobby/Entryway 34
Locker room 35
Multipurpose room (2 or more
of cafeteria, gym, assembly) .... 36
Office 37
Restroom 38
Stage 39
Stairway 40
Storage/Supply room 41
Swimming pool 42
Teachers' lunch room 43
Teachers' lounge 44
Weight/Exercise room 45
MECHANICAL AREAS
Air and duct shaft
Air handling
Air plenum
Boiler room
Crawl space
Elevator shaft or equipment...
Mechanical room
Pipe shaft
Rooftop HVAC unit
Space above dropped ceiling
(non-air plenum)
Telephone and electrical
61
62
63
64
65
66
67
68
69
70
71
Other mechanical area
(SPECIFY)
89
No Access (SPECIFY) 95
Other interior area (SPECIFY) .... 59
-------
AHEI
FORM \W3TSuspect Homogeneous Materials
Room Name or Number
Suspect
homogeneous
material
key code
1 — 1 — 1— 1
1 1 1 '
1 1 1 1
1 1 1 1
1— 1— 1— 1
1— 1— !_J
Friable
Yes 1
No 2
No 3
access
Yes 1
No 2
No 3
access
Yes 1
No 2
No 3
access
Yes 1
No 2
No 3
access
Yes 1
No 2
No 3
access
Yes 1
No 2
No 3
access
Suspect homogeneous material dimensions
Shape
Linear 1
Odd 2
Rectang. 3
Linear 1
Odd 2
Rectang. 3
Linear 1
Odd 2
Rectang. 3
Linear 1
Odd 2
Rectang. 3
Linear 1
Odd 2
Rectang. 3
Linear 1
Odd 2
Rectang. 3
Measurement .
l-_l— 1— I_J
by
1— 1— 1— 1— 1
1 1 1 1 1
by
1— 1— 1— 1— 1
1— l_l— 1 — 1
by
1 — 1— 1— 1 — 1
1— 1 1— 1 — 1
by
1— 1— 1— 1— 1
1— 1— 1— 1— 1
1 1 1 1 1
by
1— 1— 1— 1— 1
1— 1— 1— 1— 1
1 1 1 1 1
by
Unit
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
hi 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
hi 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
ft 1
In 2
A/ei
Labeled
Yes 1
No 2
Not 3
required
Yes 1
No 2
Not 3
required
Yes 1
No 2
Not 3
required
Yes t
No 2
Not 3
required
Yes 1
No 2
Not 3
required
Yes 1
No 2
Not 3
required
Current damage
Local
<1% 1
1-25% 2
>25% 3
<1% 1
1-25% 2
>25% 3
<1% 1
1-25% 2
>25% 3
<1% 1
1-25% 2
>25% 3
<1% 1
1-25% 2
>25% 3
<1% 1
1-25% 2
>25% 3
Dispersed
<1% 1
1-10% 2
>10% 3
10% 3
<1% 1
1-10% 2
>10% 3
<1% 1
1-10% 2
>10% 3
<1% 1
1-10% 2
>10% 3
<1% 1
1-10% 2
>10% 3
>K>|
j
Potential for damage
Pot
water
damage
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Gcimtl
ftOO+M
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Yes 1
No 2
Malnt
•OOOtt
Lo 1
H 2
Lo 1
HI 2
Lo 1
HI 2
Lo 1
HI 2
Lo 1
H 2
Lo 1
HI 2
Mr
Velocity
Nonel
Lo 2
HI 3
Nonel
Lo 2
HI 3
Nonel
Lo 2
H 3
Nonel
Lo 2
HI 3
Nonel
Lo 2
HI 3
Nonel
Lo 2
H 3
Effect
Of
Vibration
Lo 1
HI 2
Lo 1
H) 2
Lo 1
HI 2
Lo 1
H) 2
Lo 1
HI 2
Lo 1
HI 2
FILL IN: PAGE O OF D FOR THIS AREA
-------
AHERA
FORMI1T: TSI Key Code
(Affix label here]
TSI
T|_|0
TL_M
T|_|2
T|_|3
T| I 4
T|_|5
T|_|6
T|_J7
T|_|8
T|__|9
Description
(size, features, etc.)
Code
Type
I_J_J_I
(SPECIFY)
l_l_l_l
(SPECIFY)
I I I I
(SPECIFY)
l_l_l__l
(SPECIFY)
l_l_l__l
(SPECIFY)
l_l_l_l
(SPECIFY)
l_l_l_l
(SPECIFY)
I_J_J__I
(SPECIFY)
0
l_l_l_l
(SPECIFY)
l_l_l__l
(SPECIFY)
Texture
l_l_l
(SPECIFY)
I_I_J
(SPECIFY)
l_l_l
(SPECIFY)
I_I_J
(SPECIFY)
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
First
area ID
I_J_J
!_!_!
l_l_l
I_J_J
l_l_l
l_l_l
I_I_J
l_l_l
I_J_J
l_l_l
TSI codes
Type
Breeching 101
Boiler 102
Chiller 103
Duct - exterior 104
Duct - interior 105
Elbow 106
Pitt Inn 1H7
Pipe 108
Tank 109
Tee 110
Valve 111
Other (SPECIFY) 159
Textures
Air cell- 01
Corrugated . . 02
Layered paper 03
Matted or felted ...04
Solid 05
Woven 06
Other (SPECIFY) ....29
Textures Not Included
Fiberglass
Metal
Plastic
Rubber
Steel
Wood
FILL IN: PAGE
OF
FOR THIS BUILDING
-------
AHERA
FORM IIS: Surfacing Material Key Code
[Affix label here]
Surfacing
material
S|_|0
S|_|1
S|_|2
S|_|3
S|_J4
S|_|5
S|_|6
S|_|7
S|_|8
S|_|9
Description
(size, features, etc.)
Code
Type
l_!_l_l
(SPECIFY)
l__l_l_l
(SPECIFY)
l_l_l_!
(SPECIFY)
l_l_l_l
(SPECIFY)
I I I I
(SPECIFY)
I I I I
(SPECIFY) .
I_I_I_J
(SPECIFY)
l__l_l_l
(SPECIFY)
I_I_J__I
(SPECIFY)
l_l_l_l
(SPECIFY)
Color
I_I_J
(SPECIFY)
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
l_l_!
(SPECIFY).
l_l_l
(SPECIFY)
I I I
(SPECIFY)
I_L_J
(SPECIFY)
l__l__l
(SPECIFY)
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
First
area ID
I_J_J
l_l_l
l_l_l
l_l_l
l_l_l
I_J__I
l_l_l
l_l_l
l_l_l
l_l_l
Surfacing material codes
Type
Ceiling material - hard and
granular/cementitious ... 201
Ceiling material - fluffy 202
Ceiling material - soft and
granular 203
Ceiling material - textured
paini or popcorn cut
Fireproofing - hard and
granular/cementitious.... 205
Fireproofing - fluffy 206
Fireproofing - soft and
granular 207
Wall coating - hard and
granular/cementitious
or stuccoed 208
Wall coating - fluffy 209
Wall coating - soft and
granular 210
Wall coating - textured
paint or popcorn 211
Color
Black . .. 31
Blue ... .32
Brown 33
Gray 34
Green ... . 35
Off-white 36
Pink 38
Purple 39
Red 40
Tan 41
White 42
Yellow 43
Other (SPECIFY) ....59
Material Types
Not Included
Cinder blocks
Concrete blocks
Paint, smooth
Hard plaster wall
Sheetrock drywall
Structural concrete
FILL IN: PAGE
OF
FOR THIS BUILDING
-------
AHERA
FORM 11M: Miscellaneous Material Key Code
[Affix label here]
Miscellaneous
material
M|_|0
M|_|1
M|_|2
M | j 3
M|_|4
M|_|5
M|_|6
M|_|7
M| |8
M|_|9
Description
(size, features, etc.)
Code
Type
l_l_l_l
(SPECIFY)
l_l_l_l
(SPECIFY)
I_J_J_J
(SPECIFY)
I_J_J_J
(SPECIFY)
1 I 1 1
(SPECIFY)
III!
(SPECIFY)
l_l_l_l
(SPECIFY)
l_l_l_l
(SPECIFY)
I_J_J_I
(SPECIFY)
l_l_l_l
(SPECIFY)
Color
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
l_l_l
(SPECIFY)
l__l__l
(SPECIFY)
l_l_l
(SPECIFY)
1 1 1
(SPECIFY)
I_J_J
(SPECIFY)
I_J_I
(SPECIFY)
l_l_l
(SPECIFY)
I_J_I
(SPECIFY)
First
area ID
!_!_!
l_l_l
l_l_l
l_l_l
l_l_l
l_l_l
l_l_l
l_l_l
l_l_l
l_l_l
Miscellaneous material codes
Type
Acoustical wall tile 301
Ceiling tile - glue-on 302
Ceiling tile - lay-In 303
Ceiling tile - spline 304
Cooling tower slats 305
Fire doors 306
Plrutr tila Q" v Q" 1D7
Floor tile - 1 ' x 1 ' 308
Fume hood sheeting 309
Linoleum or solid floor
covering 310
Patch 311
Radiator board 312
Transite- ducts 314
Transite- panels 315
Transite- water pipe
(interior) 316
Vibration dampening
cloth on ducts 317
mner (brtt»irY) ooa
Color
Black 31
Blue 32
Brown 33
Gray 34
Green 35
Off-white 36
Pink 38
Purple 39
Red 40
Tan 41
White 42
Yellow 43
Other (SPECIFY) ....59
Material Types
Not Included
Adhesives
Auditorium curtains
Brake shoes
Bunsen burner pads
Carpet
Caulking
Electrical wire ins.
Flooring under wall to
wall carpet
Fire blanket
Gasket
Kiln bricks
Laboratory gloves
Laboratory table tops
Light socket collars
Roofing materials
Sheetrock
Stored materials
Tectum— board
Vinyl wall paper
Fll I IN: PAGF I I OF | | FOR THIS BUM DING
-------
AHERA
FORM 12: Suspect Homogeneous Materials Calculations
1
(Affix Label Here]
Area ID
i .- i i
1 ___!__ 1
• ••
1— I_J
1 -_ • 1
1 1 '
•-_r— ir 1- ' — "
1 — 1 — 1
1 — I—I
1 1, 1
Material
key code
1— 1— 1— 1
i i I I
1— l_l— 1
* ' ' '
i i • •
' ' • '
' * i i
* - ' * . *
* '-• i i
1 — 1 — 1 — 1
Calculation space
•
. Total
Units
(CIRCLE)
ft
In
ft
In
ft
In
ft
In
ft
In
ft
In
ft
In
ft
In
ft
In
ft
In
FILL IN: PAGE Q OF Q FOR THIS BUILDINC
-------
OMB No. 2070-0034
Expires 8/31/90
[ID NUMBER]
U.S. ENVIRONMENTAL PROTECTION AGENCY
AHERA EVALUATION STUDIES
FORM O1: Inspector's Interview
June 1990
Public reporting burden for this collection of information is estimated to average 15 minutes, including time for
hearing instructions, reporting information, and reviewing information.
Send comments regarding the burden estimate or any other aspect of this collection of information, including
suggestions for reducing this burden, to:
Chief, Information Policy Branch and Office of Management and Budget
U.S. Environmental Protection Agency » Paperwork Reduction Project (2070-0034)
401 M Street, S.W. (PM-223) Washington, DC 20503
Washington, DC 20460
Westat, Inc.
1650 Research Boulevard
Rockville, MD 20850
-------
AHERA Start time: am
Form 01: Inspectors' Interview pm
Hello, I'm (YOUR NAME) and I'm calling from Westat, a survey
research firm, in Rockville, Maryland. I'm calling about a study we are conducting for the Environmental
Protection Agency about asbestos inspectors' backgrounds. Is this [NAME OF INSPECTOR]?
YES 1
NO 2 [TERMINATE]
1. I also need to verify that the asbestos I.D. number we have listed for you is or was an
inspection certification or ID number used by you. Is or was [CERTIFICATION
NUMBER] your I.D. number?
YES 1
NO 2 [TERMINATE]
BOX1
Westat has selected a nationwide sample of schools that were inspected for asbestos under AHERA. Your
name was listed in an AHERA management plan as having participated in at least one school inspection.
We would like to ask you a few questions about your background. We'll start with training you may have
received in order to become an asbestos inspector.
2. Have you ever received accreditation according to AHERA as an asbestos building
inspector?
Yes [[[ 1
No [[[ 2 [SKIP TO END]
3. What month and year did you successfully complete the AHERA asbestos building
inspector training course?
__ __
MONTH YEAR [IF LESS THAN ONE YEAR
AGO, SKIP TO 07]
DK [[[ . ..... 9898
-------
Form 01 (continued)
5. What month and year did you successfully complete your first AHERA inspector
refresher course?
__ __
MONTH YEAR [IF LESS THAN ONE YEAR
AGO, SKIP TO Q7]
DK ........................................... 9898
6. How many AHERA inspector refresher courses have you successfully completed?
' l_l_l
[NUMBER OF COURSES]
DK ........................................... 98
7. Is your accreditation, according to AHERA, as an asbestos inspector current?
YES [[[ 1
NO [[[ 2
DK [[[ 8
YES 1
NO 2
DONT KNOW 8
8. Have you taken any non-AHERA training related to asbestos?
1
"* [SKIP TO BOX 2]
" )
9. Was any of this non-AHERA training taken at a
YES NO DK
College or university? 1 2 8
Technical school? 1 2 8
Some other kind of school? (SPECIFY) 1 2 8
-------
Form 01 (continued)
11. What year did you take this training?
YEAR
DK 98
BOX 2
The next few questions I will ask are about the asbestos inspections you have conducted. We are
interested in inspections you may have conducted alone or as a member of an inspection team. Please
include AHERA and non-AHERA inspections, and if you are unsure of the exact answer please give me your
best estimate.
12. In what month and year did you conduct your first asbestos inspection?
MONTH YEAR
DK 9898[SKIP TO Q13]
BOX 3
IF Q12 PRIOR TO 1988. -> GOTOQ13
IF Q12 IS BETWEEN JANUARY-JUNE 1988, -> GO TO 014
IF Q12 IS BETWEEN JULY-DECEMBER 1988, -> GO TO Q15
IF Q12 IS BETWEEN JANUARY-JUNE 1989, -> GO TO 016
IF 012 IS BETWEEN JULY-DECEMBER 1989, ~> GOTO 17
Pages
-------
Form 01 (continued)
13. The following series of questions ask for information about the number of buildings or
parts of buildings you have inspected for asbestos either alone or as a member of a
team.
How many
buildings did
you inspect?
How many of
those bldgs.
were schools?
NUMBER DK NUMBER DK
a. Prior to 1988
b. From Jan thru Jun 1988..
c. From July thru Dec 1988.
d. From Jan thru Jun 1989..
e. From July thru Dec 1989.
98
98
98
98
98
[SKIP TO BOX 4]
14. The following series of questions ask for information about the number of buildings or
parts of buildings you have inspected for asbestos either alone or as a member of a
team.
98
98
98
98
98
How many
buildings did
you inspect?
NUMBER DK
How many of
those bldgs.
were schools?
NUMBER DK
a. Prior to and including June 1988.
b. From July thru Dec 1988
c. From Jan thru Jun 1989
d. From July thru Dec 1989
98
98
98
98
[SKIP TO BOX 4]
98
98
98
98
15. The following series of questions ask for information about the number of buildings or
parts of buildings you have inspected for asbestos either alone or as a member of a
team.
How many
buildings did
you inspect?
a. Prior to and including Dec 1988....
b. From Jan thru June 1989
c. From July thru Dec 1989
How many of
those bldgs.
were schools?
NUMBER DK NUMBER DK
J_J 98
.LJ 98
.!_! 98
[SKIP TO BOX 4]
98
98
98
Page 4
-------
Form 01 (continued)
16. The following series of questions ask for information about the number of buildings or
parts of buildings you have inspected for asbestos either alone or as a member of a
team.
a. Prior to and including June 1989...
b. From July thru Dec 1989
How many
buildings did
you inspect?
How many of
those bldgs.
were schools?
NUMBER DK NUMBER DK
I_J 98 |
l_l 98 |
[SKIP TO BOX 4]
98
98
17.
The following question asks for information about the number of buildings or parts of
buildings you have inspected for asbestos either alone or as a member of a team.
How many
buildings did
you inspect?
NUMBER DK
How many of
those bldgs.
were schools?
NUMBER DK
a. Prior to Jan 1990 l_l_l 98 l_l_l 98
BOX 4
The next few questions are about your employment history.
18. Have you ever worked in a building trades industry such as carpentry, plumbing, or
construction?
YES 1
NO 2 [SKIP TO Q20]
19. How long (have you worked/did you work) in (this industry /these industries)?
|_|_J AND|_|_|
YEARS MONTHS (I F APPLICABLE)
DK 9898
Pages
-------
Form 01 (continued)
20. Have you ever worked in an environmental services laboratory, such as one where
suspect hazardous materials are analyzed?
YES 1
NO 2 [SKIP TO Q22]
21. How long (have you worked/did you work) in this field?
l_l_l AND |_J_|
YEARS MONTHS (IF APPLICABLE)
DK 9898
22. Have you ever worked in the fields of environmental health, occupational health and
safety, industrial hygiene, or air monitoring, excluding labs?
YES 1
NO 2 [SKIP TO Q24J
23. How long (have you worked/did you work) in these fields?
YEARS' MONTHS (IF APPLICABLE)
24. Have you ever worked in the architecture or engineering field?
YES 1
NO 2 [SKIP TO BOX 5]
25. How long (have you worked/did you work) in the architectural /engineering field?
____
YEARS MONTHS (IF APPLICABLE)
DK 9898
Page6
-------
Form 01 (continued)
BOX 5
Now I'd like to ask you some questions about your education background.
26. What is the highest level of education you have completed?
(CIRCLE ONE)
A. HIGH SCHOOL OR GED 1 [SKIPTOQ37J
B. VOCATIONAL TRADE OR BUSINESS SCHOOL
AFTER HIGH SCHOOL 2 [SKIP TO 037]
C. COLLEGE OR UNIVERSITY
LESS THAN 2 YEARS OF COLLEGE 3 [SKIP TO 038)
2 OR MORE YEARS OF COLLEGE
(INCLUDING 2-YEAR DEGREE) 4 [SKIP TO Q34]
COMPLETE COLLEGE
(4- OR 5-YEAR DEGREE) 5 [SKIP TO Q31J
MASTER'S DEGREE OR EQUIVALENT 6 [SKIP TO Q29]
PH.D. OR OTHER ADVANCED
PROFESSIONAL DEGREE 7
27. What year did you receive your (Doctoral/advanced professional) degree?
19I_!_I
YEAR
28. What is the subject area of your (Doctoral/advanced) degree?
(CIRCLE ONE)
ENGINEERING 1
ARCHITECTURE 2
ENVIRONMENTAL SCIENCE 3
OCCUPATIONAL HEALTH/INDUSTRIAL HYGIENE 4
OCCUPATIONAL SAFETY 5
OTHER (SPECIFY) 6
Page 7
-------
Form 01 (continued)
29. What year did you receive your Masters degree?
YEAR
30. What is the subject area of your Masters degree?
(CIRCLE ONE)
ENGINEERING 1
ARCHITECTURE 2
ENVIRONMENTAL SCIENCE 3
OCCUPATIONAL HEALTH/INDUSTRIAL HYGIENE 4
OCCUPATIONAL SAFETY 5
OTHER (SPECIFY) 6
31 . What year did you receive your undergraduate college degree?
YEAR
32. Is your undergraduate degree a BA, BS or some other degree?
BA 1
BS 2
SOME OTHER (SPECIFY) 3
33. What is the subject area of this degree?
(CIRCLE ONE)
ENGINEERING 1
ARCHITECTURE 2
ENVIRONMENTAL SCIENCE 3
OCCUPATIONAL HEALTH/INDUSTRIAL HYGIENE..... 4
OCCUPATIONAL SAFETY 5
OTHER (SPECIFY) 6
34. Did you receive an Associates degree?
YES 1
NO 2 [SKIP TO 38)
Pages
-------
Form 01 (continued)
35. What year did you receive your Associates degree?
19I_J_J
YEAR
36. What is the subject area of your Associates degree?
(CIRCLE ONE)
ENGINEERING TECHNOLOGY 1
ARCHITECTURE TECHNOLOGY 2
ENVIRONMENTAL SCIENCE 3
INDUSTRIAL/PUBLIC HEALTH 4
APPLIED SCIENCE AND TECHNOLOGY 5
OTHER (SPECIFY) 6
37. Have you taken any college or university course work not related to asbestos that did
not result in a college or university degree?
YES 1
::::::::::::::: I
38. What year did you last take course work not related to asbestos that did not result In
college or university degree?
YEAR
DK 98
39. What was the subject area of this course work?
a.
SUBJECT
b.
SUBJECT
C.
SUBJECT
Page 9
-------
Form 01 (continued)
40. At this point I'd like to ask you about any non-asbestos related technical training
you've received. Did you ever attend school with the goal of obtaining a vocational or
technical certificate or diploma?
YES 1
NO 2 [SKIP TO 045]
41. Have you received a vocational or technical certificate or diploma?
YES 1
NO 2 [SKIP TO 045]
42. What is the subject area, or areas, of your vocational /technical (certificate/diploma)?
a.
[SUBJECT]
b.
[SUBJECT]
c.
[SUBJECT]
43. What year did you receive
your certificate or diploma
from this program?
a- 19|_l_l
OK 98
DK
98
DK
98
44. How long, in weeks or
months, was the course
of study for this vocational/
technical program?
[NUMBER OF WEEKS]
OR
a- I_J_I
[NUMBER OF MONTHS]
OR
a- I_J_J
[NUMBER OF DAYS]
[NUMBER OF WEEKS] [NUMBER OF WEEKS]
OR OR
c. I I I
[NUMBER OF MONTHS] [NUMBER OF MONTHS]
OR
- I_J_J
[NUMBER OF DAYS]
OR
c. I I I
[NUMBER OF DAYS]
DK.
98
DK.
98
DK.
98
Page 10
-------
Form 01 (continued)
45. Do you have professional certification as a:
What year
was this
certification
YES obtained?
NO DK
a. Professional Engineer (P.E.) ....................
b. Certified Industrial Hygienist (CIH) ..........
c. Registered Architect, (RA) .....................
d. Certified Safety Professional (CSP), or...
e. Some other professional certification? ...
(SPECIFY)
19|_|_|
19|_|_J
19|_J_|
19|_|_|
19 1 _ j _ j
2
2
2
2
2
8
8
8
8
8
END
Those are ail the questions I have. Thank you very much for your help.
Page 11
-------
OMB No. 2070-0034
Expires 8/31/90
[ID NUMBER]
U.S. ENVIRONMENTAL PROTECTION AGENCY
AHERA EVALUATION STUDIES
FORM N1: Notification Interview
May 1990
Public reporting burden for this collection of information is •stim«t«d to average 15 minutes, including time for
hearing instructions, reporting information, and reviewing information.
Send comments regarding the burden estimate or any other aspect of this collection of information, including
suggestions for reducing this burden, to:
Chief. Information Policy Branch and Office of Management and Budget
U.S. Environmental Protection Agency Paperwork Reduction Project (2070-0034)
401 M Street, S.W. (PM-223) Washington, DC 20503
Washington, DC 20460
Westat, Inc.
1650 Research Boulevard
Rockville, MD 20850
-------
AHERA Start time: am
FormNl: Notification pm
BOX1
Hello, (RESPONDENT NAME), my name is (YOUR NAME). I work with Westat, a survey research firm in !
Rockviile. Maryland and we obtained your name (when you sent us a postcard/from the PRINCIPAL'S
NAME of SCHOOL'S NAME). I'm calling regarding a survey that we are conducting for the ;
Environmental Protection Agency. The EPA has asked Westat to conduct a study to evaluate the \
asbestos in schools legislation, commonly called AHERA. The (SCHOOL NAME) was randomly selected j
for inclusion in this study, and we have no reason to believe that this school is out of compliance with this j
regulation. j
Your help is essential because we cannot use anyone else in your place. The information you provide |
will not be identified with you or your school. j
NIL I would like to be sure that we have recorded your name correctly. Is the correct spelling
[SAY TITLE AND SPELL RESPONDENT'S NAME]?
YES 1
NO 2
(CORRECT SPELLING)
(NAME)
(TITLE)
N2. At the time we spoke with the (PRINCIPAL'S NAME), we were told that you were a
(PARENT/TEACHER) active in school matters. Is that accurate?
YES 1 [SKIP TO NS IF PARENT]
[SKIP TO N8 IF TEACHER]
NO 2
N3. Would you please give me the name of a (PARENT/TEACHER) at (SCHOOL NAME) who is
actively involved in extra curricular school matters?
YES 1
NO 2 [TERMINATE]
N4. What is that person's name and telephone number, including the area code?
(NAME)
_J_I_I ' LI_J_J • I__LLI_J [TERMINATE]
(AREA CODE) (PHONE NUMBER)
DK 8 [TERMINATE]
Pagei
-------
=orm N1 (continued)
IF PARENT:
N5. Which of the following best describes your activities in this school?
PTA officer 1
Parent volunteer 2
Committee member 3 ^ [SKIP TO N7]
OTHER ROLE (SPECIFY) 4
PTA AND OTHER ROLE 5
N6. What is your position in the PTA?
PRESIDENT 1
VICE PRESIDENT 2
SECRETARY 3
TREASURER 4
OTHER (SPECIFY) 5
N7. How long have you been associated with (SCHOOL NAME)?
LESS THAN 1 YEAR 1
1-3 YEARS 2
4 or MORE YEARS 3
BOX 2
SKIP TO BOX 3
IF TEACHER:
N8. Which of the following best describes your nonteaching activities in this school?
Teacher's union representative 1
Teacher volunteer 2
Committee member 3 }• [SKIPTON10J
OTHER ROLE (SPECIFY) 4
TEACHERS UNION AND OTHER
ROLE 5
N9. What is your position in the teachers' union?
PRESIDENT 1
VICE PRESIDENT 2
SECRETARY 3
TREASURER 4
OTHER (SPECIFY) 5
Page 2
-------
Form N1 (continued)
N10. How long have you been associated with (SCHOOL NAME)?
LESS THAN 1 YEAR 1
1-3 YEARS 2
4 or MORE YEARS 3
BOX 3
My next questions are about notifications to parents of students in this school regarding activities relating
to asbestos that have been performed in this school since December 1987.
N11. To the best of your knowledge, since December 1987, has the school or school board
administration ever notified parents of students about any activities pertaining to asbestos in
this school, such as a letter to parents, a meeting, or an article in the school newspaper?
YES 1
NO 2 \ [SKIP
DK 8 / PG9]
N12. Since December 1987. have parents been notified more than once about activities pertaining
to asbestos in this school?
YES 1 [SKIP TO N22, PG 6]
NO 2
DK 8
N13. In what month and year, since December 1987, were parents notified of activities pertaining
to asbestos?
(MONTH) (YEAR)
DK 9898
Pages
-------
=orm N1 (continued)
N14. Were parents notified by the school:
YES NO DK
a. In a letter, notice, or publication
regularly sent to parents (such as
a school newsletter)? 1 2 8
b. By a special letter, notice, or
publication sent to parents
specifically to inform them of
school activities regarding
asbestos? 1 2 8
c. During a regular parent-teacher
meeting, such as a PTA meeting? "1*2 8
d. During a meeting called specifically
to discuss asbestos in this school? 12 8
e. In an official press release? 1 2 8
f. In some other ways? (SPECIFY):
1 2 8
BOX 4
IF ANY SHADED NUMBERS ARE CIRCLED IN N14, CONTINUE. IF ALL DK IN N14, SKIP TO N16.
OTHERWISE, SKIP TO N17.
N15. Regarding the school meeting or meetings held, were minutes or written records later
published or distributed?
YES 1
NO 2
DK 8
N16. Do you remember the contents of this notification?
YES 1
NO 2
DK 8 J PG9]
NO 2 I [SKIP TO BOX 8,
Page 4
-------
Form N1 (continued)
N17. Did the notification contain:
YES NO DK
a. I nformation about the availability
of a management plan? 1 2 3
b. An announcement about the performance
of the initial AHERA buUding inspection? 1 2 3
c. A list of materials containing asbestos
found in the school as well as the
location of these materials, at the time
of the initial Inspection? 1 2 8
d. An announcement of response actions, such as
removal, encapsulation, enclosure of building
materials containing asbestos or
suspected to contain asbestos? 1 2 8
e. An announcement of other actions regarding
asbestos in the school? (SPECIFY):
1 2 8
f. General information about asbestos? 1 2 8
N18. Were there any reactions to the notification from parents such as:
YES NQ DK
a. Requests to see the management plan? 1 2 8
b. Requests for additional information? 12 8
c. Requests for a special meeting
to discuss asbestos in this school? 12 8
d. Requests to add the topic of
asbestos in this school to the agenda
of a regular PTA or similar organization
meeting? 12 8
e. Withdrawal of children from classes
in this school? 1 2 8
N19. Were there any other reactions from parents?
YES :
(SPECIFY)
NO.
DK..
2
8
BOX 5
IF NO SHADED NUMBERS ARE CIRCLED IN N18 OR N19, SKIP TO BOX 8, PG 9. OTHERWISE,
CONTINUE.
Pages
-------
Form N1 (continued)
N20. Would you say a few, some, many or all parents responded in some way to the notification
pertaining to asbestos?
A FEW PARENTS ................................. 1
SOME PARENTS .................................. 2
MANY PARENTS .................................. 3
ALL PARENTS ...................................... 4
DK [[[ 8 [SKIP TO BOX 8, PG 9]
N21 . For parents who responded to the notification, would you say they expressed little concern,
some concern, or considerable concern?
LITTLE CONCERN ............................... 1 '
SOME CONCERN ................................ 2 [SKIP TO BOX 8,
CONSIDERABLE CONCERN .............. 3 ' PG 9)
DK [[[ 8
N22. How many times were parents notified about activities in this school pertaining to asbestos
since December 1987?
(NUMBER OF TIMES)
DK [[[ 98
N23. Beginning with the first notification, please give me the month and year in which parents were
notified about activities in this school pertaining to asbestos since December, 1987. [VERIFY
THAT ALL DATES LISTED ARE SINCE DECEMBER 1987]
a-
(MONTH)
(YEAR)
DK
9898
b.
(MONTH)
(YEAR)
9898
(MONTH)
_
(YEAR)
9898
d- I_J_M9I
(MONTH) (YEAR) 9898
-------
Form N1 (continued)
N24. Were parents notified by the school:
YES NO DK
a. In a letter, notice, or publication
regularly sent to parents (such as
a school newsletter)? 1 2 8
b. By a special letter, notice, or
publication sent to parents
specifically to inform them of
school activities regarding
asbestos? 1 2 8
c. During a regular parent-teacher
meeting, such as a PTA meeting? 12 8
d. During a meeting called specifically
to discuss asbestos In this school? 12 8
e. In an official press release? 1 2 8
f. In some other ways? (SPECIFY):
12 8
BOX 6
IF ANY SHADED NUMBERS ARE CIRCLED IN N24, CONTINUE. IF ALL DK IN N24, SKIP TO N26.
OTHERWISE, SKIP TO N27.
N25. Regarding the school meeting or meetings held, were minutes or written records later
published or distributed by the school?
YES 1
NO 2
DK ! 8
N26. Do you remember the contents of any of these notifications?
YES 1
NO 2 \ [SKIP
DK 8 J PG 9]
Page?
-------
Form N1 (continued)
N27. Did any of the notifications contain:
YES NO DK
a. Information about the availability
of a management plan? 1 2 8
b. An announcement about the performance
of the initial AHERA bidding inspection? 12 8
c. A list of materials containing asbestos
found in the school as well as the
location of these materials, at the time
of the initial inspection? 1 2 8
d. An announcement of response actions,
such as removal, encapsulation, or enclosure
of building materials containing asbestos, or
suspected to contain asbestos? 1 2 8
e. An announcement of other actions regarding
asbestos in the school? (SPECIFY):
1 2 8
f. General information about asbestos? 1 2 8
N28. Were there any reactions to the notifications from parents such as:
YES NO DK
a. Requests to see the management plan? ^2 8
b. Requests for additional Information? 1 ;: 2 8
c. Requests for a special meeting
to discuss asbestos in this school? ~Tv\ 2 8
d. Requests to add the topic of W- "
asbestos In this school to the agenda
of a regular PTA or similar organization ""<•••'
meeting? 1,2 8
e. Withdrawal of children from classes
in this school? 12 8
N29. Were there any other reactions from parents?
YES
(SPECIFY)
NO 2
DK 8
BOX?
IF NO SHADED NUMBERS ARE CIRCLED IN N28 QR N29, SKIP TO BOX 8. OTHERWISE,
CONTINUE.
Pages
-------
Form N1 (continued)
N30. Would you say a few, some, many or all parents responded in some way to the notifications
pertaining to asbestos?
A FEW PARENTS 1
SOME PARENTS 2
MANY PARENTS 3
ALL PARENTS 4
DK 8 [SKIP TO BOX 8]
N31. From parents who responded to the notifications, would you say they expressed little
concern, some concern, or considerable concern?
LITTLE CONCERN 1
SOME CONCERN 2
CONSIDERABLE CONCERN 3
DK 8
BOX 8
The next few questions are about notifications to teaching staff at [SCHOOL NAME] regarding activities
relating to asbestos that have been performed In this school since December 1987.
N32. Since December 1987, has the school or school board administration ever notified teaching
staff about any activities pertaining to asbestos in this school, such as a letter to teachers, a
meeting, or an article in the school newspaper?
YES 1
NO 2 \ [SKIP TO ENDJ
DK 8 J
N33. Since December 1987, have teaching staff been notified more than once about activities
pertaining to asbestos in this school?
YES 1 [SKIP TO N43, PG 12)
NO 2
DK 8
N34. In what month and year, since December 1987, were teaching staff notified of activities
pertaining to asbestos?
.191
(MONTH) (YEAR)
DK 9898
Page 9
-------
Form N1 (continued)
N35. Were teaching staff notified by the school:
NO DK
IF ANY SHADED NUMBERS
OTHERWISE, SKIP TO N38.
a.
b.
c.
d.
e
f
q-
ARE
In a letter, notice, or publication
regularly sent to the school community
(such as a school newsletter)?
By a special letter, notice, or
publication sent to teachers
specifically to inform them of
school activities regarding
asbestos?
During a regular parent-teacher
meeting, such as a PTA meeting?
During a school community meeting
called specifically to discuss asbestos
in this school?
During a regular teachers' meeting?
in an official press release? , ,
In some other ways? (SPECIFY):
BOX 9
CIRCLED IN N35, CONTINUE. IF ALL DK IN
1 2
... 1 2
... t 2
$ 2
..12
1 2
1 2
N35, SKIP TO N37.
a
a
a
8
a
a
8
N36. Regarding the school meeting or meetings held, were minutes or written records later
published or distributed?
YES 1
NO 2
DK 8
N37. Do you remember the contents of this notification?
YES 1
NO • 2 \ [SKIP TO END]
DK 8 ^
Page 10
-------
Form N1 (continued)
N38. Did the notification contain:
YES NO. DK
a. Information about the availability
of a management plan? 1 2 8
b. An announcement about the performance
of the initial AHERAbuUding inspection? 1 2 8
c. A list of materials containing asbestos
found in the school as well as the
location of these materials, at the time
of the Initial Inspection? 1 2 8
d. An announcement of response actions, such as
removal, encapsulation, enclosure of building
materials containing asbestos or
suspected to contain asbestos? 1 2 8
e. An announcement of other actions regarding
asbestos in the school? (SPECIFY):
1 2 8
f. General information about asbestos? 1 2 8
N39. Were there were any reactions to the notification from teaching staff such as:
YES NO DK
a. Requests to see the management plan? 12 8
b. Requests for additional information? \ 2 8
c. Requests for a special meeting
to discuss asbestos In this school? 1 - 2 8
d. Requests to add the topic of
asbestos in this school to the agenda
of a regular teachers'meeting? t 2 8
e. Requests to change classrooms or
transfer to a different school? 12 8
N40. Were there any other reactions from teaching staff?
YES 1
(SPECIFY)
NO 2
DK....: 8
BOX 10
IF NO SHADED NUMBERS ARE CIRCLED IN N39 OR N40, SKIP TO END. OTHERWISE,
CONTINUE.
Page 11
-------
Form N1 (continued)
N41. Would you say a few, some, many or ail teaching staff responded in some way to the
notification pertaining to asbestos?
A FEW TEACHING STAFF 1
SOME TEACHING STAFF 2
MANY TEACHING STAFF 3
ALL TEACHING STAFF 4
DK 8 [SKIP TO END]
N42. For teaching staff who responded to the notification, would you say they expressed little
concern, some concern, or considerable concern?
UTTLE CONCERN 1
SOME CONCERN 2 , - Q
CONSIDERABLE CONCERN 3 r 1SKIP TO END1
DK 8
N43. How many times were teaching staff notified about activities in this school pertaining to
asbestos since December 1987?
(NUMBER OF TIMES)
DK 98
N44. Beginning with the first notification, please give me the month and year in which teaching
staff were notified about activities in this school pertaining to asbestos since December, 1987.
[VERIFY THAT ALL DATES LISTED ARE SINCE DECEMBER 1987]
DK
(MONTH)
(YEAR) 9898
__
(MONTH)
(YEAR)
9898
(MONTH) (YEAR)
9898
(MONTH) (YEAR)
9898
e- — _M9|
(MONTH) (YEAR) 9898
Page 12
-------
Form N1 (continued)
N45. Were teaching staff notified by the school:
YES NO DK
a. In a letter, notice, or publication
regularly sent to the school community
(such as a school newsletter)? 1 2 8
b. By a special letter, notice, or
publication sent to teachers
specifically to inform them of
school activities regarding
asbestos? 1 2 8
c. During a regular parent-teacher
meeting, such as a PTA meeting? * 2 8
d. During a school community meeting
called specifically to discuss asbestos
in this school? 12 8
e. During a regular teachers'meeting? 12 8
f. In an official press release? 1 2 8
g. In some other ways? (SPECIFY):
1 2 8
BOX 11
IF ANY SHADED NUMBERS ARE CIRCLED IN N45, CONTINUE. IF ALL DK IN N45, SKIP TO N47.
OTHERWISE, SKIP TO N48.
N46. Regarding the school meeting or meetings held, were minutes or written records later
published or distributed by the school?
YES 1
NO 2
DK 8
N47. Do you remember the contents of any of those notifications?
YES 1
NO 2 \ [SKIP TO END]
DK 8 /
Page 13
-------
Form N1 (continued)
N48. Did any of the notifications contain:
YES NO. DK
a. information about the availability
of a management plan? 1 2 8
b. An announcement about the performance
of the initial AHERA building inspection? 12 8
c. A list of materials containing asbestos
found in the school as well as the
location of these materials, at the time
of the initial inspection? 1 2 8
d. An announcement of response actions.
such as removal, encapsulation, or enclosure
of building materials containing asbestos, or
suspected to contain asbestos? 1 2 8
e. An announcement of other actions regarding
asbestos in the school? (SPECIFY):
1 2 8
f. General information about asbestos? 1 2 8
N49. Were there any reactions to the notifications from teaching staff such as:
YES NO DK
a. Requests to see the management plan? 1 2 8
b. Requests for additional Information? 12 8
c. Requests for a special meeting ;>; - ,
to discuss asbestos in this school? t? 2 8
d. Requests to add the topic of \\
asbestos in this school to the agenda >. ^
of a regular teachers'meeting? 12 8
e. Requests to change classrooms or transfer to
a different school? 12 8
N50. Were there any other reactions from teaching staff?
YES
(SPECIFY)
NO 2
DK 8
BOX 12
IF NO SHADED NUMBERS ARE CIRCLED IN N49 OR N50, SKIP TO END. OTHERWISE,
CONTINUE.
Page 14
-------
Form N1 (continued)
N51. Would you say a few, some, many or all teaching staff responded in some way to the
notifications pertaining to asbestos?
A FEW TEACHING STAFF 1
SOME TEACHING STAFF 2
MANY TEACHING STAFF 3
ALL TEACHING STAFF 4
DK 8 [SKIP TO END]
N52. From teaching staff who responded to the notifications, would you say they expressed little
concern, some concern, or considerable concern?
LITTLE CONCERN 1
SOME CONCERN 2
CONSIDERABLE CONCERN 3
DK 8
END
Thank you very much for your cooperation with this questionnaire. The results will be used to assist in
the evaluation of the asbestos regulation.
End time: am
pm
Page 15
-------
June 25, 1990
AHERA
Form Ml: Management Plan Checklist
Start time:
am
pm
Building ID(s).
Reviewer
Review Date
General Inventory (10 pts.)
ic. Is a general Inventory of school buildings present?
Yes 5
No 0 [SKIP TO Q.4)
2c. Is the name and address indicated for each school building on the inventory?
All indicated..! 2
Most indicated 1
Some indicated 0.5
None indicated 0
3c. Is it indicated whether each school building listed contains friable ACBM, nonfriable ACBM, ACBM
assumed to be ACM or no ACBM?
All indicated 3
Most indicated 2
Some indicated 1
None indicated 0
Exclusion/Inspection Information (66 pts.)
4. Check if the following are present:
Exclusions declared for inspections
completed or for removal operations
conducted before December 14,1987? ( )
Inspection information for an AHERA
inspection? ( )
Pagel
-------
June 25, 1990
Form M1 (continued)
BOX1
REVIEW THE MANAGEMENT PLAN FOR EXCLUSION AND INSPECTION
COMPONENTS. COMPLETE THE MANAGEMENT PLAN REVIEWER'S COMPARISON
FORM THROUGH MP AHERA 1-7 CATEGORY.
5c. Does the management plan contain exclusion/inspection information?
Yes 5
No 0 [SKIP TO Q. 19 ]
6c. Does the exclusion/inspection information contain
ALL MOST SOME NONE
a. Dates of inspection? 1 0.6 0.2 0
b. Name of each accredited
person performing the inspection? 1 0.6 0.2 0
c. Signature of each accredited person
performing the inspection? 1 0.6 0.2 0
d. Accrediting state? 1 0.6 0.2 0
e. AHERA accreditation number? 1 0.6 0.2 0
7c. Does the exclusion/inspection information contain a blueprint, diagram or written description of
ALL MOST SOME NONE NA
a. Locations of homogeneous areas? 531 0
b. Approximate square or linear footage
of homogeneous areas? 531 0
c. Exact sample locations (if sampling
required)? 53 1 0 ( )
d. Dates of sample collection (if sampling
required)? 1 0.6 0.2 0 ( )
8c. Does the exclusion/inspection information identify whether homogeneous areas are TSI, surfacing
material or miscellaneous material?
In all areas 5
In most areas 3
In some areas 1
In no areas 0
Page 2
-------
June 25, 1990
Form M1 (continued)
9. Were samples collected as part of the inspection?
Yes ( )
No ( ) [SKIP TO Q.15]
10c. Is the method used to determine sample locations described?
For each homogeneous area 5
For most homogeneous areas 3
For some homogeneous areas 1
For no specific homogeneous area 0
11 c. Is the manner used to determine sampling locations completely or substantially in accordance with
AHERA for
YES NO NA
a. TSI? 2 0 ( )
b. Surfacing Material? 2 0 ( )
c. Miscellaneous Materials? 1 0 ( )
12c. Is the following information present for inspectors who collected bulk samples?
YES NO. NA
a. Name of Inspector? : 1 0 ( )
b. Signature of inspector? 1 0 ( )
c. Accrediting state? 1 0 ( )
d. AHERA accreditation number? 1 0 ( )
13c. Is the following information regarding bulk sample analysis present?
ALL MOST SOME NONE NA
a. Copies of analyses 531 0
b. Dates of analyses 1 0.6 0.2 0
c. Name(s)andaddress(es)of laboratory(ies).... 1 0.6 0.2 0
d. Statement(s) of laboratory accreditation 21 0.5 0 ( )
14c. Are the name and signature present for persons who performed analyses of the bulk samples?
All 2
Most 1
Some 0.5
None 0
NA. ( )
Pages
-------
June 25, 1990
Form M1 (continued)
15. Is any friable or friable assumed ACBM or TSI reported in the exclusion/inspection information?
YES ( )
NO ( ) [SKIPTOQ.24]
I6c. Are written assessments present for friable ACBM, friable assumed ACBM, nonfriable material
which is newly friable and/or TSI?
All 5
Most 3
Some 1
None 0 [SKIP TO Q.19]
17c. Do the written assessments in Q. 16 provide
YES Np_
a. Signature of the assessor? 1 0
b. Date of signature? 1 0
c. Accrediting state? 1 0
d. AHERA accreditation number? 1 0
18c. Are reasons given for each assessment?
For all 5
For most 3
For some 1
None 0
Response Action Recommendations (30 pts.)
Box 2
REVIEW RECOMMENDED RESPONSE ACTIONS AND COMPLETE THE
MANAGEMENT PLAN REVIEWER'S COMPARISON FORM
I9c. Are there written recommendations to the LEA regarding response actions for friable
homogeneous areas and TSI?
All 10
Most 6
Some 2
None 0 [SKIP TO Q.22]
Page 4
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June 25,1990
Form M1 (continued)
20c. For the management planner who made the recommendations In Q. 19, is there
YES NO.
a. Name? 1 0
b. Signature? 1 0
c. Date? 1 0
d. Accreditatlng state? 1 0
e. AHERA accreditation number? 1 0
21 c. For the response actions recommended, are there
ALL MOST SOME NONE
a. Methods described to be used for preventive
measures and response actions? 5310
b. Locations specified where such actions and
measures will be taken? 5310
c. Schedules for beginning and completing each
preventive measure and response action? 53 10
[Question 22c. intentionally excluded]
Activity Plans (39 pts.)
23c. Are activity plans or statements present for
YES NO.
a. Relnspectlons?..... 5 0
b. Periodic surveillance? 5 0
c. O&Mplan? 10 0
d. Management planner recommendation for
initial and additional cleaning? 5 0
e. The LEA response to initial cleaning
recommendation? 3 0
[SKIPTOQ.25]
24c. Are activity plans or statements present for
YES NO NA
a. Reinspections? 14 0 ( )
b. Periodic Surveillance? 14 0 ( )
Pages
-------
June 25,1990
Form M1 (continued)
25c. Are steps described by which workers and building occupants, or legal guardians, will be or have
been notified about
YES NQ
a. Inspections/reinspections? ............................................. 2 0
b. Response actions? [[[ 2 0
c. Post-response action activities, including
periodic surveillance and reinspections? ........................ 2 0
d. Availability of management plan? .................................... 5 0
Resource Evaluation (10 pts.)
26c. Is an evaluation of resources needed to complete the response actions and carry out
reinspections, O&M, periodic surveillance and training present?
.......... 5
NoZZZZZZZZZZZZZ ........ .' o [SKIP 100.28]
27c. Does the resource evaluation take all activities listed in Q23/Q24 and all recommended actions into
account?
All [[[ 5
Most [[[ 3
Some [[[ 1
None [[[ 0
ADP (6 pts.)
28c. Are the following items provided regarding the LEA's designated person?
YES NO.
a. Name [[[ 2 0
-------
June 25,1990
Form M1 (continued)
AIR SAMPLE CLEARANCE RESULTS
BOX 3
REVIEW THE CLEARANCE AIR SAMPLE RESULTS (IF ANY) SUBMITTED IN THE
MANAGEMENT PLAN PACKAGE. ANSWER THE FOLLOWING QUESTIONS.
29a. Were clearance air sample results submitted with the management plan package?
Yes 1
No 2 [SKIP TO Q31]
30. Was the method of analysis of the clearance air samples
YES NO DK
a. Transmission Electron Microscopy (TEM)? 128
b. Phase Contrast Microscopy (PCM)? 1 2 8
USABILITY
31 u. Are the following Items, which may enhance usability, present?
YES NO
a. Table of Contents - basic 1 2
b. Table of Contents - detailed 1 2
c. Headings for Table of Contents used consistently in text 1 2
d. Pages are numbered 1 2
e. Definitions section 1 2
f. Narrative(s) which describe sections 1 2
g. Program Organization Chart 1 2
h. List other items which enhance the usability of this
management plan.
List items which detract from the usability of this
management plan.
Page?
-------
June 25, 1990
Form M1 (continued)
32u. Could the Management Plan be used and understood, without prior instruction, by persons with
a. Less than high school diploma? 1
b. High school diploma? 2
c. An advanced degree beyond high school? 3
33u. Could the Management Plan be used and understood, without prior instruction, by persons with
AJI Most Some None/Few
a. Knowledge of the school's buildings? 123 4
b. AHERA asbestos inspection experience? 123 4
34u Are the following terms used correctly, as defined by AHERA. in the MP?
YES NO NA
a. Homogeneous Area .: 1 2 ( )
b. Functional Space 1 2 ( )
c. Exclusion 1 2 ( )
d. Random Sampling 1 2 ( )
End time: am
pm
Pages
-------
SCHOOL :
BUILDING:
OJUIU
01
MIOH SCHOOL
MAIN 8LOC
Form M2: Management Plan Comparison Report
CSU : A24U
SAMPLE IU: PU36
DATE: JWU/V'J
PA3E: V
fctSMT MATtRIAL:
TYPE:
IcXTURt/COLOR:
WtSlftl AHEAS
10 ROOM
MU6. VXV NICROHOLt i !CT
302. Catling til* - glu«-on
42. Whit*
HP AREAS
(CHECK IF
LEVEL PRESENT)
HP RESPONSE ACTIONS RECOMMcNUEO
HP AHERA . APPROPRIATE RESPONSE
4ESTAT HP HP HATERIAL CATEGORY . . BEYOND AHERA
3UANTITV QUANTITY SAHPLES ASSESSED? (1-7) . . . ReSPOUSt
115 STAIRWAY B 6.0 SF
146 BOY'S LOCKfcR FUl 21.0 SF
C4V GIKL-S LOCKER Fill 16.0 SF
C50 OFUtE FUl 48.0 SF
C5J HALLMAY FOl 47.0 SF
Utt> CLASSROOM FUl 312.0 SF
UBJ STAIRWAY LANDING FU2 3J.O SF
L»4 STAIKWAY LANDING FU2 35. U SF
086 CLASSROOM FU2 _._ 1.U SF
UBf CLASSROOM FU2 Z7.U SF __
1UB CLASSROOM f"U2 . 11.0 SF
111 HALLHAV FU2 6f.U SF
11* CLASSROOM FU2 113. U SF __ ._
113 CLASSROOM FU2 37. U SF
11* CLASSROOM FU2 _ . 64. U SF
115 CLASSROOM FU2 47. U SF
118 CLASSRUOM FU2 39.U SF
101AL: V2*.U *F .
i i
i
N NA 1
N NA
N NA
N NA
N NA
N NA
N NA
N NA
N NA
N NA
N NA ___
N NA
N NA
N NA
N NA
N NA
N NA
r N NA V N NA
r N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
r N
r N
• S 3
r N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
N
t = =
r N
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
N G S
ESS S = Z= == = =
r N G s
»P NO.
DESCRIPTION : ..
HP TYPt : T
TYPt CURKECT?: Y
S
N
M
All
| I SAHPLES COLLECTED :
| CORRECT? (AHERA HIN):
I EXCEEDS AHERA? :
NOT INDICATED | BULK SAHPLE RESULTS :
| (IF NEC' STOP ROW)
V N
V N
A P N
HP APPRO-
PRIATE?:
V N
(It- NA,
STOP RON)
MP APPRO-
PRIATE?:
Y N
(IF NA,
STOP ROM)
RESPONSE ACTION
RECOMMENCED:
-------
APPENDIX B
TRAINING MATERIALS FOR COMPLETING FIELD FORMS FOR THE AHERA
EVALUATION
TO BE DONE
B-l
-------
APPENDIX C
TRAINING MATERIALS FOR COMPLETING TELEPHONE FORMS FOR THE AHERA
EVALUATION (SCREENING QUESTIONNAIRE, INSPECTOR QUESTIONNAIRE, PARENTS
AND TEACHERS NOTIFICATION QUESTIONNAIRE)
TO BE DONE
C-l
-------
PEER REVIEW DRAFT
APPENDIX D
PARENTS AND TEACHERS NOTIFICATION
FOCUS GROUPS
DISCUSSION GUIDE AND FINDINGS
Parti: Discussion Guide
Part 2: Findings
D-l
-------
PEER REVIEW DRAFT
Appendix D presents the discussion guide and findings of the parent and teacher
notification focus groups held for the AHERA evaluation. These groups were conducted with
parents and teachers from schools in four locations nationwide.
Parti
A discussion guide presents a starting point for group discussions and is not a formal
questionnaire. Unlike a questionnaire which must be administered in the same exact manner each
time it is used, a discussion guide provides topics for the moderator to discuss using whatever
phraseology he/she is comfortable with in the context of the ongoing discussion.
The following presents the discussion guide that was used during the parents and
teachers focus groups.
D-2
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PEER REVIEW DRAFT
July 1990
FOCUS GROUP GUIDE FOR NOTIFICATION FOCUS GROUPS
Introduction
• Introduce yourself, the concept of focus groups, AHERA, the new asbestos law, and
the evaluation. Explain 3 steps - inspection, maintenance plans and response to
any asbestos found.
• First, I'd like to say that everything you say during this discussion will be held
confidential. Following standard focus group procedures, this session is being
taped to make it easier for me to write a report. Also, following standard focus
group procedures there are observers behind the mirror. The mirror is there
just so the observers don't interfere with our discussion.
• Reassure parents and teachers that the group's findings will be held confidential,
and that none of the examples given during the group pertain to the individual
schools with which respondents are associated.
• What is your first name and what is your role at the school with which you are
associated? (Remind them not to mention school name.)
Asbestos in Schools
Q • Does your school have asbestos currently?
Q • Was asbestos found in a recent inspection for asbestos?
Q • Did you ever receive a notification about asbestos in your school? [Probe for
letter, newsletter, posted on a school bulletin board or in a meeting.]
What did it contain? [Probe for locations of A CM in school]
How were you notified?
Was there any parent/teacher reaction to the notification?
Q • Do you know if your school has a Management Plan?
Were you informed it was available for review?
Have you ever reviewed your school's Management Plan? Do you know
anyone in a position like yours who reviewed your school's Management
Plan?
Do you know where Management Plan is located? [Probe for availability,
access to updated version.]
How easy did you find it to understand?
What did your Management Plan contain?
Was the Management Plan available in a second language?
D-3
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PEER REVIEW DRAFT
Examples of Notifications
• West Township notification example will be handed out and discussed.1 The
moderator will ask questions about what respondents think their reaction to this
type of notification in their school would have been.
Does this notification give you as much information as you would want
from a notification?
Would you call the school or someone else to discuss this notification?
• South Community notification example will be handed out and discussed.2
Does this notification give you as much information as you would want
from a notification?
Would you call the school or someone else to discuss this notification?
• North Community notification example will be handed out and discussed. 3
Does this notification give you as much information as you would want
from a notification?
Would you call the school or someone else to discuss this notification?
• Now that you have seen these three types of notifications how would you
compare your reactions to them?
• What elements of a notification do you think are most critical for parents or
teachers to feel appropriately informed?
Name of responsible person;
Telephone number of responsible person;
Description of the AHERA law;
Name/qualifications of inspection company or lab;
Explanation about friability;
Description of the findings of the asbestos inspection (locations/condition);
and
School responses to asbestos found;
Health risks of asbestos.
* West Township Example is a "minimalist" notification, barely fulfilling the requirements of AHERA.
2 South Community Example fulfills the requirements of AHERA and contains information on the response action planned but not the
location of materials found.
3 North Community Example fulfills the AHERA requirements and presents information on where asbestos is located in the school.
D-4
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PEER REVIEW DRAFT
If There Is Time
How you think parents and teachers would reaction to different methods of
dissemination such as:
Hand carried letters;
Notice posted on school bulletin board;
Letters either mailed with other materials or mailed alone;
Notification in a PTA meeting;
PTA president's being notified by mail; and
Notification through a school newsletter. (Appletree example).
How different do you think that retention of these notifications might be with
these different methods of distributing the information?
Thanks and Conclusion
• Thank you for agreeing to participate in this group. As we said any examples we
have used do not relate to the specific schools in which you work. Anything that
you have told us will only be reported on using your first names.
• Goodbye.
D-5
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PEER REVIEW DRAFT
Part II
The following section presents the findings of the focus group discussions held with
parents and teachers in four locations nationwide. These focus groups posed questions to parents
and teachers from various schools throughout the four locations. Participants were recruited
based on working in or being a parent of children in a school built before 1975, which serves
children in some of grades 1 through 12. Special efforts were not made to recruit actively involved
parents or teachers. Opinions about the adequacy of the various notification examples and
contents reflect parent and teacher beliefs, rather than EPA or Westat judgments about adequacy.
The letters used as the basis for discussion about reactions to different types of
notification are appended to this section.
D-6
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PEER REVIEW DRAFT
NOTIFICATION FOCUS GROUP
St. Louis, Missouri
Date: July 9,1990
Attending: Six Parents, all women, and four teachers, two of whom were also parents of school
age children. One teacher was a man. One teacher worked in a Catholic school; the
remainder were affiliated with public schools in the St. Louis, Missouri area.
Previous Knowledge of Asbestos
The initial topics of group discussion were knowledge about the presence of asbestos
in participants' school and knowledge of whether or not the school had been inspected for asbestos
within the last two years. A total of seven group participants knew whether asbestos was in their
school, and all of the teachers knew this fact. By contrast only five participants knew about an
inspection for asbestos performed within the last two years. The others knew the asbestos status of
their school from hearsay, or from previous asbestos inspections.
When asked about receiving notifications of the asbestos status of their schools, all of
the parents (including those who were also teachers) remembered being notified, and three of the
four teachers remembered being notified. One teacher had to sign a statement that she had been
informed of the asbestos status of her school. One participant described her notification as
follows:
'It was a letter, but worded in legal language ... It simpfy stated that asbestos has been
found in these areas in the school, and that the school would be working in compliance
with the Management Plan."
All but one of those who remembered being notified stated that their notifications
"mentioned the areas of specific concern," i.e., the areas in which friable, or at least accessible or
damaged friable asbestos had been found.
D-7
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PEER REVIEW DRAFT
When asked what their reactions had been to these notifications, all said that they had
not reviewed the Management Plan or reacted in any other significant way.
The letter outlined things so you knew what the problem was, and you knew what they
were doing so you didn't have any questions ... They covered all these grounds ... We're
trusting in the district that they are handling it, and they are doing the things that they say
they are doing."
Five participants had heard about their school's Management Plan, though none had
reviewed it. All said that they felt welcome to look at it if they had chosen to do so, though only
one person knew where the Management Plan was located. The other participants stated that they
would have a "good guess" of where to start in looking for the Plan, and that they were sure that
they could find it to review if they wanted to.
Examples
Three examples of notification letters were distributed to the group for their reaction.
Each letter presented a different degree of information about asbestos inspection, location of
ACM, and designated person information. Examples of these letters are in attachment D-l.
The West Township example was widely felt to be "unclear", and to be obscuring the
actual findings in the school. Eight people said that they would call the school if they had received
this letter, and there was general agreement that there would be "a stir" if this letter was sent to
parents.
Concern was also expressed that the designated person was not school-based, and
therefore would be speaking only from "hearsay" rather than direct knowledge of the school's
situation, which illustrates lack of knowledge of the role of the designated person. Other
participants worried that as the designated person was a "supervisor", it would not be possible to
reach him by telephone to ask for information.
One person expressed distress that the format of this notification was a memo rather
than a letter. She felt that a memo was more impersonal and cold than a letter, and that a letter
was more suited to the notification process than a memo.
D-8
-------
PEER REVIEW DRAFT
The South Community example was received much more positively by this group than
the West Township example had been.
"I get a good feeling from reading this. It's to the point, it's thorough [and] it has specifics.
If I were a parent I'd feel very comfortable with what has been done and what will be
done... [by the South Community School District.]
The word "compliance" in the phrase "In compliance with the U.S. Environmental
Protection Agency regulation" was felt to be very positive, particularly in comparison to the word
"pursuant" which had been used in a similar context in the West Township example.
Several parents also voiced approval of the South Community definition of the word
"friable."
Several other parents and teachers, however, expressed a different perspective; "My
initial reaction would be 'does my school have it?'... So I'd still have to make a phone call" These
parents and teachers wanted to know if their school had asbestos, and possibly even where it was
located.
About half of the group said that if they received the South Community notification
letter they would call either the principal or someone else at the school to learn more about the
school's asbestos situation. These parents generally felt that the notification should be school
rather than school district based, and that they would be more comfortable if they had received a
letter from the principal rather than the designated person. In general, participants stated that
principals were accessible and knowledgeable in contrast to the unknown and somewhat distrusted
ADP.
The North Community example was generally felt to be "too long." Indeed the
moderator was required to encourage the group to finish reading this letter, rather than to begin
discussing it without having fully read it. As several people said,
7 don't have time to read this."
"It's longer than one page."
D-9
-------
PEER REVIEW DRAFT
Others however, disagreed about the length being too long.
"/ think that its real clear, and it gets it down in everyday language ... Even though its
lengthy, if you have a person who is realty concerned, they will spend the time with it..."
while others may not read all of it.
One person even thought that the fact that the letter was so long showed that it was "important".
When asked if they would read the whole letter, everyone said that they would.
Only one person said that she would call the school or district about this letter. When
the moderator asked her what she would inquire about during this call, she said that she would
want to know the time frame for the school's proposed response actions.
One person thought that the North Community example "would be inflammatory" as
once they were given this much information, PTA members would want more and more
information on location, condition, and health-related information on the asbestos found in the
school. She said that her school would never send such a letter to parents, and seemed to think
that was appropriate.
Considerable discussion was raised about the North Community notification's
reference to the periodic reinspection of the school. This group thought that a reinspection every
six months was inadequate, and that "lots can happen in six months, lots."
Comparison Between Examples
This group as a whole overwhelmingly preferred the South Community example. All
of the teachers preferred it, and only one of the parents preferred the North Community example.
Some of those who preferred the South Community example wished it had contained a few more
specifics of asbestos locations like those that were listed in the North Community example.
D-10
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PEER REVIEW DRAFT
Outline for Future Notifications
When asked what the contents of an ideal notification would be, the following items
were mentioned by one or more people:
• Letter as opposed to a memo format;
• Definition of friability;
• Information on asbestos not posing a health hazard;
• Availability of a school-based asbestos resource person in the school;
• Explanation of and reassurance that appropriate response actions were being
undertaken;
• Timetable for the response action; and
• Statement that the school was in compliance with the regulation.
Several people also voiced a request for the letter to be "reassuring" to parents.
When asked by the moderator about the importance of specific items being included
in future notifications, the following priorities emerged:
• Name of a designated person. One person thought that the name of a district
level designated person should be presented in the notification, and nine
thought that the name of a school-based designated person should be
presented. Most of these nine thought the principal should be the school's
designated person.
• Designated person's telephone number. Eight participants thought that the
designated person's telephone number should be presented in the notification.
• Description of the law. Four participants thought that a general description of
the law, or at least a statement that the school was in compliance with the law,
should be included in the notification.
• Name of the inspection company. None of the participants thought that the
name of the company performing the inspection of the school was important or
should be presented in the notification letter.
• Definition of key terms. All participants thought that the key terms presented
in the notification (e.g., friability) should be defined within the letter.
D-ll
-------
PEER REVIEW DRAFT
Location of asbestos-containing building materials. When directly asked, none
of the participants in this group stated that they thought the location of the
asbestos-containing building materials in the school should be included in the
letter. Some, however, thought that the letter could contain a brief description
of areas of particular concern.
Response actions planned. Three participants thought that the notification
should include a description of the school's planned response actions and the
timetable for these actions.
Method of Distribution
Both parents and teachers in this group responded overwhelmingly in favor of
notification letters being mailed to parents in a dedicated mailing. These participants thought that
by sending a notification in this way, the school was doing the maximum to ensure that parents
were informed, and that the school recognized that the notification was an important topic. With
regard to other notification techniques the group stated:
• When letters are sent home with children you are "lucky if 50% arrive."
Moreover, "there are some fads that would read this and freak out, and say 'that's
it, Mom, I refuse to go to school'"
• Bulletin boards were felt to be too public, and frequently not read.
• Notification either of PTA/PTO presidents or of parents through PTA/PTOs
were considered inappropriate. These organizations were not the correct
avenue for notification as not enough parents participate, and these
organizations do not have the budget or the mandate for this type of
notification.
• Notification through newsletters, as in the Appletree example (distributed to
the group as an example of a newsletter notification), was thought to be an
acceptable supplemental notification, but inadequate as primary or sole
notification of the asbestos status in the school.
In conclusion, the group strongly felt that the most effective way to notify parents of
the school's asbestos status was through a dedicated mailing of a letter notifying the parents of the
findings of the school's asbestos inspection.
D-12
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PEER REVIEW DRAFT
NOTIFICATION FOCUS GROUP
Boston, Massachusetts
Date: July 12,1990
Attending: Five parents (one of whom was on what is commonly called the district's school
board, and two of whom were PTO office holders) attended this group. In addition
six teachers, three of whom were also parents of school-age children, attended. All
of the participants were women, with the exception of one teacher who was also a
parent. All were affiliated with public schools in the Boston, Massachusetts area.
Previous Knowledge of Asbestos
The level of knowledge about the asbestos situation in the schools represented by the
participants was very low. When asked if the school with which they are associated had asbestos,
several people said, Wo", only to revise their statements as the discussion progressed by saying
that they had been told that asbestos in their school was at 'safe levels". Two women initially
answered that the schools their children attended were "too new" to contain asbestos, but upon
questioning by other group members these women admitted that the schools had been built in the
mid to late sixties. These women then learned through other, better informed participants that
both schools might indeed have asbestos.
Those who did know something about the asbestos status of their schools seemed to
do so more through hearsay than through official notification. The only participants who firmly
remembered being notified in any formal manner were two of the four teachers. One of the other
teachers thought that perhaps the superintendent had told them about asbestos in their school at a
meeting, though she did not remember this clearly.
During this discussion the member of the district's school board stated,
"After the schools were inspected for $100,000, "We then had to go and allocate another
$100,000 to do this study because there was something in the law that said you had to do
it yearly [reinspect.] / remember it ticked me off because you knew where you were at
and you shouldn't have to keep this process going for ever."
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Examples
Three examples of notification letters were distributed to the group for their reaction.
Each letter presented a different degree of information about asbestos inspection, location of
ACM, and designated person information. Examples of these letters are in attachment D-l.
The West Township example elicited considerable concern and even some anger.
Immediately upon reading the notification participants zeroed in on the fact that,
"/ think that they should have told you what the results were."
"It strikes me that if it came out and it was a good report they would have said something
about it," i.e., the findings in this school district probably were quite negative.
Over half of the participants in this group expressed continual questions about the location of the
asbestos found during the inspection, and why this information was not included in the West
Township example.
When asked about the strengths of the West Township example, one person said, "It
brings it [the asbestos inspection] to your attention that you may want to then find out more... It lets
you know who to contact to get more information."
The reaction was, however, on the whole quite negative. As one participant said,
"As a teacher [the contents of this notification are] easy because you then go to the
office and say 'what was the result?' As a parent its a completely different situation
because I think it is a burden to ask each parent to call the office and find out what's
going on."
One participant was even more vigorous in her denunciation of the West Township notification,
stating,
"I personalty can't stand this because of rumors. I can't stand this whole letter because
this is like a trigger to make everybody go 'Oh my God, Oh my God.' You either have a
problem or you don't and this letter raises questions, without presenting any answers."
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One participant thought that the notification could easily have been improved.
"An additional sentence in here could have allayed any fears that parents have at all...
'The findings in such and such a school were acceptable."
Despite the overall negative reaction from this group, one participant did, however,
admit that most people would not react in any significant way to this notification: "You see that
there was an inspection and you see 'has complied' and a lot of people would toss it [the letter]."
The South Community example was greeted less negatively, but participants still
thought that,
7 would want to know which schools have the problem and how they are going to deal
with it, and when they are going to deal with it."
"The letter should be "a little more specific than this... [It] should be more specific to the
school"
"I would be on the phone immediately to find out how my school related and, if they were
going to be doing anything to treat the asbestos, when they would be doing it."
On the whole, however, the South Community notification was thought to be "better than the first
one," though it would be better still as a "cover form for each school to attach their own communique
to, outlining specifically what was found in that school"
When asked if they would call the school after receiving this letter, six participants
said that they would call. One who said he would not call stated,
7 would guess that most people, which may not be the people around this table... would
not read this and would be trusting... "Yes, it was found and they have a plan for it and
they'll take care of it and so now I don't have to worry about it.' If there are 200 parents
maybe 10 to 15 would call"
When asked to summarize their reactions to this notification several of the
participants in this group stated that: "This letter makes you feel more comfortable... the only thing it
should have added is the findings in each school" The only specific item that this group could list as
contributing to this comfort was the presence of a definition of the term "friability".
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Reaction to the North Community example was more positive than to either of the
other two, though only marginally so. It is difficult to separate out whether some of the reactions
in this group were to specific components of the notification (e.g., participants did not like the fact
that in this example custodians would be performing the removal of ACBM) and whether they
were to the overall design of the notification. The participants did say, however,
"It certainly gives a lot more information, but boy am I mad - first to require the
custodians to remove the asbestos, its cruel and unusual punishment, and second to
expect people to pay" $15 for a copy of the Management Plan.
"It's telling you what there is to tell you. You may disagree with something but they are
telling you what they are doing."
One person expressed concern that the level of detail and length of the letter would
make it very hard for a non-native English speaker to comprehend. A teacher then said that the
letter would be sent out in Spanish if her school knew about the potential language problem, even
if the child were in a standard classroom rather than a bilingual program.
One parent summarized the group's reactions by saying: "I like this better than the
other two because the second page is specific ... It's telling you what's happening, what they are
planning to do, and where the problems are."
When asked if they would call the school or the designated person after receiving this
letter, only one person said yes. She said she would question the appropriateness of the
custodians' performing the response actions, but other than that would not have any questions
about the letter. All present agreed, however, that they would call the school to ask for more
details if their child were a student in one of the classrooms with asbestos listed on the second
page of the letter.
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x
Outline for Future Notifications
The elements listed by the participants in this group as important to a notification
• Information on asbestos locations specific to the school;
• Time frame for response actions;
• Name and phone number of someone to call for additional information;
• Short summary of the AHERA act and any standards it contains;
• Explanation of the health risks of asbestos;
• Description of the inspection process, an explanation that "An agency has gone
through each and every room and fine combed it for asbestos"; and
• Report on the planned response actions in each school.
In general, this group was extremely interested in having a short and to the point,
school-based notification. Ideally, this notification would present the locations, conditions, and
planned responses to asbestos in each school, though in the very compressed space of one to two
pages of text.
One interesting suggestion to emerge from this group was the idea that the
superintendent should run school-by-school meetings on the topic of asbestos in each school. This
parent thought that this type of meeting would be very important to increase parental
understanding of the asbestos issue in schools. The notification letter could then contain
information on the upcoming meeting as well as some of the specific items listed below, the
importance of which were discussed by the participants:
• Name of a designated person. All eleven participants thought that this was an
important element in a notification.
• Designated person's telephone number. All present thought that this was
important.
• Description of the law. Eight people though that a brief description of the
AHERA regulation should be included in all notifications.
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Name of the inspection company. Ten people wanted to know something about
the inspection company. Several people said that knowing the company was
"certified" would be adequate, others thought a statement as to the training of
the inspectors would be adequate.
Definition of key terms. All eleven people thought that a definition of key
terms such as friability should be included in the notification. During the
earlier discussion of the examples, a question was also raised about the
meaning of the terms TSI, Surfacing and Miscellaneous, which should be
defined if they are used.
Location of asbestos-containing building materials. Ten participants thought
that the location and description of the ACBM in the school should be
included.
Response actions planned. All of the participants expressed a considerable
interest in what response actions would be undertaken, and believed that this
information should be included in the notification. All of the participants also
thought that the time frame for these response actions should be included.
Health risks of asbestos. Nine participants thought that a brief description of
the health risks of asbestos should be included in the notification.
Method of Distribution
Financial constraints in this community's school system more or less removed the
possibility of mailing the notification letters to parents. For this reason, discussion centered more
on the different ways that notifications sent home with children can be assured of reaching their
destination. The group as a whole agreed that "if money were not a problem, then that [direct
mailing of notifications to parents] is the way to do it." Other topics of discussion included the
following:
• Over half of the participants in this group stated that the superintendent of
schools should conduct a press conference either before or immediately after
notification letters were sent out. This press conference would ensure "that the
information is correctly quoted in the newspaper."
• Some discussion occurred on the desirability of notifying parents in a newsletter
that an "important notice" regarding asbestos would be sent home with the child
on a certain date. Some people thought that this type of pre-notice would
ensure that parents asked for the notification from their child, while others
thought "you are then setting everybody up to say "when is this important notice
coming?"' No consensus was reached on this topic.
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• Notification through PTA or PTO meetings was considered inadequate as "not
enough people attend," Moreover the PTA office holders did not .want the
responsibility for notifying parents.
• Notification through school newsletters was thought to be inappropriate, and
certainly the Appletree example, distributed to the group as an example of a
notification by newsletter, was considered to be inadequate. Wo way, this opens
a can of worms ... I'd rather have nothing than this," said several parents about
the Appletree example.
In conclusion, the group as a whole thought that the only method of notification
possible in their school system was for the letters to be sent to parents through children, though in
a more ideal world, these notifications would be sent to parents in the mail.
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NOTIFICATION FOCUS GROUP
Seattle, Washington
Date: July 16,1990
Attending: Five parents, all of whom were women, and four teachers, two of whom were also
parents of school age children. One teacher was a man. All participants were
associated with public schools in the Seattle, Washington area.
Previous Knowledge of Asbestos
The parents in this group knew very little about the asbestos status of the school with
which they were associated, while all four teachers believed that they did know the current status
of asbestos in their school. No one in the group recalled being informed through a formal
notification process, while the teachers had gained their knowledge through in-person contact with
asbestos inspectors or removers working in the school.
One teacher in a small parochial school had been part of a volunteer effort to remove
floor tiles in her school. She said that after they had done the job she heard something about the
material or glue being asbestos. This incident occurred within the last two years, and was not
preceded by any training or notification.
This participant was, however, involved in an awareness type training about asbestos,
conducted by the Lutheran Teachers Council, of which she was a member. No other teacher had
received any type of training about asbestos from any school or school-related source.
None of the participants in the group had reviewed or heard of their school's
Management Plan.
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Examples
Three examples of notification letters were distributed to the group for their reaction.
Each letter presented a different degree of information about asbestos inspection, location of
ACBM, and designated person information. Examples of these letters are in attachment D-l.
Reaction to the West Township example was overwhelmingly negative.
"// doesn 't tell me anything."
"I'd probably panic if I read it, and want to go find out what the results in my school were
and what they were going to do about it, and how bad it is. It would trigger me to make
several phone calls."
"I'm going to start asking lots of questions."
"I feel my time would be wasted with this letter... First off I'm frustrated because it tells
me nothing. Second off I'm angry because they wasted my time and told me nothing."
Other parents expressed misunderstanding of or dislike for some of the contents of
the notification, stating,
"I'm going to assume that there has been a problem [after reading this letter] because
they have developed a plan... Why would you need a Management Plan if you didn 't have
a problem?"
"'Pursuant,' what does that mean?"
Only one teacher, who was also a parent, did not find the West Township example
objectionable. She also expressed such overwhelming confidence in her school district that she
would have been comfortable not being notified at all. She said,
7 suppose it depends on how much faith you have in your school district. I say 'great,
they must have taken care of it, my kids are safe.' That's the way I look at it as a parent.
As a teacher I say 'good, my school's safe'... My job is to teach the children and I don't
realty need to be bothered with it. Now as a parent if there is a a hazard to my children
yes, but I stick with 7 trust my district'."
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In general the concerns about the West Township example were that it did not
actually notify parents and teachers of the results of the inspection, nor did it say what would be
done in response to the inspection.
Of the assembled group, seven people said that they would call the school after
receiving this notification. The two who said that they would not call the school were the very
trusting teacher quoted above, and a teacher who said he would simply ask someone at the school
for more detail after receiving this letter.
The South Community example was generally thought to be "much better than the
other one, [it] gives much better information." One parent said as an apparent compliment to the
South Community example, "This one is going to pacify me right there."
None of the parents said they would call the school after receiving this notification,
though several said that they would ask 'casual" questions about it when they got a chance.
When asked what they liked about this example they said that it was friendly, brief (as
one person volunteered, "nobody reads two pages") and signed by the AHERA designated person.
When asked about the weaknesses of this notification the group raised the following
questions:
"What are the [response] measures to be taken?"
"Are they going to dose off certain areas" of the school for response actions?
"It doesn't tell about health risks" of asbestos.
The North Community example was generally felt to provide more information than
needed in a notification of this type. Discussion of the North Community example lead to the
following dialogue:
Parent: "Parents don't want to know all this stuff
Teacher 1: "I don't want to know all that stuff."
Parent: "AU they had to do is say 'we found asbestos and this is what we're doing
about it.'"
Teacher 2: "There is obviously a problem and they are dealing with it, however, why
they had to tell the parents all this nitty-gritty stuff is beyond me."
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When asked if they would call the school after receiving this notification only one
parent said she would call. "I'd call to say if there is that much asbestos and all this work has to be
done, then why is the school open?"
Specific concern was voiced about the sentence in the notification that reads, "If you
discover any damaged ACM, immediately report it to a teacher, principal, or supervisor." This
sentence was thought to indicate that the school did not have confidence in their original AHERA
inspection, and was asking for the active assistance of parents and staff in performing inspections.
By contrast, one teacher in this group thought that the best sentence in the
notification was "Our goal is to ensure the health and safety of all North Senior High School
occupants."
Considerable discussion occurred on the topic of how much information parents need
to know about asbestos.
7 trust them to do it [behave responsibly about asbestos] but I'd almost rather not know
about it because if I know about it I'd want them to get it out."
"The more [information] you give them the more parents start to knock down the door."
By contrast one teacher thought that this letter was stronger than the others because
it did provide so much information.
"/ get the feeling that this letter is a little more honest than the rest... The others say a
Management Plan is available for review, but it doesn 't say how you obtain it. You might
have to pay $15 to get that one also. This one [North Community notification says] if
you want to own it you have to pay $15, or you can review it. I just think they are being a
lot more honest."
In general, however, this group believed that the level of detail in this example, and
particularly the list of areas with ACBM, was needlessly disturbing and unnecessarily detailed.
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Comparison between Examples
Participants in this group preferred the South Community example over the other
two. This was particularly surprising given their reaction to the West Township example, in which
they had eager requests to learn the findings of the inspection. When asked about this apparent
contradiction, the group expressed surprise over the extent of ACBM in the North Community
example, and seemed to be saying 'if it is that bad you would be better not to tell us about it in
detail.' One person did, however, state that if the first page of the North Community example had
been more concisely and clearly written she might well have more patience and attention left for
the presentation of materials on the second page.
Outline for Future Notifications
When the group was asked about what they would include in a notification, the
following points were raised:
• The health risks of asbestos. (This opinion was expressed by several people,
though others said "no, [that shouldn't be included] that is scary*);
m Explain the law and that it is being complied with;
• What will be done about the problem;
• When the problem will be treated;
• Occupants of specific rooms or areas that are affected should be notified of the
ACBM present, and others need not be notified of this presence;
• The letter should be "personal", rather than bureaucratic;
• One teacher said that he would like to see a very detailed letter, where "the first
page would be a very personal letter, without all the nuts and bolts, and legal stuff,
from the principal, saying there are some concerns and we are taking care of them.
The second two pages would be the technical" report;
• Notifications should be written in the first person rather than the third person;
and
• The letter should be sent home on vividly colored paper in order to show its
importance and make it memorable.
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When asked about the value of including specific elements in the letter, the group
responded in the following ways:
• Name of a designated person. Eight people thought that the name of the
AHERA designated person should be included in the notification. This was
important because this is "the person that if you have further concerns you call
them."
• Designated person's telephone number. Eight people also thought that the
AHERA designated person's telephone number should be included in future
letters.
• Description of the law. Four people thought that a brief or very brief
description of the law should be included.
. • Name of the inspection company. Five participants thought that the name of
the inspecting company was important and should be included in notifications.
Another said that the company's history including its insurance and bonding
status was also important. Expressing a different perspective however, one
teacher said, The statement that they are EPA-accredited is sufficient for me."
• Definition of key terms. Nine people thought that key terms including friability
and EPA should be defined for a parental audience.
• Location of asbestos-containing building materials. None of the participants
thought that the notification letter should include the location and condition of
ACBM.
• Response actions planned. Six people thought that a description of the
response actions planned should be included. All of these people thought that a
time frame for these response actions should also be included.
• Health risks of asbestos. Three people thought that a "simple and brief
description of the health risks of asbestos should be included in the
notifications.
Additional concern was expressed in this group that the notification should be school
based rather than district-based. This group also thought that the principal or someone at the
school should be responsible for signing the letter, rather than someone at the district level.
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Method of Distribution;
All present recommended strongly that notifications should be mailed to parents
directly, in a separate envelope. Alternatively, postcards with the notification information might
be sent. "You know when you get a letter in the mail it's important."
Only as a much less desirable alternative, delivery by a child might be considered
adequate. In the abstract, notification through a school newsletter was thought to be acceptable,
particularly if no asbestos was found. The Appletree example, distributed to the group as an
example of a newsletter notification, was generally considered to be inadequately informative if
the school had found asbestos, however. Notification in a PTA meeting was considered
inadequate and undesirable as "onty seven people would be informed" and notification through a
bulletin board was pronounced useless as "no one reads them".
Special concern was raised about the ability of foreign parents to understand a
notification. Moreover, in a local English for Speakers of Other Language (ESOL) program, 14
different languages were spoken. "If it is not written simpfy enough for the child to translate for the
parents, many parents will not be notified."
In conclusion, the group was divided between those who felt confidence in their school
districts and therefore did not feel the need for much detail or precision in their notifications, and
the overwhelming majority of those who preferred the South Community example for its warm
tone and moderate informational content.
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FOCUS GROUP
New Orleans, Louisiana
Date: July 31,1990
Attending: Five parents and five teachers, four of whom were also parents of school age
children, attended the group. All of the participants were women. All but three of
the participants were associated with public schools. One teacher who was also a
parent was associated with a private school and two parents, one of whom was also
a teacher, were associated with Catholic schools in the New Orleans, Louisiana
area.
Previous Knowledge of Asbestos
The teachers in this group were much more knowledgeable than the parents about the
asbestos status of their school. Four of the teachers were able to describe in some detail the types
of response actions that had been taken to remediate their school's asbestos. By contrast only two
of the parents were knowledgeable about asbestos in their schools.
Most of these knowledgeable persons had obtained their knowledge prior to AHERA,
however, and only the same handful of parents and teachers in Catholic schools recalled being
notified in a formal AHERA notification. None of the parents or teachers associated with public
schools had been notified by their school under AHERA. As two public school teachers said,
"Public schools were not that open with parents or teachers. In fact I finally cornered the
principal and said, What is that little box [air monitoring device] in our room?'... No
letters were ever sent out to parents, nothing was ever said."
They don't always tell the faculty, never mind the parents."
The notifications that did occur were in Catholic schools. These notifications were by
letter to both parents and teachers, though only parents and teachers in schools where asbestos
was found were notified, according to one teacher in a Catholic school whose school did not have
asbestos and who had not been notified. One parent of children in a Catholic school said about
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the notification sent out by the Diocese, 7 think a lot of parents were glad that they were aware what
was going on" as a result of notification.
One teacher said that she remembered something "vaguely" about a Management Plan
being written for her school, but she did not know what it contained, or that it was supposed to be
available to parents and teachers. The other participants had no knowledge about a Management
Plan in their school.
Examples
Three examples of notification letters were distributed to the group for their reaction.
Each letter presented a different degree of information about asbestos inspection, location of
ACBM, and designated person information. Examples of these letters are in attachment D-l.
The West Township example was not favorably received by the participants.
Discussion from the first focussed on what was missing from the notification.
"It says a Management Plan is available but it doesn't say that anything is necessarily
going to be done, and it doesn 't say "Yes, they found something or they didn 't, and if they
did, what are they going to do?' You know nothing."
"I would want to know more as a parent, and as a teacher I would want to know more."
"They've taken the time to send us a note, tell us more."
Reaction to the notification was in some cases even more negative with responses
such as,
"This smacks of some kind of a cover-up."
"They are hoping that 99% of people don't read it."
One parent suggested that, "In addition to this [notification] something should have
been attached from the individual school"
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When asked if they would call for more information after receiving the West
Township notification, all of the participants said that they would call. Many, however, said that
they would call their school's principal rather than the AHERA designated person listed in the
notification. The primary reason for calling the principal rather than the listed AHERA
designated person was that the designated person was thought to be less accessible than a
principal.
Reaction to the South Community example was more positive than to the West
Township example, but still far from completely positive.
7 think this tells you more, but I still think I'd call the principal and say 'What is the
condition in our school?'"
"I thought the first letter didn 't say enough, but this one; I think it says a little too much...
I was happy to see this one [West Township example] they were going to remove it, [the
asbestos] but in this one [South Community example] they went into too much detail
and the last paragraph would probably scare a lot of parents."
Indeed, considerable concern was expressed in this group about the last paragraph of
this example. This paragraph reads,
The overwhelming majority of asbestos-containing building materials in areas used by
students and teachers were found to be nonfriable and in good condition. Any friable
asbestos-containing building materials will be scheduled for repair, removal or
maintenance as outlined in the Operations and Maintenance Program. Measures will
be taken to prevent damage and disturbance of this material. Thus, as long as
asbestos-containing materials remain in good condition and undisturbed, their
presence does not pose a health threat to building occupants. We will closely monitor
the condition of the asbestos-containing building materials until their ultimate
removal."
Some participants singled out every sentence in this paragraph as "the troublesome
one." Some thought too much was said about the planned response action, while several others
said that the sentence that begins "Measures will be taken to prevent damage ..." needed more
clarification. Others objected to the last two sentences. In these cases the idea of the asbestos-
containing building material becoming damaged during the school year seemed to be so upsetting
that the entire paragraph was rejected. "That sounds like if you bump on the ceiling in one room you
are disturbing it [the asbestos-containing building material] in another room."
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One teacher, however, said that she wanted to play the devil's advocate and stated,
"If you think about the actual logistics of a project of this nature the fact that they have...
gone to every school and monitored and they already determined which schools need to be
helped... [The last few sentences show] they are taking responsibility by admitting the
problem exists and that they are monitoring it..."
By the end of her monologue on the topic, however, she had become noticeably more negative
about the contents of the example letter and the value of the last two sentences in the final
paragraph. She finished her statements by saying: V would not just accept the contents of this letter,
I'd trot down and review that Management Plan."
One teacher, however, had a quite different perspective, and thought that the South
Community example was a fine example of a notification.
'It would satisfy me considering the size of Orleans Parish ... This would be more than
they've said in a long time. Usually they give out vague information, two or three lines,
and beat around the bush. This is straight to the point. I would be satisfied with this
letter; I wouldn 't even calL"
A topic that came up in this group which was not a major topic of discussion in any of
the other groups was the difference in the type of notification that a parent should and would want
to receive and the type that a teacher should and would want to receive. Several people thought
that teachers should and would want to receive a more detailed notification than parents, while
one teacher who was also a parent thought that parents should receive a more detailed
notification. There was considerable discussion among the teachers who were also parents about
what their reactions to the South Community example would be as a parent versus their reactions
as a teacher.
7 think that most parents would accept this letter... this would satisfy them, [though it
would not satisfy me as a teacher.]"
"As an ignorant, innocent parent this would be very acceptable. As a teacher who is right
there, of course I have problems"'with this level of notification.
When asked if they would place a call to someone associated with the school about
this letter, half of the participants said that they would call. This was divided between parents and
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teachers. When questioned about what they would ask about when they called, the participants
said they would ask what rooms had asbestos-containing material and what the response plans
were.
The North Community example was also not well received. Comments focused both
on the poor writing style used in the notification and on the contents of the letter.
"This is a horrible letter and the $15 [charge for photocopying the Management Plan] is
the least of my concern."
"If anybody takes a look at it [the list of asbestos-containing materials] they are going to
panic."
About half of the group expressed the opinion that this letter would be more
appropriate for teachers than parents, though one parent strongly disagreed, indicating that
parents should be as fully informed as teachers.
The primary points of concern with the North Community example were:
• The $15 charge for photocopying the Management Plan.
• The statement "If you discover any damaged ACM, immediately report it to a
teacher, principal, or supervisor" was thought to indicate that the school had not
performed a thorough inspection, and that as a result hazardous materials had
gone undetected.
• The overly complete listing of asbestos-containing materials presented.
One teacher suggested that instead of listing all of the asbestos-containing materials
in the school, a notification letter should only state the following:
Step one should read: "The majority of ACM is found in the attic, and boiler room, and
a couple of classrooms were affected. Step two is what we are going to do... [Step three
is] if you have any questions call this number. Period."
Other participants did not respond to this suggestion with any great degree of enthusiasm, but by
this time in the group the tone had become so distrustful of school motives that no letter would
have been widely accepted.
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When asked if they would call the school after receiving this letter six parents, some of
whom were also teachers, said they would call as parents, while no teachers said they would call as
teachers. One activist parent who said she would not call explained this by saying, 7 wouldn't call
because I would be there. I wouldn 't take the time to calL"
One participant summed up her reaction to this letter by saying,
"If they are going to do this kind of foolishness, and send me out this kind of a long letter
then they are also going to have to send me a schedule of repair" and remediation.
In other words, "If the school is going to send out more information than I want, they are going to
have to give me all of the information to make me not panic."
Comparison between Examples
While most participants' reaction to all three notifications was negative during the
initial discussion, when asked to compare the three notifications, the group as a whole agreed that
the South Community example struck the best balance between giving too much and too little
information.
"The second one is more to the point and its not too wordy. [The North Community
example] is too wordy."
The West Township example was "an insult to my intelligence" while the North
Community example "was absurd."
Most particularly, almost all of the participants concluded that a listing of asbestos-containing
materials was not a desirable element of a notification.
Discussion about the differing needs of parents and teachers came up again, with
about the same number of people thinking parents should receive the South Community example
and teachers should receive the North Community example, and those who thought that the South
Community example was adequate for all notifications.
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Outline for Future Notifications
When asked what items should be included in a notification, the following items were
mentioned:
• Location of asbestos-containing materials;
• Plan of action to respond to the asbestos;
• Explanation as to whether children in certain classrooms are "protected" from
asbestos risks; and
• Statement that further information will be sent out through out the year as the
situation develops.
One teacher who is also a parent suggested that the EPA have a standard letter
similar to the South Community example for use by all schools. The letter would contain points 1,
2 and 3 from the South Community notification: the definition of friability, a description of
sampling methods, and an explanation of the development of a Management Plan. It would also
contain new points 4, 5, and 6 which would be school specific. These points would include whether
asbestos-containing building material was found in the school, that it presents no danger to users
of the building, and that a specific type of response would be undertaken during a specific time
frame.
When asked about the desirability of including specific elements in the letter, the
group responded in the following ways:
• Name of a designated person. Eight participants thought that the name of the
AHERA designated person should be included in the letter. Several people
suggested that it would be helpful to have the names of two people listed, "in
case you can't get through to the first one. Two people should be knowledgeable
enough to answer all your questions." The participants who did not think this
person's name should be listed explained that it was because "I'm jaded, I just
don't think you will ever get this person on the phone," and that thus there was no
reason to include their name in the notification. This person also said that
most people would probably go to the principal, who was "somebody I knew,"
someone who was accessible, and who knew the physical layout of the school
building.
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Designated person's telephone number. Eight of the participants thought that
the telephone number of the AHERA designated person should be included in
the notification.
Description of the law. Nine participants thought that a very brief description
of the law would be helpful. The one person who did not think that this would
be useful said that "all that friable and non friable stuff [would not be read]. I'm
a science teacher and I didn't even want to read about friable and non-friable.
Ordinary, everyday parents aren't interested."
Name of the inspection company. None of the participants thought that the
name of the inspection company should be included in the notification. Two,
however, said that a brief statement that the inspection company was accredited
or approved by the EPA would be helpful.
Definition of key terms. Only three participants thought that a definition of key
terms such as friability should be included in the notification. Some of the
people who said they did not think this should be included in a notification said
that this definition "made them nervous," and using this word runs the risk of
letting less educated parents think that their children will be "fried." Others,
however, said that a definition of key words increased parental confidence that
the school was not "hiding" anything.
Location of asbestos-containing building materials. None of the parents
thought that a description of the locations of asbestos-containing building
materials should be presented in the letter. When asked about the seeming
inconsistency between the parents eagerness to know where asbestos was in the
school, and their unwillingness to have it printed in the notification letter, the
following comment arose: "There is a difference between 'wanting to know where
[ACBM is in the school]' and going and sending out a letter that's going to have
400 parents stampeding into the principal's office... To me it's almost irresponsible
to send out a letter that almost incites people to worry."
Response actions planned. All of the participants thought that a general
description of the planned responses should be included in notifications. "The
parents have to be assured that their school is on top of the situation. So two or
three concisely worded sentences that indicate that we are not just going to leave
the Plan sitting on a shelf are necessary.
Health risks of asbestos. None of the participants thought that the health risks
of asbestos should be outlined in any detail in the notification. Two, however,
thought that a very brief description should be included.
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Method of Distribution
The best method of distribution for notifications was felt by most to be by mail. 7
don't think that this type of letter should be pinned onto tdndergartners, this kind of letter should be
signed, sealed and delivered to parents."
There was general agreement that children, particularly middle school and above,
don't deliver notices/papers to parents, and that notifications simply would not arrive unless they
were mailed. Several parents' schools mailed out a monthly newsletter, and these parents thought
that a copy of the notification letter should be stapled into the newsletter, as a foolproof and
inexpensive route of delivery. These parents did not, however, think that including the notification
in the Appletree example newsletter text was adequate.
Notifications posted on a school bulletin board would not be read, according to this
group, and not enough parents attend PTA meetings to make this an adequate method of
notification.
All of these non-mail methods of dissemination, with the possible exception of posting
a notification on a bulletin board, were thought to be "a nice followup, but should not be the only
method" of notification.
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Attachment D-l
SAMPLE NOTIFICATION LETTERS
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WEST TOWNSHIP PUBLIC SCHOOLS
West A Street
West Township, CA 91005
OFFICE OF THE SUPERINTENDENT
~ob Smith
Superintendent
7eL 818-555-1111
LETTER OF NOTIFICATION
TO: PARENTS AND STAFF
OF THE WEST TOWNSHIP SCHOOL DISTRICT
FROM: Bob Smith, Superintendent of Schools
DATE: June 30, 1989
Pursuant to the Asbestos Hazard Emergency Response Act (40
C.F.R. Part 763) all primary and secondary schools were required
to be inspected for asbestos-containing building materials.
Based on the results of the inspection, a management plan was
prepared assessing each area and the condition of each.
This is to advise you that the West Township School District
has complied with the legislation and has a management plan
available for review in the central office of each school.
If there are any questions, they should be directed to the
Asbestos Program Manager, Charles Brown, Facilities Supervisor at
555-1112.
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SOUTH COMMUNITY UNIFIED SCHOOL DISTRICT
SOUTH B AVENUE, South Community, NJ 61105 . (011) 999-1111
Office of
Associate Superintendent
Management and Administrative Services
Jill Jones
October 14,1989
Dear Parents and Staff:
In compliance with the U.S. Environmental Protection Agency regulation [40 CFR Part 763.93(e) (10)],
"Asbestos-Containing Materials in Schools; Final Rule and Notice", the South Community Unified School
District has completed the following requirements:
1. All facilities were inspected for both friable and non-friable asbestos-containing building materials.
Friable is defined as easily crumbled or pulverized by hand.
2.
4
Samples were taken during the inspections of all materials suspected of containing asbestos, and
samples were analyzed at an EPA-accredited laboratory.
3. The District has developed Management Plans which include measures to prevent release of
asbestos fibers and to abate asbestos-containing building materials. These Management Plans also
provide the locations and condition of the asbestos-containing materials. A copy of each school's
Management Plan is located in the school office and is available for your review.
The overwhelming majority of asbestos-containing building materials in areas used by students and
teachers were found to be nonfriable and in good condition. Any friable asbestos-containing building
materials will be scheduled for repair, removal, or maintenance as outlined in the Operations and
Maintenance Program. Measures will be taken to prevent damage and disturbance of this material. Thus,
as long as asbestos-containing building materials remain in good condition and undisturbed, their presence
does not pose a health threat to building occupants. We will closely monitor the condition of the asbestos-
containing building materials until their ultimate removal.
Sincerely,
Jill Jones
Asbestos Coordinator
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PARK AVENUE
NORTH COMMUNITY NORTH COMMUNITY, GA sooso
PHONE: (555) 555-1212
SCHOOL DISTRICT
Dr. Morris Sparrow.—Superintendent
April 26, 1989'
Dear Parents and Staff:
The purpose of this notice is to inform you about steps being taken to
eliminate the risk and to insure the safety of students and staff at North
Senior High School with regard to asbestos containing material (ACM). The
practices and procedures we are following were established by legislation
known as the Asbestos Hazard Emergency Response Act (AHERA).
The first step in compliance with AHERA was an Asbestos Assessment and
Inventory Study in all North Community School District buildings. This
study found some ACM in North Senior High School.
The second step in AHERA is the development and implementation of an
asbestos management plan. The "Plan" outlines all operations and
maintenance activities used to control asbestos found in our buildings.
Management Plans for the schools in North Community School District will til
completed and submitted to the Department of Education for approval by May
1, 1989, and will be available for your review in each school's office.
You may obtain a personal copy of North Senior High School's asbestos
management plan by submitting a written request or by "in person" contact
with Richard Black, telephone number 222-4444. A reasonable "copy charge"
of $15.00 must be paid with your request. Mr. Black is the person
designated to carry out the North Community School District's
responsibilities under E.P.A. Final Rule and Notice CFR Part 763, Section
763.84 and 763.92.
A fully certified environmental service company was engaged to (a) conduct
the asbestos assessment and inventory study, (b) to develop the asbestos
management plan, and (c) to train our maintenance employees in the removal
and/or emergency repair of ACM commonly found in public buildings. These
services have been completed and the school district is reviewing the
asbestos management plan. This company will continue to conduct asbestos
inspection activities in the school building at least once every six (6)
months.
The following list summarizes the type and location of ACM in the North
Senior High School building. Floor tile was assumed to contain asbestos.
(Floor tile poses no health problem if the material is not ground, chipped,
abraded, etc.) Friable ACM can be crumbled easily by hand pressure.
Asbestos fibers are released into the air whenever friable ACM is
disturbed. If you discover any damaged ACM, immediately report it to a
teacher, principal or supervisor.
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d handling or disturbing the ACM at the following locations:
:YPE*
LOCATION
-YPE*
.OCATION
-YPE*
JDCATION
TYPE*
LOCATION
TYPE*
LOCATION
TYPE*
LOCATION
TYPE*
LOCATION
.TION
TYPE*
LOCATION
TYPE*
LOCATION
TYPE*
LOCATION
Fitting Insulation (TSIACM)
Guidance Area Conference Room
Ceiling Tile (SACM)
Maintenance Shop Storage Room
Pipe '& Fitting Insulation (TSIACM)
Maintenance Shop Area
Boiler Breeching, Pipe & Fitting Insulation (TSIACM)
Friable
Small Boiler Room (1925 Annex)
Wall Plaster (SACM)
Stairway to Small Boiler Room
Floor Tile (MACM)
Room 108
Pipe Insulation (TSIACM) - Friable
1925 Annex Attic
Shingle Roof (MACM)
1925 Annex Attic
Transite Workbench Tops (MACM)
Industrial Technology Shop
Boiler, Pipe & Fitting Insulation (TSIACM) - friable
Large Boiler Room (1962 Addition)
Ceiling Plaster (SACM)
Room 128 (First Floor)
All of the friable materials presented above will be scheduled for repair,
removal or ongoing maintenance. Our goal is to ensure the health and
safety of all North Senior High School occupants.
Sincerely,
Dr. Morris Sparrow
Superintendent
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APPLETREE ELEMENTARY
SCHOOL NEWS
September 13, 1990 Dr. Edgar Plummett, Principal
PRINCIPAL'S ADDRESS
To all parents and staff of
Appletree Elementary School,
greetings 1 As we begin the new
school year, I want to welcome you
back and hope you had a relaxing
summer. For parents of new
students and new staff, welcome!
At Appletree Elementary our
goal is to provide a stimulating
and enriching environment where
each student's potential can be
realized. We pride ourselves in
bringing quality education to
students for over 20 years, and we
look forward to another rewarding
school year ahead.
NEW COMPUTER FACILITY
This year we have many
challenges ahead, as one goal for
the new year is to introduce to
students and staff our newly
developed computer facility, thanks
to the donation of four ZERON 249
computers from EEE Technologies. A
special thanks goes to Mrs. Irene
B. Maxwell for her initiative in
contacting Mr. Cartell, President
of EEE Technologies. Thanks,
IreneI
SCHOOL LUNCH MENU FOR WEEK
OF 9/17
Monday - grilled cheese sandwich,
green beans, apple
Tuesday - fish sandwich, french
fries, cole slaw, peanut butter
cookie
Wednesday - tomato soup,
frankfurter on roll, orange slices
Thursday - hamburger, peas and
carrots, apple pie
Friday - chicken tenders, corn,
brownie
ROOM MOTHERS WANTED!!!
We need volunteers to help oH
in the classrooms at least one day
a week for the Kindergarten, 1st
and 2nd grades. If you would like
to volunteer, please call Ms.
Schmeel at 555-1212 between 9:00 AM
and 2:00 PM.
ASBESTOS REPORT
The AHERA (Asbestos Hazard
Emergency Response Act) Inspection
Report for Appletree Elementary
School is available in the office
of the principal. If you would like
to see the report, please call the
office to make an appointment. The
report will be available throughout
the school year.
SCHOOL CLOSING DATES
The school will be closed on
Sept. 23 for staff development day.
Please mark this down on your
calendar.
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PEER REVIEW DRAFT
APPENDIX E
MAINTENANCE AND CUSTODIAL WORKERS
FOCUS GROUPS
DISCUSSION GUIDE AND FINDINGS
Part 1: Discussion Guide
Part 2: Findings
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Appendix E presents the discussion guide and findings of the maintenance and
custodial workers focus groups held for the AHERA evaluation. These groups were conducted
with maintenance personnel (school staff responsible for small and moderately sized repairs to the
schools' mechanical, plumbing and other systems) and custodians (school staff primarily
responsible for janitorial and cleaning duties at schools). Focus groups were held in five locations
nationwide.
Parti
A discussion guide presents a starting point for group discussions and is not a formal
questionnaire. Unlike a questionnaire which must be administered in the same exact manner each
time it is used, a discussion guide provides topics for the moderator to discuss using whatever
phraseology he/she is comfortable with in the context of the ongoing discussion.
The following presents the discussion guide that was used during the maintenance and
custodial workers focus groups.
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July 1990
FOCUS GROUP GUIDE FOR MAINTENANCE AND CUSTODIAL WORKERS
Introduction
• Introduce the concept of focus groups, the Asbestos Hazard Emergency Response Act
(AHERA), and the AHERA evaluation.
• First, I'd like to say that everything you say during this discussion will be held
confidential. Following standard focus group procedures, this session is being taped
to make it easier for me to write a report. Also, following standard focus group
procedures there are observers behind the mirror. The mirror is there just so the
observers don't interfere with our discussion.
• Reassure participants that what is said in the discussion will be kept confidential, and that
none of the examples given during the discussion pertain to the individual schools with
which the participants are associated.
• What is your first name and what kinds of jobs are you responsible for?
(Remind them not to mention school name.)
Asbestos in Schools - Early
• When did you find out that there was asbestos in your school?
• How did you first find out that there is asbestos in your school?
• Did you know specific locations of the asbestos?
• Did you do anything different working around the asbestos back then?
Asbestos in Schools - Recent
• From this point in our discussion, I'd like you to talk only about your experiences in
the last 24 months.
Q • Have you been informed that there is asbestos in your school in the last 24 months or
so?
(Probe for written, oral, awareness training, mention of Management Plan, warning
labels).
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For notifications
What was in these notifications?
(Probe for locations ofACBM in school, mention of Management Plan.)
Was there any reaction to these notifications?
Based on what was told to you in the last 24 months, do you know where the asbestos
is in your school?
(Ask for a show of hands.)
How did you find out where the asbestos is?
(Probe for written, oral, awareness training, mention of Management Plan, warning
labels.)
If you're not sure where the asbestos is, do you know how to find out?
(Probe for Management Plan.)
Describe Management Plan. Do you know if your school has a Management Plan?
(Ask for a show of hands for those who answer yes.)
Do you know where the Management Plan is located?
(Probe for availability, access to updated version, also if workers are on night shift,
can they get to it.)
Have you ever looked up something in it?
How easy was it for you to understand?
Have you ever looked for something and not found it?
Did you get any training or instruction on how to use the Management Plan?
What kind?
If you have a question about something in the Management Plan, who can you
go to for help?
(Ask about second language, if applicable.)
Does your school have an Operations and Maintenance plan, that is, written steps to
follow in working around asbestos?
Have you ever read it?
Is it easy to use?
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Training
• Within the last 24 months/those last 2 years, what types of training about asbestos
have you received?
(Probe for school sponsored or union sponsored.)
When did you first get training?
Q - How many hours did the training last?
(Probe for 2-hour, 2-day training. Repeat by name, length of training for each.)
Q - What kinds of materials were used during this training?
(Probe for written, video.)
If video,
Q - Was someone with you during the video to answer any questions you had?
(Ask for show of hands for those who saw video.)
Q - What kind of information was in the video?
(Probe for health effects how to recognize asbestos, equipment used in asbestos
work, and how to use a respirator.)
As part of this training, did someone explain to you where the asbestos in your
school was?
Did someone walk through your school with you to show you where the
asbestos was?
Did someone show you examples of asbestos?
Were you shown different kinds of equipment to be used around asbestos?
Did someone show you how to put on/use a respirator?
During training, did anyone show you how to do cleaning or repairs any
different than the way you had been doing them?
Do you think the training covered all you need to know about working around
or handling asbestos on the job?
What other information do you think would have been helpful during the
training?
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Asbestos Related Work
• Explain that for this part of the discussion some questions may seem directed to
maintenance, some to custodial If a custodian does what the maintenance workers are
asked, and vice versa, say so, but all may respond. Emphasize this is during the past 24
months.
Ceiling area
Q • Have you ever been asked to clean up after a roof leak has damaged asbestos?
(Probe for how they know this was asbestos:
If asbestos, probe for procedures, special equipment, wet, HEP A vac, protective
clothing, respirator, have any procedures changed in last 24 months?;
If unknown, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If not asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
Or it hasn 't happened.)
Q • Have you been asked in the last 24 months to do work above a ceiling (tiles) where
there is asbestos?
(Probe for how they know this was asbestos:
If asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If unknown, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If not asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
Or it hasn't happened.)
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Boiler Room
Have you ever been asked to clean up in a boiler room where there is asbestos?
(Probe for how they know this was asbestos.'
If asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If unknown, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If not asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator, have any procedures changed in last 24 months?;
Or it hasn 't happened.)
Pipe Insulation
Have you ever worked in a location where a pipe that is insulated with asbestos has
leaked, damaging an area about this big (show with hands) and you were asked to
repair the damage or clean the area? (Show once area smaller than 3 feet, once area
larger than 3 feet).
(Probe for how they know this was asbestos:
If asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If unknown, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If not asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
Or it hasn't happened.)
What other kinds of jobs are you expected to perform around material that has
asbestos?
(Probe for how they know this was asbestos:
If asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If unknown, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator; have any procedures changed in last 24 months?;
If not asbestos, probe for procedures, special equipment, wet, HEPA vac, protective
clothing, respirator, have any procedures changed in last 24 months?;
Or it hasn't happened.)
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Have you removed asbestos in the past 24 months, or cleaned up after asbestos was
removed?
Did you receive any special instructions before doing this removal?
Did you use special equipment to do this?
(Probe for protective clothing, respirator.)
If respirators have been used by any participants, probe for which of 3 lands of masks
(dust, negative pressure, PAPR) were used.
When were you given your respirator, and how did they test to see if it fit?
Are you the only person who uses a respirator, or do you share it with others?
Were you given a choice of which kind of respirator or mask to use?
Have you been given a medical exam through your job since you were issued a
respirator?
Have any other job duties, or the way you perform them, changed in the last 24
months or since your school was inspected under AHERA? (Buffingpads)
What kinds of jobs are you spending more time doing?
What kinds of jobs are you spending less time doing? (Probe for AHERA jobs
that take longer.)
What techniques or procedures have changed in the past 24 months?
Some schools have special staff that are called in to do some asbestos related work in
the school or school district. Is this one way asbestos work is done at your school?
Under what circumstances are these asbestos specialists called in?
Can you ask to have these specialists come to your school?
Have you ever asked to have a specialist come to your school? (Ask for show of
hands.)
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Thanks and Conclusion
Thank you for agreeing to participate in this group. As we said, any examples we have
used do not relate to the schools where you work. Anything you have told us is
confidential, and when we write a report, your names will not be used.
Goodbye.
If participants express concern about health or safety, or have questions about procedures on the job,
refer them to the person in charge of asbestos in their school
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Part II
The following section presents the findings of the focus group discussions held with
maintenance and custodial workers in five locations nationwide. Each focus group posed
questions to public school and private school maintenance and custodial staff. The primary topic
of discussion was abestos awareness and asbestos-related activities during the past 24 months and
the personal experiences of the participants. Opinions about the appropriateness of work
practices and training expressed throughout this section reflect participant beliefs rather than EPA
or Westat judgments.
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MAINTENANCE AND CUSTODIAL WORKERS FOCUS GROUP
St. Louis, Missouri
Date: July 9,1990
Attending: Eight people consisting of two maintenance workers for private schools, three
maintenance workers for public schools, one custodian for a private school, and
two custodians for public schools in the St. Louis, Missouri area.
Job Responsibilities
The job responsibilities of the maintenance workers who participated in this focus
group involved plumbing, heating, air conditioning maintenance and repair, floor tile removal,
roofing repair and removal, and purchasing parts. The custodians were responsible for general
cleanup and also assisted in emergency cleanup when a roof leak occurred or a pipe burst.
Initial Awareness of Asbestos
Three maintenance workers from public schools and one from a private school were
first aware of asbestos in their schools approximately 10 years ago. At that time they had no
awareness of any danger associated with the material and did not follow any special procedures
while working around or repairing ACBM. The other participants were not aware of asbestos
being in their schools until within the last two years.
Recent Awareness of Asbestos
All participants have become aware of, or have been made more aware of, the
existence of asbestos in their schools within the past two years.
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In no case was a notification sent or given to any of the participants. Most of the
maintenance workers acquired a heightened awareness of asbestos when they were told to attend
training sessions held in response to AHERA or, as one maintenance worker said, "usually we
pointed it out to them [custodians]." The other maintenance workers became more aware of the
ACBM when told that a private company had tested for ACBM. In one case, a maintenance
worker saw paperwork about an asbestos inspection on his supervisor's desk and asked about it.
The maintenance workers know where the asbestos is located, based in large part on
what they were told by a supervisor or by other knowledgeable individuals (such as inspectors or
outside consultants). The custodians had been made aware of asbestos through training, but could
only speculate about the exact locations of ACBM. In some cases, knowledge about the location of
ACBM was based on what other (not particularly well informed) school workers had said.
The subject of the Management Plan came up during the discussion. All maintenance
workers were aware of the Management Plan and had access to it. One had his own copy. Only
one custodian had some awareness of the Management Plan. About half of the maintenance
workers had read the Plan. They found it difficult to read and understand, but said it could be
done, "You "ve got to be a lawyer or engineer. I don't think it'd be easy for anyone. You 'd almost have
to be a professor." Two people had used the Plan to determine whether or not a material contained
asbestos. Two maintenance workers stated that they used building blueprints to determine
whether the specifications called for ACBM, and that was their basis for determining whether or
not a material contained asbestos.
If they needed help in understanding the Plan, about half the maintenance staff would
go to their supervisor and, if no assistance was available, would contact the company that wrote the
Plan. The others felt that it would be necessary to go to the company initially, since they were the
only ones who could really be trusted.
There was no awareness of an Operations and Maintenance (O&M) Plan specific to
any individual school. Most maintenance workers were aware of having general procedures given
to them during training. "We have no set procedures" for cleanup. One custodian thought there was
an O&M Plan, but he had not seen it.
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Training
All participants, with the exception of one private school maintenance worker, had
received asbestos training. Hah7 the participants received training before the school was inspected
for asbestos, half after. The maintenance workers attended two or three-day classes which
included movies and film strips on asbestos awareness and health effects, examples of ACBM, and
hands-on training in glove bag removal procedures. Additionally, these workers received another
training session on cleaning and removal procedures.
The custodians all remembered a movie, with someone available to answer questions.
This awareness training was either a two- or four-hour course. There was scant recollection as to
the content of the training, other than it had a lot of big words and that asbestos was in hair dryers
and other common appliances.
Part of the training for three maintenance workers included information on negative
pressure respirator use. The only fit testing that occurred involved positive and negative pressure
testing (holding your hands over the canisters to create a vacuum).
The maintenance workers felt their general asbestos training was quite
comprehensive. One person said, "I know enough not to handle it." The custodians, however,
clearly did not feel they knew enough about asbestos and expressed a concern that no one really
cared about them and their exposure to ACBM.
Asbestos-Related Work
A series of questions about work experiences around asbestos were posed to all
participants. The first question dealt with cleaning up after a roof leak had damaged asbestos.
The custodians had cleaned up after roof leaks but were not sure that asbestos was involved. No
special cleaning procedures were followed. One maintenance worker said he had cleaned up a
roof leak following glove bag procedures. At best these procedures must have been modified as
glove bags are usually intended for use on pipes.
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The second question involved working above ceiling tiles where asbestos was located.
Most custodians had worked above ceiling tiles or with tiles that contained asbestos. No special
procedures were followed. Most situations were viewed as emergencies and there was no time to
follow special procedures. In one case, since the ceiling tile was "not friable," no need was seen to
follow any special procedures.
Question Three dealt with cleaning in a boiler room where asbestos was located. Two
maintenance workers, both from public schools, followed special procedures (suits, respirators, and
disposal) to clean up problem areas in the boiler room. No one else in the group had been
involved in this type of cleaning.
The fourth question dealt with working in a location where a pipe insulated with
asbestos had leaked, damaging less than three linear feet of insulation. One situation experienced
and described by two public school maintenance workers (who work in different schools) was that
an asbestos crew happened to be in the school and was asked to remove the damaged asbestos and
they did so, following reportedly appropriate procedures. However, in the process, other ACBM
was damaged and was left without being cleaned up. Maintenance staff at the public schools
followed special procedures for handling ACBM when dealing with water damaged asbestos both
less than and greater than three linear feet. One private school maintenance worker has repaired
insulation in a similar circumstance, not following any special procedures. There have been no
circumstances where the participants have cleaned up around ACBM with greater than three
linear feet of damage.
If problems occur during the middle of the night, the public school staff simply do the
job, without using special procedures or equipment.
"They call you in, you don't know what you're getting into, [or] how to prepare for it,... "
"It's time when you have an emergency and don't give it a second thought."
"It's like this, one guy is trying to do the job often guys."
Other types of work around ACBM included removing floor tiles, roof tiles, and, for
custodians, sweeping in areas where they did not know for sure ACBM was present, though they
thought it possible. Four maintenance workers have removed floor tile with no special procedures
except to use a heat gun. Rags have been used to wipe up after removal and are then re-used. In
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one instance, when a large area of tile was being removed, the custodian who was assisting in the
removal called OSHA for guidance. OSHA, however, claimed no authority. The school hired an
outside contractor who used masks, or perhaps respirators, but did not seal off the area.
Respirator Availability
Training on use and fit (positive and negative pressure testing) was given during the
required AHERA courses to all maintenance workers, except for the one private school worker
who has not had any training. Three of the five maintenance workers have negative pressure
respirators. The two public school workers obtained school funds and purchased the respirators
and canisters themselves. The private school worker has one available through his school. Ail of
these respirators are available for anyone to use. One private school worker was told by his school
to obtain a medical exam as a result of training, and this person does not have a respirator.
No custodians have access to a respirator.
Other
There has been no change in job responsibility during the past two years. The only
change in equipment or techniques of ACBM management include using glove bags around
asbestos, and that only in the public schools.
All but one school represented use outside contractors to perform large asbestos jobs.
The one who does not has only a small amount of ACBM in the school.
Conclusions
All workers, both maintenance and custodial, have been made aware of asbestos and
the maintenance workers appear, with one exception, to have received the required level of
AHERA training for their job responsibilities. However, the custodial staff have received only a
basic awareness training. By their own reporting, they do disturb ACBM and therefore their level
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of training does not meet AHERA requirements. The maintenance staff are aware of where
asbestos is, though custodial staff are less sure and less knowledgeable about how to find out
whether a material is ACBM. Again, maintenance staff are aware of a Management Plan and
have access to it. This is not the case with custodians. Asbestos-related work is performed
according to appropriate procedures more in the public than private schools, except in the case of
maintenance emergency repair, when appropriate procedures are frequently ignored even in
public schools.
There is genuine concern on the part of support staff for their own health, though
some feel it is fait accompli that they have had significant exposure to asbestos, and probably are
continuing to be exposed. "It's my job. What are you going to do?" There is also concern for the
students in the schools. Public school staff especially expressed confusion and anger over why the
asbestos that is present is not being removed more quickly and in a more ethical manner.
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MAINTENANCE AND CUSTODIAL WORKERS FOCUS GROUP
Boston, Massachusetts
Date: July 12,1990
Participants: Three people consisting of two maintenance workers for private schools and one
maintenance/custodial worker for a private school in the Boston, Massachusetts
area.
Job Responsibilities
The job responsibilities of the maintenance workers who participated in this focus
group involved carpentry, painting, sheetrock installation, electrical work, and water treatment
plant operations. The person who was responsible for both maintenance and custodial work
performed these tasks as well as traditional custodial duties.
Initial Awareness of Asbestos
Two individuals became aware that asbestos was in their schools about ten years ago,
one through hearsay and the other because asbestos was required by state law to be part of fire
doors. The other was made aware of asbestos when he was hired two years ago.
Recent Awareness of Asbestos
Approximately two years ago, two workers were told by their supervisor that there
was asbestos in the schools. The other worker first saw a notice about required asbestos training
posted and deduced ACBM was present. In all cases a notice had been posted about a required
training film and speaker or about an upcoming asbestos inspection.
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The maintenance workers know where the asbestos is located either because they
were told by a supervisor or because materials are marked as being ACBM. In one case, the
wrapping on asbestos pipes is different from that on non-asbestos pipes, making it clear what is
ACBM. If anyone is unsure of whether a material was ACBM, they stated they could go to their
supervisor or to the Management Plan.
All participants were aware of the Management Plan, though only one worker had
gone through the Plan. He felt that, "It took a while, [but it's] not bad, when you get on to it, you can
find out."
The Management Plan was available for all maintenance workers, and the individual
who had gone through the Plan stated that an Operations and Maintenance Plan was included in
his school's Plan. "That book is therefor anybody in the maintenance department who needs it."
Training
These maintenance workers were all told that they were not expected to deal with any
materials that contained asbestos. All workers were trained during a two or four-hour training
session. These sessions included films, slides, and someone to interpret the presentation and
answer questions. The films and slides covered the history of asbestos, health issues, and where it
is most likely to be found. Two workers were shown suspect and actual locations of ACBM in their
schools, and two trainings included a segment on procedures, one of which showed examples of
asbestos. "Afteryou see this [the film]... I don't want to [work around] it."
There was, however, consensus that the training received was sufficient for the
participants'job responsibilities.
At one school, a maintenance worker related that some newly-hired
housekeeper/custodial workers had been given the same training that he had and, since they had
difficulty with English, an interpreter assisted in explaining the information.
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Asbestos-Related Work
None of the maintenance workers were expected to do any work with asbestos or in
locations where they might come into contact with ACBM. The one exception was that one person
said that his arm might brush against pipe wrap, but he was not responsible for working directly
with it. The only activity mentioned was that one individual had painted ACBM pipe insulation
with latex paint which helped seal it, but that the insulation was in excellent condition, and that
painting was being done in the area anyway.
None were responsible for removal of any ACBM. In all cases, if there was a question
about anything, the workers felt they could go to their supervisors for assistance and information.
For these reasons the questions in the discussion guide about specific ACBM related tasks were
not discussed in great detail.
Respirator Use
No one had been issued a respirator nor did they feel they needed one, given their job
responsibilities.
Other
There had been no change in jobs during the past two years.
Two of the three schools' ACBM was labeled as such.
All schools represented use outside contractors to perform any jobs which might
disturb ACBM.
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Conclusions
The private school maintenance workers represented by this focus group had been
made aware of asbestos in their schools and appear to have received the required training. Even
though they are maintenance workers, their actual job responsibilities do not involve potentially
disturbing ACBM and therefore, the short course is sufficient according to AHERA. If any have
questions about ACBM and its locations in the school, they have access to the Management Plan,
and are comfortable with bringing questions to their supervisors.
These maintenance workers believe that they were adequately trained and are
comfortable with their school's handling of any asbestos. As one person said, "It did enough, [and]
made me aware of it, [to] be careful enough to keep away from it."
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MAINTENANCE AND CUSTODIAL WORKERS FOCUS GROUP
Seattle, Washington
Date: July 23,1990
Attending: Nine people consisting of one maintenance worker for a private school, five
custodian-engineers for public schools, two custodians for private schools, and
one custodian for a public school in the Seattle, Washington area.
Job Responsibilities
The job responsibilities of the custodian-engineers, custodians with significant though
not major maintenance responsibilities, included general cleaning, repair, refrigeration, and
heating and ventilation work. Custodians were responsible for general cleanup and assisted in
emergency cleanup when needed, for instance, when a roof leaks or a pipe bursts.
Initial Awareness of Asbestos
All participants, with the exception of a private school custodian, were aware of
asbestos in their school at least eight to ten years ago, and some were aware up to 15 years ago. In
some cases this was based on bulletins posted for general information, and for others it was based
on general knowledge of asbestos learned through working with the material. One respondent
stated that 7 knew it was there, [but] I didn't know anything about it." The private school custodian
became aware of ACBM through material labeling when he was first employed at the school.
Recent Awareness of Asbestos
All participants have become more aware of the existence of ACBM in their schools
within the last few years.
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None of the participants remembered a specific notification of the existence of
ACBM within the past 24 months. The participants were, for the most part, made aware of the
presence of ACBM in their schools through the requirement that they attend an asbestos training
course. Two private school custodians were made aware of ACBM when inspectors came to
perform the AHERA inspection.
All participants believed that they knew the location of asbestos in their schools,
based on labeling in the schools, meeting with a supervisor, pre-AHERA awareness training, or in
one case having been asked to report on the condition of ACBM through review of a pre-AHERA
inspection.
A large majority of the participants knew about the existence of a Management Plan
and had easy access to it. Three custodian-engineers had used their Management Plans. 7 had no
problem using it. It's a pretty good book." One custodian-engineer said that when he went to his
current school, approximately two and a half years ago, he would not do any work until he checked
out the Management Plan.
One private school custodian had no awareness at all of a Management Plan, and one
public school custodian said he thought he had heard of it. The public school custodian-engineers
stated that they had the telephone number of the designated person and would go to that person if
there was a problem interpreting the Plan. Other participants said they would go to a supervisor
for information.
No one was aware of a written Operations and Maintenance Plan. Several individuals
stated that they had been given verbal instructions in techniques for working around ACBM.
Training
Seven of the participants received training consisting of one and one-half to two hours
of video tapes and some oral presentation within the past 24 months. One private school
custodian had taken a one-week asbestos worker course and received his certification. One
private school custodian had received no training at all.
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Information presented during training for the majority included the history of
asbestos, why it is used, and only a few comments regarding health effects. These individuals had
received pre-AHERA training which they felt was more comprehensive and useful. One person
said, "In my opinion it was way outdated It could"ve been something a little more recent." In one case
someone pointed out where ACBM was located in a specific school. In another case, They gave us
this book [Management Plan] and said, well, look it up."
No different procedures for working around ACBM were presented during the
training, with the exception of training received by the one-week course participant.
Suggestions for additional information to include in training were samples of asbestos
and more information on health concerns. However, one participant stated that 7 think they
actually tried to downplay this — so people couldn't go off on a tangent." Others expressed an interest
in knowing what kind of exposure would be expected from different types of ACBM, such as floor
tile and spray-on insulation.
There was, for the majority, a clear feeling that the training was not enough, and that
in particular more emphasis should be placed on safety procedures for the workers.
Asbestos-Related Work
A series of questions about work experiences around asbestos were posed to all
participants. The first question dealt with cleaning up after a roof leak had damaged asbestos. All
had cleaned up a roof leak situation but none knew if ACBM was present or damaged and no
special procedures were used.
The second question involved working above ceiling tiles where asbestos was located.
Several participants have worked above tiles but did not know if ACBM is present. If there is a
knowledge that ACBM is present everyone said they would not do work in that area. Other
workers are called in if ACBM is known to be present. One private school maintenance worker
does work above ceiling tiles and is not sure if there is ACBM, but he "stays away from the pipes."
No special procedures were followed in any of these cases. It was clear, however, that pre-
AHERA most public school custodian-engineers would have performed such duties.
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Question Three dealt with cleaning in a boiler room where asbestos was located. Two
participants perform cleaning in this situation. Both wet mop the area, as they have always done,
and no special procedures are followed.
The fourth question dealt with working in a location where a pipe insulated with
asbestos had leaked, damaging less than three linear feet of insulation. No one performs any work
in this kind of situation; someone else is called in. In one private school this situation occurred
recently and is awaiting action. There have been no situations in the participants' schools in which
greater than three linear feet of ACBM was damaged.
Other jobs around ACBM include working with floor tiles. Procedures for waxing and
buffing have not changed post-AHERA. Uncertainty as to the appropriateness of these
procedures is prevalent: "/ can't get an answer, they feel this won't hurt us. I have lads walking in the
hall, with sand... we only sweep the floor every two days. Does that sand hurt?" In several cases,
when vinyl asbestos floor tile (VAT) "busts loose," the tiles are simply picked up and tossed into the
trash. One private school custodian said that their VAT "tile has very little [asbestos], so we're
fortunate and don't have to worry."
Other situations include custodians dry sweeping floors next to pipes insulated with
ACBM, and a maintenance worker drilling into plaster wall with no knowledge of whether or not
the material has asbestos in it. One public school custodian changes filters in the boiler room
where piping is insulated with ACBM. No special procedures are followed in any of these cases.
None of the participants have been involved in removing asbestos or cleaning up after
asbestos was removed.
Respirator Availability
About half the participants were trained, pre-AHERA, in respirator use. This
training ranged from being shown a respirator to actual suiting up. None were fit-tested.
Respirators (with purple filters) are available for half the public school employees. They are for
anyone who wants to use one, but these participants have not done so. These respirators are
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included in "asbestos fats" which include suits, respirators, yellow warning ribbon, and a wetting
bottle. However, said one participant "have you ever tried to get supplies for those? To get them
resupplied isn't that easy in the past few years." The other participants do not have access to
respirators.
No one has been advised to obtain medical exams in support of respirator use.
Other
The only change in job responsibilities involves the public school custodian engineers
who now perform the required six-month inspections. In addition, most have been told not to
work around asbestos, and to keep an eye out for it.
About half the participants have specially trained people in their school districts to
handle asbestos problems. The others use outside consultants. All use outside consultants to deal
with major problems or school renovation.
Labeling of ACBM is very limited in the schools represented.
Conclusions
All workers appear to be aware of asbestos in their schools. Training appears to be
adequate only to the extent that most people had received significant training pre-AHERA. The
participants have been told not to work around ACBM. The exception to this is the private school
custodian who has had no training and does work around ACBM. Most are knowledgeable about
the location of ACBM, although further training on identifying ACBM would be helpful, as would
having specific locations pointed out. Management Plan awareness is high, though additional use
of the Plans would heighten knowledge of ACBM locations. Much custodial work is done without
regard to appropriate work practices, simply because the workers have not been told differently.
There is concern about health effects, though several people feel that they are
following appropriate procedures and that, since they have been told not to work around ACBM,
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this is not a significant issue. Concern about this is divided equally between custodian-engineers
and custodians. In addition, several people are aware of situations in their schools that they
believe are dangerous, such as fan areas where friable ACBM is located or buildings belonging to
their district but used by other groups, such as a pre-kindergarden, which are cleaned (as far as
they know) without any awareness of ACBM location or condition.
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MAINTENANCE AND CUSTODIAL WORKERS FOCUS GROUP
New Orleans, Louisiana
Date: July 31,1990
Attending: Five people consisting of three custodians for public schools and two maintenance
workers for private schools in the New Orleans, Louisiana area.
Job Responsibilities
The job responsibilities of the custodians consisted almost exclusively of keeping the
buildings clean and very minor maintenance work. The maintenance workers were responsible for
building equipment maintenance including heating, air conditioning/refrig-eration, and plumbing.
Initial Awareness of Asbestos
One custodian became aware of asbestos in the school during an inspection about six
years ago. Most materials were removed and what remained was labelled. There was no change in
job procedures. All other participants became aware of asbestos in their schools within the last two
years.
Recent Awareness of Asbestos
All participants were aware of asbestos in their schools.
A majority of the participants had been informed about asbestos, however, none
remembered a specific written notification about asbestos in their schools. One public school
custodian remembered a bulletin requiring all workers to attend a workshop about asbestos. One
private school maintenance worker attended a required workshop about asbestos, and he also
remembered a notice sent to parents about two years ago. The other maintenance worker was
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notified verbally by his supervisor. Two custodians had no recollection of any notification; their
knowledge of ACBM came from what other school workers had told them. One custodian said,
"During testing, guys came around, of course they never tell you whether they found it or not, but it's an
old building."
All maintenance and custodial workers believed they knew the location of asbestos in
their schools, based on what was in the Management Plan, what was labeled, or what they had been
told by a supervisor. The one exception to this was a public school custodian who said, "It would be
to use my own judgment, to say if somebody came and told us, not me."
Only one public school custodian was aware of a Management Plan. She never had
used it, but expressed clearly that she could use it if she so desired and had easy access to it, saying
"It was given to us to look at, and after we reviewed it, we gave it to the principal"
No one was aware of a printed Operations and Maintenance Plan. They felt that
there was a verbal process of information dissemination. The technique described to these
participants involved sweeping ACBM up, putting it in a bag, and throwing it away. One
maintenance worker had been told not to drill into any ACBM.
Training
Two participants received training, one custodian and one maintenance worker. The
maintenance worker attended a two to three-hour workshop that covered removal and handling
asbestos, and he suited up with a respirator. The custodian attended a one-hour mandatory
session where films were shown that discussed equipment and what asbestos looked like. The
designated person was present for the viewing of the film. In her opinion, "It was a big help." In
neither case was the location of ACBM pointed out during training, nor was it presented at a later
time. The other three workers received no training. The maintenance worker was simply told,
"Just don't deal with it."
No specific procedures for working around ACBM were presented during the
training.
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Participants suggested adding more information about health effects of asbestos
during the training. Those who did receive training felt it was not adequate, but that they pay
more attention to it now.
None of the participants were aware of training required for or presented to new
employees.
Asbestos-Related Work
A series of questions about work experiences around asbestos were posed to all
participants. The first question dealt with cleaning up after a roof leak had damaged asbestos.
Two custodial workers cleaned up after leaks. One said she had never been told if there was
asbestos present. The other custodial worker mopped up the leak before anyone else came
because children were present. Co-workers had told her there was asbestos present. No special
procedures were followed in either case.
The second question involved working above ceiling tiles where asbestos was located.
One maintenance worker stated that he worked near ACBM, but since he had been told not to
drill into the material, he did not. He did however, work above ceiling tiles in close proximity to
the material.
Question Three dealt with cleaning in a boiler room where asbestos was located. All
custodial workers had at various times cleaned up in boiler rooms. In one case ACBM is labelled
and the custodian stayed away from the material. Another custodial worker had swept up a
powdery dust in the school boiler room but did not know if it was asbestos. No special procedures
were followed.
The fourth question dealt with working in a location where a pipe insulated with
asbestos had leaked, damaging less than three linear feet of insulation. One custodian cleaned a
pipe leak in a boiler room without following any special procedures. Later, when a plumber came
to repair the pipe, he would not touch it since the insulation contained asbestos. In one other case,
a maintenance worker picked up a piece of insulation that had fallen to the floor and threw it
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away. He stated that he was just doing his job. There have been no situations where greater than
three linear feet of ACBM had been damaged.
Other jobs around ACBM include cleaning (wet mopping) vinyl asbestos floor tiles
(VAT), dry buffing VAT, and picking up pieces of VAT when it is broken and throwing it away.
One maintenance worker removed an asbestos insulation plug in order to drain the boiler.
In no cases are any special procedures followed when working around asbestos.
None of the participants have been involved in removal of ACBM or cleaning up after
asbestos was removed.
Respirator Availability
Only one worker had received some training in respirator use, and none have access
to respirators.
Other
There have been no changes in job responsibilities in the past two years except that
one maintenance worker has been told not to disturb any ACBM.
Most schools have outside consultants to deal with any asbestos. One private school
maintenance worker said that the school "deals with it." One public school custodial worker said
that the school board has people on staff to deal with asbestos problems. In all cases, if any
problem was suspected, the participants said they would either go to their supervisor or their
principal.
Only one school had asbestos labeled.
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Conclusions
There is a lack of knowledge about asbestos and awareness of the location of asbestos
in the schools. Over half the participants did not receive training, their only knowledge of asbestos
being based on what they were told by co-workers. This is definitely not in compliance with
AHERA requirements. Only one person was aware of a Management Plan. With one exception,
work is done without regard to appropriate procedures. This is due to the workers not being
informed as to what appropriate procedures are and because of lack of enforcement by
supervisors.
There is a high level of concern about personal safety. Some participants said they
want suits and masks. They felt that everyone should be told about asbestos and that everyone
should have to attend a training program. One custodian stated that a training program, "Lets you
know more how to take care of yourself. To not know where it is, to not be told, then you're in danger
all the time."
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MAINTENANCE AND CUSTODIAL WORKERS FOCUS GROUP
Bethesda, Maryland
Date: October 10,1990
Attending: Five people consisting of three maintenance workers for public schools and two
maintenance workers for private schools in the Washington, D.C. area.
Job Responsibilities
The job responsibilities of the maintenance workers who participated in this focus
group involved plant equipment operations, heating and air conditioning maintenance, building
and grounds maintenance, replacement of ceiling tiles, and plastering. Several participants
performed all maintenance except that for which a license was required.
Initial Awareness of Asbestos
Several participants were aware of the existence of asbestos in their schools from 15
to 20 years ago. One simply just "knew it was there", while others were made aware through a
seminar or through special work practices, such as applying a "special paint" to seal asbestos pipe
insulation. One participant was made aware of asbestos when he was transferred to a different
school about eight years ago, and another was made aware of asbestos about three years ago when
an inspection was being conducted in the school.
Recent Awareness of Asbestos
All participants had been informed of the existence of asbestos in their schools within
the last two years.
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Three workers received notices about asbestos in their schools, and in a few cases the
Management Plan was mentioned. The public school workers who were building-based received
notices circulated to them individually, as did a private school worker. The other workers were
made more aware of asbestos through warning labels and training seminars.
Everyone believed they knew where the asbestos in their school was located, based on
information in the Management Plan or the location of labels. Additionally, the participants
believed they knew the location of asbestos relative to their job responsibilities, though not
necessarily the location of all asbestos in their individual schools. If there was any question, most
workers felt they could ask a supervisor or go directly to the Management Plan. Only one private
school worker felt he had no one to go to for information, as the designated person was new and
the information was "too recent."
The Management Plan was mentioned early in the discussion. All participants had
seen Management Plans, and several had looked up the location of asbestos. The consensus was
that finding information was not all that easy, and once the information was found, it was not very
clear. All workers stated that they could contact a supervisor for help in understanding the
Management Plan, though one participant thought that his designated person was too new to be
truly helpful.
No one was familiar with the existence of an O&M plan as part of the Management
Plan. The workers felt they had received this information during training. One worker stated that
there were "...onty two things to be concerned with, that it fACBMJ is covered and safe, or that if it
[ACBM] is broken, it has to be removed."
Training
All participants had received asbestos training within the past 24 months. All but one
worker had received a two-hour training session. One worker attended a three-day session. These
two-hour sessions included films and slides, with someone leading the session to answer questions.
The class content was primarily awareness training, what asbestos looked like and the likely places
to find it. Some were shown on film the containment process, including glove bag procedures. All
were told very emphatically not to touch or disturb ACBM. The one worker who attended the
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three-day session felt his course was very informative and included a hands-on removal training
session.
Only one worker, a private school employee, was told specifically the location of
ACBM in the school during training. The others received general information about where
asbestos-containing material was likely to be found.
Most workers saw only films which explained equipment used in asbestos removal.
One worker, the three-day graduate, has hands-on experience with safety equipment.
One statement which sums up feelings was that "You don't have time to fix one joint
that takes four hours to do."
The participants thought that several areas should have been explained in greater
depth during training. They wanted to know more detail about how to remove ACBM on the spot,
and they wanted more information on the statistics and health hazards as well as more information
on how to work safely around ACBM.
Asbestos-Related Work
A series of questions about work experiences around asbestos were posed to all
participants. The first question dealt with cleaning up after a roof leak had damaged asbestos. A
few workers had performed clean-up jobs in this situation, one of them frequently. Procedures
included making a supervisor aware that the area was labeled ACBM and checking the
Management Plan to confirm the presence of ACBM. In one case a worker was told to clean up
anyway, and he did so without following appropriate work practices. Another was "...careful not to
disturb it [ACBM]", but he, too, did not following any special work procedures.
The second questions involved working above ceiling tiles where asbestos was located.
Most workers had performed this kind of work and no special work procedures were followed.
The concensus was that there was no time to do "...everything right." Concern was also expressed
that the labels that state ACBM is present do not clearly show which materials contain asbestos.
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Question Three dealt with cleaning in a boiler room where asbestos was located.
Most workers have performed cleaning jobs in this situation. Procedures involved sweeping,
mopping, dusting, and using a water hose to wet down the floor. The feeling was that all the
ACBM is covered and none of it is lose or friable and, therefore there is no danger. As one person
said, "They ain't proved to me it's dangerous."
The fourth question dealt with working in a location where a pipe insulated with
asbestos had leaked, damaging less than three linear feet of insulation. In one situation that
occurred, the worker cleaned up with a dust pan and broom and put the material in the trash.
Another worker had patched ceilings around damaged ACBM but was careful not to disturb it. No
special work procedures were followed. There were no cases where an area greater than three
linear feet had been damaged, except that one worker had to clean up debris after a contractor had
removed a large amount of ACBM. The only special procedure followed was hosing down the
floor area.
Other types of work around ACBM include working on boilers and the heating plant
systems, patching plaster around ACBM, and floor tile removal. In one case an outside contractor
removed ceiling tiles with ACBM and in the process damaged floor tiles. The worker asked the
contractors about it and one of them picked up a tile and threw it across the room indicating that
the tile was harmless. The worker proceeded to clean up the floor tile. This all occurred in a
containment area.
The following quotes typify feelings expressed in the discussion.
"It's not a realistic thing. This is a small school... We still had to go through. They told
us not to go inside the boiler room. We still went in there. We didn 't have lights."
"I have to do my job, if I don't do my job,... the whole building might blow up."
Respirator Availability
Several workers have access to respirators, although only one private school worker
had received training. He does not use a respirator since he was told to stay away from ACBM. A
few public school workers have access to respirators. One believes that the respirator he used was
E-35
-------
PEER REVIEW DRAFT
the wrong kind since he does not feel well when he uses it. In another case a worker has his own
respirator which he has used in a boiler room. These respirators are for use only by the individual
workers. Only the private school worker who attended the three-day course had been to see a
doctor about respirator use, and the exam was reportedly perfunctory.
Other
The only job responsibilities which appear to have changed within the past two years
are those having to do with work above ceiling tiles where there is ACBM.
All participants reported that their schools use outside contractors to perform large
asbestos removal jobs, although one person said he had heard that at some time in the future there
was to be a special school district abatement team to handle these matters. All would go to a
supervisor first if they suspected a problem which needed an outside contractor. In one case, a
worker had requested a removal crew but was turned down by his supervisors. Several people felt
that the contractors do more damage than good and that excessive costs were interfering with
removal occurring more rapidly.
Labeling was reportedly extensive in the schools in this area.
Conclusions
All workers have been made aware of asbestos in their schools. However, most do
not appear to have received the AHERA-mandated level of training considering their job
responsibilities and that they very possibly disturb ACBM. The maintenance workers know where
the asbestos is located and have good access to additional information, both from people and
Management Plans, if they so desire. Appropriate work procedures do not appear to be followed
in most cases around ACBM, either because the job has to be done immediately in a maintenance
emergency situation, because inadequate training and no access to appropriate equipment get in
the way, or supervisors tell the workers to do the work anyway.
E-36
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PEER REVIEW DRAFT
Concern over job security was expressed quite strongly by one maintenance worker.
He had objected to doing a job and was told by the school safety division to go ahead. As he said,
"I got chewed out fordoing it, but if I wouldn't nave done it, my superiors probably would've held me
insubordinate..." There was concern expressed that they as workers have been told that asbestos is
dangerous, but that it is not clear to the public what is considered safe and unsafe with regards to
asbestos. There was concern expressed for their own safety while on the job, their wanting further
information on safe work practices and health issues. There was also some confusion in that some
workers believed the only safe thing to do was to remove all ACBM from the school.
E-37
-------
PEER REVIEW DRAFT
APPENDIX F
MANAGEMENT PLAN
COMPLETENESS ITEM RESULTS
F-l
-------
Percent of Management Plans awarded specified points in Form M11
Question
General Inventory
1C.
2c.
3c.
Is a general inventory of school buildings present?
Is the name and address indicated for each school building on the
inventory?
Is it indicated whether each school building listed contains
friable ACBM, nonfriable ACBM, nonfriable ACBM, ACBM
assumed to be ACM or no ACBM?
Exclusion/Inspection
5c.
6c.
7c.
Does the management plan contain exclusion/inspection
information?
Does the exclusion/inspection information contain:
a Dates of inspection?
b. Name of each accredited person performing inspection?
c. Signature of each accredited person performing inspection?
d. Accrediting state?
e. AHERA accreditation number?
Does the exclusion/inspection information contain a blueprint,
diagram or written description of.
a Locations of homogeneous areas?
b. Approx. square or linear footage of homogeneous areas?
c. Exact sample locations (if sampling required)?
d. Dates of sample collection (if sampling required)?
0
2%
2%
11%
0%
4%
8%
13%
9%
8%
2%
5%
5%
7%
2
x
x
X
X
5%
0%
0%
0%
0%
x
X
X
2
.5 .6 1
XXX
3% x 3%
x x 2%
XXX
x 1% 90%
x 2% 91%
x 4% 83%
x 3% 88%
x 3% 89%
x x 14%
x x 15%
x x 1%
x <1% 90%
2
x
90%
9%
x
x
X
X
X
X
X
X
X
X
Points2
3
x
x
76%
X
X
X
X
X
X
27%
28%
7%
x
4
X
x
X
X
X
X
X
X
X
X
X
X
X
5
98%
X
X
100%
X
X
X
X
X
58%
52%
85%
x
6 10 14 NA3
X X X X
x x x 2%
x x x 2%
x x x x
x x x x
X X X X
X X X X
X X X X
X X X X
X X X X
X X X X
xx x 2%
x x x 0%
-------
Percent of Management Plans awarded specified points In Form Ml (Continued)
Question
8c.
10c.
11c.
12c.
13c.
14c.
Does the exclusion/inspection Information identify whether
homogeneous areas are TSI, surfacing materials, or miscel-
laneous material?
Is the method used to determine sample locations described?
Is the manner used to determine sampling locations
completely or substantially in accordance with AHERA for
a TSI?
b. Surfacing material?
c. Miscellaneous materials?
Is the following information present for inspectors who
collected bulk samples:
a Name of inspector?
b. Signature of inspector?
c. Accrediting state?
d. AHERA accreditation number?
Is the following information regarding bulk sample
analysis present:
a Copies of analyses?
b. Dates of analyses?
c. Name(s) and address(es) of laboratory(ies)?
d. Statement(s) of laboratory accreditation?
Are the name and signature present for persons who
performed the analyses of the bulk samples?
0
16%
76%
12%
24%
9%
12%
20%
15%
14%
1%
31%
2%
16%
18%
2
X
X
X
X
X
X
X
X
X
X
1%
0%
X
X
JS
X
X
X
X
X
X
X
X
X
X
X
X
0%
1%
.6
X
X
X
X
X
X
X
X
X
X
4%
2%
X
X
1
18%
2%
X
X
87%
85%
77%
82%
82%
0%
61%
93%
2%
5%
2
X
X
67%
42%
X
X
X
X
X
X
X
X
78%
72%
Points2
3
22%
1%
X
X
X
X
X
X
X
1%
X
X
X
X
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5
45%
18%
X
X
X
X
X
X
X
95%
X
X
X
X
6 10 14 NA3
X X X X
x x x 2%
xxx 21% •
xxx 34%
x x x 4%
x x x 3%
x x x 3%
x x x 3%
x x x 3%
x x x 2%
x x x 2%
x x x 2%
xx x 4%
x x x 4%
-------
Percent of Management Plans awarded specified points in Form M1 (Continued)
Question
16c.
17c.
18c.
Are written assessments present for friable ACBM, friable
assumed ACBM, nonfriable material which is newly
friable and/or TSI?
Do the written assessments in Q16 provide:
a. Signature of the assessor?
b. Date of signature?
c. Accrediting state?
d. AHERA accreditation number?
Are reasons given for each assessment?
Response Action Recommendation
19c.
20c.
21 c.
Are there written recommendations to the LEA regarding
response actions for friable homogeneous areas and TSI?
For the management planner who made the recommendations
in Q 19, is there
a Name?
b. Signature?
c. Date?
d. Accrediting state?
e. AHERA accreditation number?
For the response actions recommended, are there
a. Methods described to be used for preventive measures
and response actions?
b. Locations specified where such actions and measures
will be taken?
c. Schedules for beginning and completing each preventive
^^neasure and response action?
0
2%
17%
34%
12%
12%
4%
3%
6%
9%
26%
9%
7%
1%
2%
13%
.2 .5 .6 1
x x x 2%
x x x 68%
xxx 51%
xxx 73%
xxx 73%
x x x 0%
x x x x
xxx 78%
x xx 75%
xxx 59%
xxx 76%
xxx 78%
xxx <1%
x x x 2%
x x x 3%
2
x
x
X
X
X
X
0%
X
X
X
X
X
X
X
X
Points2
3
4%
X
x
X
X
<1%
X
X
X
X
X
X
1%
1%
15%
4
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
5 6 10
79% x x
xxx
xxx
xxx
xxx
81% x x
x 4% 81%
xxx
xxx
xxx
xxx
xxx
82% x x
79% x x
54% x x
14 NA3
x 13%
x 15%
x 15%
x 15%
x 15%
x 15%
x 13%
x 15%
x 15%
x 15%
x 15%
x 15%
x 15%
x 15%
_Jk!!5__
-------
Percent of Management Plans awarded specified points in Form M1 (Continued)
Question
Activity Plans
23c. Are activity plans or statements present for
a Reinspections?
b. Periodic surveillance?
c. O&M plan?
d. Management planner recommendation for initial
and additional cleaning?
e. The LEA response to initial cleaning recommendation?
24c. Are activity plans or statements present for
a. Reinspections?
b. Periodic Surveillance?
25c. Are steps described by which workers and building occupants,
or legal guardians, will be or have been notified about
a. Inspections/reinspections?
b. Response actions
c. Post-response action activities, including periodic
surveillance and reinspections?
d. Availability of management plan?
Resource Evaluation
26c. Is an evaluation of resources needed to complete the response
actions and carry out reinspections, O&M, periodic surveillance
and training present?
27c. Does the resource evaluation take all activities listed in Q23/Q24
and all recommended actions into account?
0
7%
8%
5%
30%
74%
3%
3%
12%
28%
31%
13%
6%
1%
Points2
2 JS A 1 2 3
X X X X X X
X X X X X X
X X X X X X
X X X X X X
x x x x x 14%
X X X X X X
X X X X X X
x x x x 88% x
x x x x 72% x
x x x x 69% x
x x x x x x
0% 0% 0% x x x
0% 0% 0% 16% x 25%
4
X
x
X
X
X
X
X
X
X
X
X
X
X
5
81%
79%
x
58%
x
x
x
x
x
x
X
94%
51%
6 10 14 NA3
xxx 13%
xxx 13%
x 82% x 13%
xxx 13%
xxx 13%
x x 10% 87%
x x 10% 87%
XX X X
X X X X
X X X X
X X X X
X X X X
x x x 6%
-------
Percent of Management Plans awarded specified points in Form Ml (Continued)
Question
ADP
28c. Are the following items provided regarding the LEA's
designated person?
a Name
b. Address
c. Phone Number
d. Training received
e. Sign-off that LEA responsibilities
under AHERA have or will be met
Points2
0 2 .5 .6 1 2 34 5 6 10 14 NA3
3% x x x x 97% x x x x x x x
14% xxx 86% x x x x xx x x
10% xx x 90% xxxxxxxx
21% xxx 79% xxxxxxxx
28% xxx 72% xxxxxxxx
N - 83,840
1 Questions used to produce logical skip sequences were numbered In Form M1, but not scored. For this reason, the question numbers presented In this and other tables are not contiguous.
2X means that this was not a score option for particular question.
3Not applicable answers are those where the question was not answered based on friability, assumption of ACM, exclusions, or other Management Ran characteristics.
-------
PEER REVIEW DRAFT
APPENDIX G
EPA KEY ELEMENTS CHECKLIST
G-l
-------
OPTIONAL FORM
REQUIRED ELEMENTS
FOR
LEA ASBESTOS MANAGEMENT PLAN
Submission with Asbestos Management Plan Required
This "Required Elements" form must be completely filled out and submitted by
each local education agency (LEA) with its asbestos management plan. If the
"Required Elements" form is missing or incomplete, the entire management plan
will be rejected as incomplete.
Carefully completing this form will help assure that the management plan
meets federal requirements and will facilitate accurate and timely state review.
Directions
This form lists the federally required elements of each LEA asbestos
management plan. The form is completed by listing all the page numbers where a
specified element appears in the plan. When completed, therefore, the form will
index the management plan's required elements.
In addition, questions are posed for a number of elements that require
either (1) affirmation that information for those elements of the management
plan is complete, or (2) an explanation of what is missing and why the required
element is incomplete. Inadequate explanations for missing elements will be
treated as incomplete responses.
Format
The "Required Elements" form is organized into 13 sections. Citations to
federal regulations mandating specific elements are given in the appropriate
sections. Space is provided in the form for the page numbers in the plan where
the specific elements are contained. Space also is provided for responses'to
questions posed in the form. If additional space is needed, continue on the
back of the same page.
-------
OPTIONAL FO
REQUIRED ELEMENTS
FOR
LEA ASBESTOS MANAGEMENT PLAN
Directions: List the pages of the management plan that contain the specified
elements and give complete responses to each question.
I. General Inventory - 763.93 (e)(l)
A list with the name and address of each school building and whether
the building contains friable ACBM, nonfriable ACBM, or ACBM assumed
to be ACM.
Page Numbers
II. Exclusions for inspections completed before December 14, 1987 - 763.93
D(e)(2) - 763.99 (If NO EXCLUSIONS were declared for inspections before
December 14, 1987, check box and skip to III.)
(Hark N/A at B, D, E, or F if that type of exclusion not declared.)
A. Date(s) of inspection(s). (Required for all exclusions except (F),
which is the exclusion for school buildings constructed after October
12, 1988.)
Page Numbers
Q: Do the pages listed give the inspection dates for each
homogeneous or sampling area receiving an exclusion?
Yes * No
If no, please explain.
B. Statement(s) by accredited inspector(s) that, based on sampling
records:
(Check the appropriate box for exclusions being declared.)
d Friable ACBM was identified in homogeneous or sampling area(s).
L~H Nonfriable ACBM was identified in homogeneous or sampling area(s).
Q Material determined not to be ACBM in homogeneous and sampling ^^»
area(s) was sampled in substantial compliance with Sec. 763.85(a^r
List the pages that include statements that qualify each type of
exclusion (as checked above).
-------
Q. Do the page numbers listed give a statement for each homogeneous
or sampling area that is receiving an exclusion?
Yes No
If no, please explain.
Each statement by an accredited inspector must include: (i) signature
of the accredited inspector, (ii) date of signature, (iii)
accreditation agency (state or EPA approved), and (iv) accreditation
number (if applicable).
Q. Do the statement(s) contained in the pages listed give all four
categories of information for each inspector declaring an
exclusion?
Yes No
If no, please explain.
For each of the above exclusions (friable ACBM, nonfriable ACBM, and
material not ACBM), the additional information specified in (C) is
required.
Blueprint, diagram, or written description of each school building
that identifies clearly (a) each location and approximate square or
linear footage of homogeneous areas where material was sampled and j_f
possible (b) the exact location where each bulk sample was collected
and the date of collection.
Page'numbers, of blueprint, diagram1, or written description of school
buildings where material was sampled for ACM.
Q. Do the pages listed contain a blueprint, diagram, or written
description for each school building where an exclusion is being
declared based on samples?
Yes No
If no, please explain.
Q. Does the blueprint, diagram or written description of each
school building identify clearly the locations and approximate
square or linear footage as specified above?
-------
r
Yes No
If no, please explain.
For each bulk sample analyzed, list the pages that give the following
three categories of information:
i. Copies of analysis. Page Numbers
ii. Dates of analysis. Page Numbers
iii. Other lab reports Page Numbers
(if any prepared).
Q. Do the pages listed provide all three categories of information
for every bulk sample collected and analyzed?
Yes No
If no, please explain.
D. Statement(s) by accredited inspector(s) that, based on records of the
inspection(s), suspected ACBM in homogeneous or sampling area(s) is
assumed to be ACM.
Page Numbers
Q. Do the pages listed include statement(s) for all homogeneous or
sampling area(s) receiving an exclusion for suspected ACBM
assumed to be ACM?
Yes No
If no, please explain.
Each statement by an accredited inspector must include: (i) signature
of the accredited inspector, (ii) date of signature, (iii)
accreditation agency (state or EPA approved), and (iv) accreditation
number (if applicable).
Q. Do the statements contained in the pages listed give all four
categories of information for each inspector declaring an
exclusion?
Yes No
I f nn. nlo^p exol a in .
-------
r
J
E. Statement(s) by accredited Inspector(s) that, based on Inspection
records and contractor and clearance records, no ACBM 1s present In
homogeneous or sampling area(s) where asbestos removal operations were
conducted before December 14, 1987.
Page Numbers
Q. Do the pages listed Include statement(s) for all homogeneous or
sampling area(s) receiving an exclusion based on removal
operations?
Yes No
If no, please explain.
Each statement by an accredited inspector must include: (i) signature
of the accredited inspector, (ii) date of signature, (iii)
accreditation agency (state or EPA approved), and (iv) accreditation
number (if applicable).
Q. Do the statements contained in the pages listed give all four
categories of information for each inspector declaring an
exclusion?
Yes No
If no, please explain.
F. A signed statement by an architect or project engineer responsible for
the construction of a new school building built after October 12,
1988, or an accredited inspector, that no ACBM was specified as a
building material in any construction document for the building, or,
to the best of his or her knowledge, no ACBM was used as a building
material in the building.
Page Numbers
G. A copy of written assessments required to be made under Sec. 763.88 of
material that was identified before December 14, 1987, as (a) friable
ACBM, (b) friable suspected ACBM assumed to be ACM, (c) nonfriable
material that is newly friable, or (d) thermal system insulation.
Page Numbers
Q. Do the pages listed include written assessment(s) for all areas
of these types (a-d) that are receiving exclusions?
Yes
No
If no. olease explain.
-------
The written assessment(s) must Include the following information: (i)
name of assessor, (11) signature of assessor, (Hi) date, (iv)
accreditation agency (state or EPA approved), and (v) accreditation
number (if applicable).
Q. Do the assessments contained in the pages listed give all five
categories of information regarding each assessor and written
assessment?
Yes No
If no, please explain.
H. Descriptions of any response actions or preventive measures taken.
Page Numbers
Q. Do the pages listed give a description of each response action
or preventive measure taken in areas receiving an exclusion?
Yes No
If no, please explain.
The following additional information regarding response actions and
preventive measures is required "if possible". List the page numbers
that give the following:
i. Names and addresses of the contractors involved.
Page Numbers
ii. Start and completion dates of the.work.
Page Numbers
iii. Results of any air samples analyzed during and upon completion
of work.
Page Numbers
III. For inspections completed on or after December 14, 1987 - 763.93 (e)(3)
763.85
A. A copy of the inspection report(s) completed under Sec. 763.85.
Page Numbers
Q. Do the pages listed contain inspection reports for every LEA
building covered under AHERA, except those buildings (or parts
of buildings) receiving exclusions?
-------
Yes No
If no, please explain.
Each inspection report must include the following information: (i)
dates of inspection, (ii) name of each accredited person performing
the inspection, (iii) signature of each accredited person performing
the inspection, (iv) accreditation agency (state or EPA approved), and
(v) accreditation number (if applicable).
Q. Does each inspection report give all five categories of
information?
Yes No
If no, please explain.
B. A blueprint, diagram, or written description of each school building
that identifies clearly:
i. Each location and approximate square or linear footage of
homogeneous areas where material was sampled.
ii. The exact location where each bulk sample was collected.
iii. Dates of collection.
iv. Homogeneous areas where suspected ACBM is assumed to be ACBM.
Page numbers of blueprints, diagrams, or written descriptions of
school buildings where material was sampled for ACM or assumed to be
ACM.
Q. Do the pages listed contain a blueprint, diagram, or written
description for each school building where material was sampled
for ACM or assumed to be ACM?
Yes No
If no, please explain.
Q. Does the blueprint, diagram, or written description of each
school building identify clearly the location and approximate
square or linear footage of each homogeneous area where material
hiil k satnole was
-------
collected, the dates of collection, and each homogeneous area
where ACBM is assumed to be ACM?
Yes No
If no, please explain.
C. List of homogeneous areas Identified in (6) above that indicates
whether those areas are surfacing material, thermal system insulation,
or miscellaneous material (Sec. 763.85).
Page Numbers
Q. Does the list cover each homogeneous area identified in (B) and
classify each area as surfacing material, thermal system
insulation, or miscellaneous material?
Yes No
If no, please explain.
D. Bulk sample procedure.
i. Description of the manner used to determine sampling locations.
Page Numbers
i
Q. Do the pages listed describe the manner used to determine
sampling locations for every sample collected?
.Yes No
If no, please explain.
List the pages that give the following information regarding the
inspector(s) who collected the bulk samples.
ii. Name. Page Number
iii. Signature. Page Number
iv. Accreditation Agency Page Number
(State or EPA approved).
v. Accreditation Number Page Number_
(if applicable).
-------
Q:
Do the pages listed above give all four categories of Information
for every inspector who collected bulk samples?
Yes
No
If no, please explain.
E. Analysis of bulk samples.
List the pages that give the following four categories of information
regarding analyses of bulk samples.
ii.
iii
iv.
Copies of analyses.
Dates of analyses.
Page Number_
Page Number_
Name and address of laboratories
that analyzed bulk samples. Page Number_
Statement(s) of laboratory
accreditation.
Page Number_
Q: Do the pages listed give all four categories of information for
every bulk sample collected and analyzed?
Yes No
If no, please explain.
List the pages that give the following information regarding all
person(s) who performed the analyses of bulk samples.
v.
VI.
Name.
Signature.
Page Number_
Page Number_
F. A copy of written assessments under Sec. 763.88 of all friable ACBM,
friable suspected ACBM assumed to be ACM, and thermal system
insulation.
Page Numbers
Q.
Do the pages listed include written assessments of all friable
ACBM, friable suspected ACBM assumed to be ACK, and thermal
system insulation?
Yes
No
T f
-------
1U
Q. Do the assessments contained in the pages listed give all five
categories of information regarding the assessor and written
assessment?
Yes No
If no, please explain.
IV. Designated Person - 763.93 (e)(4)
A. Name, address and phone number of LEA's designated person.
Page Numbers
B. Training received by designated person, including date training
received, length of training (hours), and course name.
Page Numbers
V. Response Action Recommendations- 763.93 (e)(5) - 763.88 (d)
A. Written recommendation made to the LEA regarding response actions.
Page Numbers
The written recommendation must contain the following information:
(i) name of management planner making recommendation, (ii) signature
of the management planner, (iii) date, (iv) accreditation agency
(state or EPA approved), and (v) accreditation number (if applicable).
Q: Does the written recommendation contained in the pages listed give
all five categories of information for the management planner?
Yes No
If no, please explain.
VI. Response Actions - 763.93 (e)(6)
A. Detailed descriptions of preventive measures and response actions to
be taken.
Page Numbers
i. Methods to be used for preventive measures and response actions
to be taken.
Page Numbers
-------
11
1i. Locations where such actions and measures will be taken.
Page Numbers •
iii. Reasons for selecting each response action or preventive
measure.
Page Numbers
iv. Schedules for beginning and completing each preventive measure
and response action.
Page Numbers
Q: Do the pages listed in A(i - iv) give the methods, location,
schedules, and reasons for selection for every preventive
measure and response action to be taken?
Yes No
If no, please explain.
VII. Assurance of Accreditation - 763.93 (e)(7)
Statement that person(s) who inspected for ACBM and who will design or
carry out response action, except O&M, are or will be accredited by:
i. The state's approved accreditation program, Page Number
or
ii. An EPA-approved course or another state's
approved accreditation program. Page Number
VIII. ACBM Remaining After Response Action - 763.93 (e)(8)
A detailed description in the form of a blueprint, diagram, or written
description of ACBM, or assumed ACM, that does or will remain after
response action.
Page Numbers
IX. Activity Plans - 763.93 (e)(9)
A. Plan for reinspection. Page Number
B. Plan for periodic surveillance. Page Number
-------
C. Operations and maintenance plan. Page Number
i. Management planner recommendation
regarding additional cleaning. Page Number
11. The LEA response to that recommendation. Page Number
X. Notifications - 763.93 (e)(10) and (g)(4)
A. Method to notify workers and building occupants, or legal guardians,
about the following activities:
1. Inspections/reinspections. Page Number
ii. Response actions. Page Number
ill. Post-response action activities, including:
o Periodic surveillance. Page Number
o Reinspection activities. Page Number
B. Notification of parent, teacher, and employee organizations/groups of
the availability of the management plan:
i. Description of steps taken. Page Number
ii. Dated copy of the notification. Page Number
XI. Resource Evaluation - 763.93 (e)(ll)
An evaluation of resources needed to complete response actions
successfully and carry out reinspection, operations and maintenance
activities, periodic surveillance, and training.
Page Numbers
XII. Names and Signatures of Responsible Parties
A. Management Plan Consultants - 763.93 (e)(12) and (f)
i. Name and statement of accreditation (state-approved program or
EPA-approved course) for each consultant who contributed to the
management plan.
Page Numbers
ii. Name and signed statement by management planner that management
plan complies with AHERA requirements (Optional).
Page Numbers _____
-------
13
B. Designated Person Sign-Off - 763.93 (1)
Signed certification by designated person that general LEA
responsibilities under 763.84 have been met or will be met.
Page Numbers
XIII. Recordkeeping - 763.93 (h) and 763.94 (b-h)
A. For each preventive measure and response action already taken since
December 14, 1987, provide the following information (if none taken,
write N/A for page numbers).
i. A detailed written description of the action.
Page Numbers
List the pages that give the following eight categories of
information regarding each measure or action described in the
pages listed above (A[i]).
1) Methods used.
Page Number
2) Location of measure or action.
Page Number
3) Reasons for selection of each measure or action.
Page Number
4) Start and completion dates.
*
Page Number
5) Names and addresses of all contractors involved.
Page Number
6) Accreditation agency (if applicable) (State or EPA approved).
Page Number
7) Accreditation number (if applicable).
Page Number
8) Storage or disposal site if ACM was removed.
Page Number
0: Do the pages listed above give all eight categories of information
-------
14
Yes
No
If no, please explain.
ii. Documentation of air sampling at completion of response actions.
List the pages that give the following nine categories of
information for air sampling locations:
1) Name and signature of any
person collecting any air
sample.
2) The locations where those
samples were collected.
3) Date of collection.
4) Name and address of
analyzing laboratory.
5) Date of analysis.
6) Results of analysis.
7) Method of analysis.
Page Number_
Page Number_
Page Number_
Page Number_
Page Number_
Page Number_
Page Number_
8) Name and signature of person
performing analysis. Page Number
9) Laboratory accreditation
statement.
Page Number_
Q: Do the pages listed give all nine categories of information
for every air sampling location?
Yes No
If no, please explain.
B. Employee training already conducted since December 14, 1987
(16 hours of training required before employee disturbs ACBM) Sec.
763.92 (a)(l and 2).
List the pages that give the following five categories of information
for each employee trained.
i .
Name.
1 W *• » f 1 r\
Page Number
-------
15
ili. Date training was completed. Page Number
iv. Location of training. Page Number_
v. Number of hours completed. Page Number_
Q: Are all five categories of information provided for every employee
who received 16 hours of training?
Yes No
If no, please explain.
C. If the initial cleaning required under Sec. 763.91 (c) already has
been conducted, list the pages that give the following information,
otherwise list N/A.
i. Name of each person performing
the cleaning. Page Number
ii. Date of cleaning. Page Number_
iii. Locations cleaned. Page Number_
iv. Methods used. Page Number_
D. For operations and maintenance activities conducted under 763.91(d)
since December 14, 1987, list the page(s) that give the following five
categories of information. (If no O&M activities have been conducted,
list N/A.)
*
i. Name of person(s) performing
the activity. Page Number
ii. Start and completion dates. Page Number_
iii. Location. Page Number_
iv. Description of activity. Page Number_
v. If removal, the name and
location of storage and
disposal sites. Page Number_
Q: Are all five categories of information provided for every
operations and maintenance activity conducted since December 14,
1987?
Yes No
-------
E. For each time that a major asbestos activity is performed under Sec.
763.91 (e) since December 14, 1987, list the page(s) that give the
following seven categories of information.
i. Name and signature of person(s)
performing activities. Page Number
ii. State of accreditation (or EPA). Page Number_
iii. Accreditation number
(if applicable). Page Number_
iv. Start and completion dates of
activities. Page Number_
v. Location of activities. Page Number_
vi. Description of activities. Page Number_
vii. If ACBM removed, name and
location of storage or
disposal site. Page Number,
F. For each fiber release episode that has occurred since December 14,
1987, list the pages that give the following four categories of
information.
i. Date and location of episode. Page Number
ii. Method of repair, preventive
measures or response action. Page Number
iii. Name of person performing
the work. Page Number_
iv. If removal, the name and
location of storage and
disposal sites. Page Number_
Q: Are all four categories of information provided for every fiber
release episode since December 14, 1987?
Yes No
If no, please explain.
I
-------
17
Additional Comments:
LEA Designated Person
Name:
Title:
Address:
Phone Number:
Signature: Date:
-------
PEER REVIEW DRAFT
APPENDIX H
LOCAL EDUCATION AGENCY AND SCHOOL CONTACT LETTERS
H-l
-------
Initial LEA Contact Letter
WESTAT
An Employee-Owned Research Corporation
165O Reaearcn Blvd. • Rockville. MD 20850-3123 • 3O1 2S1-15OO • FAX 3O1 S94-SO4O
«data wordln.dat»
December 29,1989
^Superintendent's Name*
«title»
«LEA»
«Address»
«Cityzip»
Dear «name»:
Westat, Inc. is a survey research firm which has been conducting surveys for 28 years.
Westat has a national reputation conducting research for federal agencies, such as the
Environmental Protection Agency, and the U.S. Department of Education's National Center for
Education Statistics.
The Environmental Protection Agency (EPA) has authorized Westat to conduct a study to
assess the impact of the Asbestos Hazard Emergency Response Act (AHERA) of 1986. The
attached letter from Mr. Charles Elkins, Director of EPA's Office of Toxic Substances, briefly
introduces this study. Westat's survey design includes the following steps.
• Westat will telephone the principals of approximately 1,000 randomly selected schools
nationwide to conduct a brief screening interview to determine eligibility for the study.
• After schools have been determined to be eligible, Westat will draw the sample of
approximately 200 schools nationwide for inclusion in the study.
• After mailing a letter to the principals of these 200 schools, Westat will contact the
principals to set up appointment times for an interviewer and an AHERA-certified
inspector to come to the schools. While at the school, the Westat interviewer will
conduct a brief survey with the principal and with randomly chosen custodial and
maintenance staff. The interviewer will also photocopy the asbestos management plan
which is to be reviewed at a later date. At a time which is convenient to the school,
the Westat interviewer and the inspector will conduct a walk-through inspection of the
selected school building. At no time will classes be disrupted, and the time required
of the principal and staff will be minimal
The following page lists the schools sampled from your district* which have been selected
for the first step outlined above, the screening portion of this study. At this time we do not know
which, if any, of these schools will be selected to participate in the remainder of the study.
Participation in this study is voluntary, and all information provided to Westat will be held in
strictest confidence. No identifiable information will be provided to any individual or group,
including the Environmental Protection Agency.
-------
Initial LEA Contact Letter (Continued)
•Superintendent's name*
December 29,1990
Page 2
A Westat representative will be pilling your AHERA designated person within the next two
weeks to arrange brief telephone interviews with principals of the selected schools.
If you have any questions about the study, please contact me at Westat's toll-free number,
(800) WESTAT4.
Thank you for your assistance.
Sincerely,
Dr. Alexa Eraser
Project Director
Enclosure
cc-. AHERA designated person
* Schools in vour District
«Schools»
-------
Initial LEA Contact Letter (Continued)
I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
** WASHINGTON, O.C. 20460
.•f
OFFICE or
PKSTICIDES AND TOXIC SUBSTANCE*
Dear Superintendent:
I am writing you about the evaluation of an important national program
and Federal law that affects the safe learning environment of school children.
In 1986, Congress signed into law the Asbestos Hazard Emergency Response Act
(AHERA). This law required Local Education Agencies to inspect for asbestos -
containing material in their buildings and, if present, to develop and
implement management plans for abating any hazards associated with that
material.
The Environmental Protection Agency (EPA) is now evaluating the schools
rule developed as a result of AHEEA. EPA has asked tfestat, Inc., a nationally
known statistical survey company, to conduct this survey.
The schools listed in the footnote of the letter from Westat have been
chosen through a scientifically designed sample selection process. Their
participation, as well as the participation of other schools throughout the
United States, is absolutely essential to the success of the study. The input
of principals and custodial and maintenance staff, as well as the results of
the in-school inspections, will provide information to assess the impact of
AHERA on the schools.
Participation in this study is voluntary. We want to assure you that
all information provided will be kept strictly confidential by Westat and will
not be released to any group or individual. Nor will any personal- or school-
identifying information be released to the EPA.
If you need any assistance, or if you have any questions about the
study, please call Vestat's Project Director, Dr. Alexa Fraser, toll-free at
(800) WESTAT4. or Dr. Christine Augustyniak of my staff at (202) 382-3622.
Thank you for your cooperation and assistance.
Sincerely,
Charles L. Elklns
Director
Office of Toxic Substances
-------
School Selection Letter to AHERA Designated Person
WESTAT
An Emntoyee-Owned Reseercn Corporation
165O Researcn Blvd. • Rockvme. MD 20850-3129 • 3O1 251-15OO • FAX 3O1 294-2O4O
«data c:\word5\ahera\adp-pub.dat»
February 23,1990
«Name»
«LEA»
«Address»
«Cityzip»
«Salutation»
Thank you for your assistance in providing information about some of the schools
for which you are the AHERA designated person. We have reviewed the data collected
nationwide and have chosen the final sample of school buildings for the next phase of the
AHERA Evaluation Studies. Your school district has been selected for inclusion in this
important study, and the school «building» chosen from your district «isare» listed at the
end of this letter.
A Westat representative will be calling you to set up a time to come to your office to
obtain materials and information from you and to answer any further questions you may
have. The enclosed checklist contains a list of the information we need, and we are now
asking for your assistance and support in obtaining these items.
These items include a copy of the management plan for the selected «school». Also
needed are floor plans for each school building listed and information concerning
construction dates and renovations in the building. We need this information in order to
conduct a walk-through re-inspection in an efficient manner. Westat will be pleased to
reimburse the LEA for the cost of photocopying these materials. We will also need
information about custodial and maintenance training concerning asbestos for your district.
After speaking with you, Westat will send a letter to the principal of each school
selected to participate. Westat plans to contact each principal to set up appointment times
for an interviewer and for an AHERA-cenified inspector to visit the school, unless you
prefer to arrange these visits. While at the school, the Westat interviewer will conduct a
brief interview with the principal and the Westat interviewer and inspector will conduct a
walk-through re-inspection of the selected school building. The re-inspection does 021
include taking physical samples of suspect materials. At no time will classes be disrupted,
and the time required of the principal will be minimal Re-inspections can take place
during part of the regular school day and after normal school hours or, if you prefer, they
can occur completely after school hours and on weekends. The time required to complete
a walk-through re-inspection varies, but on average, a re-inspection will require 16 to 18
hours over a two to three-day period. We will need access to all parts of each selected
building, including crawlspaces, mechanical rooms, and storage areas. If school policy
requires us to be accompanied during this re-inspection, we would appreciate your
arranging staff to be present at the times we will be in the «school». We will also need to
have a six-foot ladder available.
-------
School Selection Letter to AHERA Designated Person (Continued)
«Name»
February 23, 1990
Page 2
Participation in this study is voluntary, and all information provided to Westat will
be held in strictest confidence. No identifiable information will be provided to any
individual or group, including the Environmental Protection Agency.
If you have any questions about this phase of the study, please contact me at
Westat's toll-free number, (800) 937-8284.
Thank you for your assistance.
Sincerely,
Dr. Alexa Fraser
Project Director
Enclosure
School Buildings in vour District
«Schoolname»
-------
School Selection Letter to AHERA Designated Person (Continued)
CHECKLIST FOR AHERA EVALUATION MATERIALS
Management Plan • a complete copy for each selected school Please check to see
that the copy has at a minimum the following:
- School inspection results
- Remediation recommendations and response actions
• Operations and Maintenance plan
- Copies of the notification document(s) through which parents were informed of the
management plan
- Copies of AHERA clearance air monitoring results for response actions completed,
including identification of areas cleared
Floor plan for each selected school building. A copy of the current fire escape plan
would meet our needs.
Construction, renovations, and response action information for each selected
building. These information items include:
- Construction dates of the buildings, building wings, and any additions
- Major renovations, such as removing walls, changing the heights of ceilings or other
renovations taking over one week to complete
- The type of HVAC system
- The location of crawlspaces, attics, mechanical rooms, and other similar areas
- Information about asbestos response actions that have been completed in each
selected school building.
Custodial and maintenance training concerning asbestos.
-------
Initial Principal Contact Letter
WESTAT
An Employee-Owned Research Corporation
1SSO Research Blvd. • Rockville. MD 2DB5O-3129 • 3O1 S51-15OO • FAX 3Q1 2S4-2O4O
«data c:\word5\ahera\princonf.dat»
March 16,1990
«Principalname»
«Schoolname»
«Address»
«Cityzip»
Dear «Salutation»:
Westat, Inc. is a survey research firm which has been conducting surveys for 28 years.
Westat has a national reputation conducting research for federal agencies, such as the
Environmental Protection Agency and the U. S. Department of Education's National Center for
Education Statistics.
The Environmental Protection Agency has authorized Westat to conduct a study to evaluate
the Asbestos Hazard Emergency Act (AHERA) which was signed in 1986. Your school has been
chosen to participate in our study. The enclosed letter from Mr. Charles Elkins, Director of EPA's
Office of Toxic Substances, briefly introduces this study.
Recently, a Westat representative spoke with your AHERA designated person to schedule
an appointment. At that time, your AHERA designated person offered to contact you to arrange
the following:
• An appointment for a Westat interviewer to come to your school and conduct a brief
interview with you. During this interview, we will be asking questions about
notification letters concerning asbestos which were sent to parents and staff.
• An appointment for an AHERA certified inspector to conduct a re-inspection of the
«buildingname» at a time that is convenient for your school.
A Westat Interviewer will call you to confirm these appointments approximately two days
prior to the scheduled time.
The re-inspection will be done by a certified AHERA inspector and will not include taking
physical samples. We anticipate part of the re-inspection will take place during the regular school
day and part after normal school hours. In addition, we will need access to all pans of the building,
including crawlspaces, mechanical rooms, and storage areas. We will also need to have a six-foot
ladder available. At no time will classes be disrupted, and the time required of you will be
minimal.
All information provided to Westat will be held in strictest confidence and participation in
this study is voluntary. No identifiable information will be provided to any individual or group,
including the Environmental Protection Agency.
-------
Initial Principal Contact Letter (Continued)
«Principalname»
Page 2
Once the study results have been compiled, we will send a copy of the inspector's report to
your AHERA designated person.
If you have any questions about the study, please contact Westat at our toll-free number,
(800) 937-8284.
Thank you for your assistance.
Sincerely,
Dr. Alexa Fraser
Enclosure
-------
Initial Principal Contact Letter (Continued)
UNfTED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, O.C. 20460
OFFICE OF
PESTICIDES AND TOXIC
SUBSTANCES
Dear Principal:
I am writing you about the evaluation of an important
national program and Federal law that affects the safe learning
environment of school children. In 1986, Congress signed into
law the Asbestos Hazard Emergency Response Act (AHERA). This law
required Local Education Agencies to inspect for asbestos-
containing material in their buildings and, if present, to
develop and implement management plans for abating any hazards
associated with that material.
The Environmental Protection Agency (EPA) is now conducting
the evaluation of the schools rule developed as a result of
AHERA. EPA has asked Westat, Inc., a nationally known
statistical survey company, to conduct this survey.
Your school has been chosen to participate through a
scientifically designed sample selection process. Your
participation, as well as the participation of other schools
throughout the United states, is absolutely essential to the
success of the study. Your input and the results of the in-
school inspection will provide information to evaluate AHERA in
schools. We believe that your support of this study is critical
to its success.
Participation in this study is voluntary. We want to assure
you that all information provided will be kept strictly
confidential by Westat and will not be released to any group or
individual. Nor will any personal- or school-identifying
information be released to the EPA.
If you need any assistance, or if you have any questions
about the study, please call Westat's Project Director, Dr. Alexa
Fraser, toll-free at (800) 937-8284, or Dr. Christine Augustyniak
of my staff at (202) 382-3622.
Thank you for your cooperation and assistance.
Sincerely,
rles L. Elkins
Director
Office of Toxic Substances
-------
APPENDIX I
COEFFICIENTS OF VARIATION AND CONFIDENCE INTERVALS
TO BE DONE
1-1
-------
APPENDIX!
FREQUENCY TABLES FOR CODED QUESTIONS
TO BE DONE
J-l
-------
PEER REVIEW DRAFT
APPENDIX K
STATISTICAL TECHNICAL APPENDIX
K-l
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PEER REVIEW DRAFT
K.1 SAMPLING METHODOLOGY DETAILS
K.1.1 Selection of PSUs
The PSU sample for AHERA was a subsample of a Westat master sample of 60
PSUs. The frame for Westat's master sample consisted of a list of 1,179 PSUs across the United
States, excluding Alaska, Hawaii, Puerto Rico, and the island possessions. The PSUs were formed
based on 1970 Census definitions and stratified by Census region and urbanicity. Then the original
60 PSUs in the master sample were selected systematically with probabilities proportionate to a
measure of size that reflected the 1980 population of the PSU.
The subsample of 30 PSUs was selected as follows. First, using 1980 population as the
measure of size, the six largest PSUs were taken as certainties. The two New York PSUs in the 60-
PSU sample were combined to form one of these certainties. The remaining 53 PSUs were
stratified based on the probability of selection in Westat's master sample. The number of PSUs
selected in each stratum was proportional to the 1980 population of the stratum. The methods of
selection differed in each stratum in an attempt to achieve a sample of PSUs whose overall
probabilities of selection were proportionate to 1980 population. The 53 PSUs were sorted by
stratum, Census region within stratum, and urbanicity within region. In the first stratum,
consisting of certainty PSUs in the 60-PSU sample, five PSUs were chosen systematically and with
probabilities proportionate to 1980 population. In the second stratum, consisting of noncertainty
PSUs in the 60-PSU sample, 19 PSUs were chosen systematically and with equal probability.
Table K-l shows the distribution of the 30 PSUs selected for the AHERA study by Census region
and urbanicity class.
K.1.2 Selection of Schools within PSUs
The sample of schools for AHERA was selected using a double-sampling design. A
screening sample of 1,041 schools was initially selected to obtain information about the eligibility
of the schools. Then a stratified subsample of 200 schools was selected from the eligible schools as
determined by screening. The remaining eligible schools were designated as replacements.
K-2
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PEER REVIEW DRAFT
Table K-l. The PSUs selected for AHERA by Census region and urbanicity class
Region
Midwest
Northeast
South
West
Total
Urbanicity class
Urban Suburban
3
4
2
2
11
3
2
5
2
12
Rural
2
1
3
1
7
Total
8
7
10
5
30
The frame for the screening sample consisted of the 21,080 public, private, and
Catholic schools on the 1988 QED file (Quality Education Data. Inc.. Denver, Colorado) that were
in the 30 selected PSUs. Previous evaluations of the QED file indicate that coverage of the public
and Catholic schools is virtually complete; however, about 15-20 percent of non-Catholic private
schools are not included in QED, representing about two percent of all schools in the nation. A
sampling measure of size was assigned to each school to facilitate sample selection. These
measures of size represented the conditional probabilities of including the school in the sample
given that its PSU was in the sample, and were inversely proportional to the selection probability
of the PSU. The sampling measures of size were designed to yield a self-weighting sample of
schools and an average of 35 schools per PSU.
After the sampling measures of size were assigned to each school, the frame was
first sorted by PSU, and type of control (public and other, private, and Catholic) within PSU.
Then within the Catholic and private type-of-control classes, the frame was further sorted by size
class (three levels based on enrollment) and instructional level (elementary and other) within size
class. Within the public and other type-of-control class, the frame was further sorted by district,
size class within district, and instructional level within size class. Then a screening sample of 1,041
schools was selected systematically and with probability proportionate to the sampling measure of
size using a random start and a skip interval of 1. Table K-2 summarizes the distribution of the
1,041 schools selected for screening, by Census region and type of control.
K-3
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PEER REVIEW DRAFT
Table K-2. The schools selected for screening by Census region and type of control
Region
Midwest
Northeast
South
West
Total
Public
207
144
301
126
778
Type of control
Private Catholic
36
35
11
13
95
39
25
68
36
168
Total
282
204
380
175
1,041
The frame for the primary sample of 200 schools consisted of the 750 schools that
were eligible after screening. Schools were eligible if all of the following conditions held:
a) The school contained any of grades 1-12.
b) The school had a Management Plan.
c) The school had at least one building which was built before October 1988,
housed students on a regular basis, and was found to contain suspect material in
an inspection performed after December 1987.
As in the selection of the initial screening sample, a sampling measure of size was assigned to each
school to facilitate selection of the final sample. These measures of size were designed to yield 200
schools, 100 that had begun remediation and 100 that had not. A school was said to have begun
remediation if all eligible buildings in the school had begun remediation. Otherwise the school
was said not to have begun remediation. Thus a building selected for inclusion in the study may be
in a school defined as a non-remediation school but in fact remediation may have occurred. The
number of schools selected in each PSU varied in order to make the workloads in each PSU more
comparable. The measures of size used for sample selection purposes depended on the PSU and
remediation status of the school.
After the sampling measures of size were assigned to each school, the frame was
sorted by PSU, remediation status within PSU, district within remediation status, and school size
(square-footage category) within district. Then a primary sample of 200 schools was selected
K-4
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PEER REVIEW DRAFT
systematically and with probabilities proportionate to the sampling measure of size using a random
start and a skip interval of 1.
Because the study plan called for the inspection of 200 schools, back-up and
replacement samples of schools were also designated to be used in the event that primary schools
refused to participate in the study. Two hundred back-up schools were selected in a manner
similar to the primary sample, and each back-up school was paired with a school in the primary
sample. The paired schools were in the same PSU, had the same remediation status, and would
result in the same number of sampled buildings in virtually all cases. The remaining 350 schools
that were not chosen for the primary or back-up samples were designated as possible
replacements. The order in which the replacements were released was prioritized so that a
replacement would have characteristics (i.e., PSU, remediation status, and number of buildings
selected) similar to that of the primary school it replaced, to the extent possible. Table K-3
summarizes the distribution of the 200 schools selected for the primary sample by Census region
and remediation status.
Table K-3. The schools in the primary sample by Census region and remediation status
Region
Midwest
Northeast
South
West
Total
Remediation status
Remediation
begun
21
18
42
19
100
Remediation
not begun
33
30
26
11
100
Total
54
48
68
30
200
K.13
Selection of Buildings within Schools
Within the selected schools, buildings were sampled systematically and with
probability proportionate to building size (square-footage category). In most cases, only one
K-5
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PEER REVIEW DRAFT
building was sampled per school; in a few cases, two buildings were sampled per school. While this
method did not yield a self-weighting sample of buildings, it increased the precision of the
building-level estimates by allowing the selection of multiple buildings in some schools, while
maximizing the number of schools selected to increase the precision of school-level estimates.
Buildings were selected for schools in the primary and back-up samples as follows.
The frame consisted of the eligible buildings in the schools in the primary and back-up samples.
The 10 largest schools in the primary sample and their pairs in the back-up sample were
designated as schools in which two buildings would be sampled, if possible. The remaining schools
were designated as schools in which one building would be sampled. Sampling measures of size
that were proportional to building size and reflected the number of buildings to be selected in each
school were attached to each building. Buildings in schools in which all buildings were to be
sampled were taken as certainties, so the sampling measure of size was 1. For schools in which
two buildings were sampled, buildings whose probability of selection would have been greater than
0.5 under PPS sampling were also taken as certainties.
After the sampling measures of size were assigned to each building, the frame was
sorted by building size within each school. The buildings were selected systematically with
probability proportionate to the sampling measures of size, using a random start and a skip
interval of 1. This method yielded 210 buildings in the primary sample and 207 buildings in the
back-up sample. Three of the schools in the back-up sample in which two buildings were to have
been selected only had one building.
Buildings were selected in a similar manner for schools in the replacement sample,
except that the number of buildings to select in each school was decided as follows. Seven
PSU/remediation status categories had primary schools in which two buildings were selected. In
these PSU/remediation status categories, two buildings were selected from replacement schools
with at least two buildings, and one building was selected from the remaining schools. In the
remaining PSU/remediation status categories, one building was selected from each school. These
procedures ensured that schools and their replacements were in the same PSU/remediation status
category, and would result in the same number of selected buildings if possible. Table K-4 shows
the distribution of the 210 buildings in the primary sample, by Census region and remediation
status.
K-6
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PEER REVIEW DRAFT
Table K-4. Buildings in the primary sample by Census region and remediation status
Region
Midwest
Northeast
South
West
Total
Remediation status
Remediation
begun
21
18
47
23
109
Remediation
not begun
33
30
26
12
101
Total
54
48
73
35
210
The screening information was originally collected by telephone. To determine the
accuracy of this information, it was verified during the AHERA designated person interview in the
field. In some cases, changes to the sampling frame used to select buildings were recorded. For
example, an eligible building not previously reported was discovered, or a structure previously
recorded as one building was really two separate buildings according to the definitions used in this
study. In these cases, buildings were resampled in the field based on the updated screening
information. Sixty-two buildings were resampled in this manner.
K-7
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PEER REVIEW DRAFT
IC2 DETAILS OF DATA WEIGHTING
K-2.1 Calculating School Weights
For the AHERA evaluation, the weight used for school-level estimation is given by:
Wsch = WXX W2X fjX W3X f2X fj
where Wj = the inverse of the PSU probability of selection.
W2 = the inverse of the within PSU sampling rate for the screening
sample.
fj = a screening sample nonresponse adjustment factor calculated within
each stratum, equal to the number of schools selected for screening
divided by the number of schools that responded during screening.
Schools that were found to be ineligible for AHERA during
screening are considered to be responding schools for weighting
purposes.
W3 = the inverse of the conditional within stratum sampling rate for
selecting the final sample from the schools eligible after screening.
f2 = a final sample nonresponse adjustment factor calculated within each
stratum, equal to the number of schools selected for the final sample
divided by the number of participating schools. The participating
schools include substitutes in the back-up and replacement samples.
f3 = a nonreponse adjustment factor for the "samples" of original
inspections, parents and teachers in RA4, RA5-parents and RA5-
teachers. The factor was calculated within each Census
region/remediation status category and given by:
2W! W2 f! W3 f2
fittfi mnplc
Sw w f w f
1 21 32
approp. RA sampk
where the numerator is summed for the 198 schools in the final
sample and the denominator is summed for the participating schools
in the original inspection, parent, or teacher samples.
K-8
-------
PEER REVIEW DRAFT
Due to the patterns of nonresponse, there are four different sets of school weights,
one for RA2, RA5-principals, and RA6, and one for each of Research Areas 4, 5-parents, and 5-
teachers. The school weights range in value from 183 to 3,959.
K22 Calculating Building Weights
For the AHERA evaluation, the weight used for building-level estimation is given by:
^bldg = Wgch X W4
where W^,, = the final school weight for RA2, RA5 principals, and RA6.
W4 = the inverse of the conditional probability of selecting a building
within a school.
The building weights calculated for the AHERA evaluation were used in RA1 and
RA3. These weights range in value from 183 to 10,135.
K-9
-------
PEER REVIEW DRAFT
KJ DETAILS OF IMPUTATION
A sequential hot deck procedure was used for imputation in RA2, RA5, and RA6. In
this method, cases are sorted by variables thought to be related to the statistics of interest. These
sort variables form imputation cells within which the imputation will occur. For each item to be
imputed, the cases that have a nonmissing value for this item ("donors") and the cases that need
imputation on this item ("recipients") are determined. Then each case is looked at in turn within
each imputation cell. When a recipient is found, the donor immediately preceding the recipient
(or immediately after, if none is preceding) is used for imputation. Occasionally, a donor is used
more than once in this method; and in some cells, there may not be any potential donors. When
the latter occurs, different sort variables are chosen until all cases have been imputed.
KJ.l RA1 School Reinspection
No statistical imputation procedures were employed in the comparison of the original
AHERA inspection and the reinspection. Since this research area was an evaluation of the
original AHERA inspection, information missing from the Management Plan would be indicative
of the level of quality of the inspection and would therefore not be a candidate for imputation.
Further, it was felt that imputing quantities of identified or quantified material from one school
building to another would be of questionable validity due to variations in school size and would
compromise the inspection evaluation.
K32 RA2 Management Plan Evaluation
The sequential hot deck procedure described above was used to impute items in RA2.
The variables control type and Census region defined the imputation cells. All necessary values
were imputed during the first invocation of the hot deck procedure.
Table K-5 shows the number of imputed cases by item. The number of total cases
varies across items due to the skip pattern.
K-10
-------
Table K-5. Imputed cases in RA2
1t Total Imputed Percent
item cases cases imputed
MIC
M2C
M3C
M7CA
M7CD
M12CA
M12CB
M12CC
M12CD
M13CA
M13CB
M13CC
M13CD
M14C
M17CA
M20CA
M20CB
M20CC
M20CD
M20CE
M23CA
M23CC
M23CD
M23CE
M24CA
M24CB
M25CA
198
196
196
198
198
191
191
191
191
193
193
193
193
189
170
167
167
167
167
167
174
174
174
174
24
24
198
2
4
4
1
6
1
4
1
1
2
2
4
3
2
1
1
1
1
1
1
1
3
3
8
1
1
4
1.0%
2.0%
2.0%
0.5%
3.0%
0.5%
2.1%
0.5%
0.5%
1.0%
1.0%
2.1%
1.6%
1.0%
0.6%
0.6%
0.6%
0.6%
0.6%
0.6%
0.6%
1.7%
1.7%
4.6%
4.2%
4.2%
2.0%
1t Total Imputed Percent
item cases cases imputed
M25CB
M25CC
M25CD
M26C
M27C
M28CA
M28CB
M28CC
M28CD
M28CE
M29A
M30AA
M30AB
M31UA
M31UB
M31UC
M31UD
M31UE
M31UF
M31UG
M32U
M33UA
M33UB
M34UA
M34UB
M34UC
M34UD
198
198
198
198
189
198
198
198
198
198
198
39
39
198
198
198
198
198
198
198
198
198
198
198
198
198
198
6
6
5
1
3
6
11
12
14
13
1
5
2
5
7
34
2
7
7
7
1
2
1
2
2
3
5
3.0%
3.0%
2.5%
0.5%
1.6%
3.0%
5.6%
6.1%
7.1%
6.6%
0.5%
12.8%
5.1%
2.5%
3.5%
17.2%
1.0%
3.5%
3.5%
3.5%
0.5%
1.0%
0.5%
1.0%
1.0%
1.5%
2.5%
-------
PEER REVIEW DRAFT
KJ3 RA3 Response Action Evaluation
No statistical imputation procedures were employed in this research area.
Information on recommended response actions was obtained from Management Plans; it was felt
that imputation from one Management Plan to another would compromise the evaluation of
recommended response actions. Information on actual response actions was obtained from the
reinspection; it was felt that only response actions that could be confirmed and evaluated by the
reinspector should enter the analysis.
K3.4 RA4 Original Inspector Evaluation
The sequential hot deck macro procedure was not used to impute missing data items
in RA4. In evaluation analysis of this type, one does not wish to ascribe to one inspector the
characteristics of another. Only "Don't know" responses were imputed based upon the following
item specific rules:
• AHERA accrediation (I3YR. I3MM): If don't know year then assume
year= 1988. If don't know month then assume month=May.
• AHERA refresher course (I5YR. I5MM^: If don't know year then assume
year = 1989. If don't know month then assume month=March.
• Date of first asbestos inspection (I12YR. I12MM): If don't know year then
year=missing. If don't know month then assume month=June.
• Number of building/school asbestos inspections conducted TI13AA ~ I17AA):
All don't knows were recorded to missing. All missing values were then treated
as zeroes for calculating the number of building/school inspections completed
for each of the five time periods (prior to January of 1988, January through
June of 1988, July through December of 1988, January through June of 1989,
and July through December of 1989).
• Years of building trade experience (I19YRS. I19MM): If don't know number
of years then years=missing. If don't know number of months then
months=zero.
• Years of environmental laboratory experience (I21YRS. I21MM^: If the
number of years was not ascertained then years=missing.
K-12
-------
PEER REVIEW DRAFT
K3.5 RA5 Process of Notification
In this research area, principals reported on the notification of parents (RA5-
principals), parents reported on their own notification (RA5-parents), and teachers reported on
their own notification (RA5-teachers). When deciding how to impute, the general assumption was
that principals should be able to answer questions regarding the notification of parents in their
school, whereas parents and teachers may have memory recall problems, or may not be the most
appropriate respondents for this information. Thus for most items, principals' "Don't know"
responses were imputed, and parents' and teachers' "Don't know" responses were not. In the
principal part of RA5, "Don't know" responses were considered as missing and were imputed,
except for item P4. For this item, which asks whether parents were notified about asbestos, "Don't
know" responses were considered an interesting finding and were not imputed. Also, for the
principal part of RA5, "Don't know" responses were imputed as "No's" for the items noted below.
The sequential hot deck procedure described earlier was used to impute cases other
than those described above. The variables chosen to define the imputation cells are listed below.
The sort variables were employed one at a time until all data were imputed.
1. District
2. Type of control within PSU
3. Type of control within region
4. Control type
Tables K-6 through K-8 show the number of imputed cases by item. The asterisk
indicates that "Don't know" responses were imputed as "No's" for that item. The number of total
cases varies across items due to the skip pattern.
K-13
-------
PEER REVIEW DRAFT
Table K-6. Imputed cases in RA5-principals
Item
P7A
P7B
P7C
P7D
P7E
P7F
P8
P9A
P9B
P9C
P9D
P9E
P9F
P10A*
P10B*
P10C*
P10D*
P10E*
Pll*
P12
P13*
P14
Total
case
163
163
163
163
163
163
63
163
163
163
163
163
163
163
163
163
163
163
163
33
33
163
Imputed
cases
10
12
14
11
17
10
4
21
22
20
17
19
21
1
1
1
1
1
3
2
4
11
Percent
imputed
6.1%
7.4%
8.6%
6.7%
10.4%
6.1%
6.3%
12.9%
13.5%
12.3%
10.4%
11.6%
12.9%
0.6%
0.6%
0.6%
0.6%
0.6%
1.8%
6.1%
12.1%
6.7%
'"Don't know" responses were imputed as "no".
K-14
-------
PEER REVIEW DRAFT
Table K-7. Imputed cases in RA5-parents
Item
N14A
N14B
N14C
N14D
N14E
N14F
N15
N17A
N17B
N17C
N17D
N17E
N17F
N18A
N18B
N18C
N18D
N18E
N19
N20
N21
Total
cases
79
79
79
79
79
79
34
78
78
78
78
78
78
78
78
78
78
78
76
23
22
Imputed
cases
1
1
1
1
1
2
1
3
3
3
3
7
3
3
3
3
3
4
5
5
6
Percent
imputed
1.3%
1.3%
1.3%
1.3%
1.3%
2.5%
2.9%
3.8%
3.8%
3.8%
3.8%
8.9%
3.8%
3.8%
3.8%
3.8%
3.8%
5.1%
6.5%
21.7%
27.2%
K-15
-------
PEER REVIEW DRAFT
Table K-8. Imputed Cases in RA5-teachers
Item
N9
N10
N35A
N35B
N35C
N35D
N35E
N35F
N36
N38A
N38B
N38C
N38D
N38E
N38F
N39A
N39B
N39C
N39D
N39E
N40
N41
N42
Total
cases
119
148
129
129
129
129
129
129
85
123
123
123
123
123
123
123
123
123
123
123
123
22
22
Imputed
cases
2
3
3
1
1
2
1
. 3
2
1
1
1
1
1
2
1
1
1
1
1
3
1
1
Percent
imputed
1.7%
2.0%
2.3%
0.8%
0.8%
1.6%
0.8%
2.3%
2.3%
0.8%
0.8%
0.8%
0.8%
0.8%
1.6%
0.8%
0.8%
0.8%
0.8%
0.8%
2.4%
4.5%
4.5%
KJ.6
RA6 Maintenance Personnel Behavior
The sequential hot deck procedure described earlier was used to impute items in
RA6. The variables chosen to define the imputation cells are listed below. The sort variables were
employed one at a time until all data were imputed.
1. District
2. Type of control within PSU
3. Related item. For example, if item L8, regarding the location of the most
recent training for custodians, were missing, then the imputation would be
based on item L14 and L15, regarding the location of the most recent training
for maintenance workers.
K-16
-------
PEER REVIEW DRAFT
In this research area "Don't know" responses were considered as missing and were
imputed. Table K-9 shows the number of imputed cases by item. The number of total cases varies
across items due to the skip pattern.
Table K-9. Imputed cases in RA6
Item
L8
L9
L10
L11A
L11B
LI 1C
LI ID
L12
L13
L14
L15
L16
L17A
LITE
L17C
L17D
L18
L19
L26A
L26B
L26C
Total
cases
188
188
188
188
188
188
188
188
188
173
173
173
173
173
173
173
173
173
198
198
198
Imputed
cases
2
4
7
13
11
10
11
3
2
2
3
6
11
10
9
11
2
1
2
5
3
Percent
imputed
1.1%
2.1%
3.7%
6.9%
5.9%
5.3%
5.9%
1.6%
1.1%
1.2%
1.7%
5.2%
6.4%
5.8%
5.2%
6.4%
1.2%
0.6%
1.0%
2.5%
1.5%
K-17
-------
PEER REVIEW DRAFT
K.4 DETAILS OF VARIANCE ESTIMATION
Replication methods are often used to estimate variance in complex sample surveys.
These techniques involve the use of several subsamples or replicates obtained from the full sample,
calculating the statistics of interest for each replicate, and estimating the variance of each statistic
using the different replicates. Many different replication methods exist. They differ in the way in
which replicates are actually formed. A method called jackknife replication was used in AHERA,
and is described below.
First, stratum and unit codes were assigned to the participating schools by PSU to
facilitate the formation of replicates. These codes are shown in Table K-10. Each certainty PSU
(whose probability of selection is one) forms its own stratum. The asterisk indicates that within
these PSUs, the schools were randomly assigned a unit code of 1 or 2. Note that the remaining
noncertainty PSUs were paired resulting in two noncertainty PSUs per stratum. Buildings
received the same stratum and unit codes as their corresponding schools.
K-18
-------
PEER REVIEW DRAFT
Table K-10. Stratum and Unit Codes for AHERA
PSU
Alll
A113
A120
A140
A210
A220
A240
A330
A350
A410
A420
B120
B150
B210
B230
B260
B330
B350
B370
B380
B390
B420
B440
C120
C210
C230
C310
C330 .
C360
C420
Stratum
1
2
3
7
4
5
7
8
8
6
9
10
11
12
13
13
15
16
16
17
17
9
18
10
11
12
14
14
15
18
Unit code
2
2
1
*
2
2
1
1
2
1
1
2
1
2
1
1
1
1
2
2
1
2
2
• 2
Eighteen replicates were formed by randomly choosing a unit code (either a 1 or 2) in
each of the eighteen strata. Replicate i consists of the schools in stratum i that do not have the
unit code that was chosen, plus all of the schools in the other strata. The resulting replicates are
called "jackknife" replicates since they were obtained by dropping a unit or set of units from the
full sample.
K-19
-------
PEER REVIEW DRAFT
An estimated total based on the survey results was calculated using the usual formula
Y = 2 w; y.
i- 1
where Y = the population total of interest,
Y = the sample estimate of Y,
n = the number of participating schools or buildings,
w- = the full sample weight for school or building i, and
y^ = the observed value of Y for sampled school or building i.
Other statistics such as means and proportions were then calculated from the totals. For example,
the sample estimate of the mean is
A
Y =
A proportion may be considered a special case of the mean in which y^ is an indicator variable
equal to 0 or 1.
The weights for replicate i were equal to: zero for the schools that were deleted in
stratum i, two times the full sample weight for the remaining schools in stratum i, and the full sample
weight for the schools in the remaining strata. Instead of doubling the weight in the schools
remaining in stratum i, the weights are sometimes recalculated for each replicate by applying the
same weighting method that was used for the full sample weights. Although the latter method of
recalculating the replicate weights is preferable, it was not used for the AHERA studies. However,
we expect that variances calculated by the method used in AHERA will be reasonably close to
those that would have been obtained from the preferred approach.
K-20
-------
PEER REVIEW DRAFT
The variance of a statistic of interest was then calculated using the formula:
' k
/>. * ^ * A /»
Var(Z) =2^ (Z; - Z)2
i= 1
where Z = the statistic of interest,
k = the number of replicates,
Z = the full sample estimate of Z,
Z_ = the estimate of Z for replicate i
K-21
-------
APPENDIX L
ASSESSMENT SCORE TABLES
L-l
-------
Table L-1. Computer Generated Potential for Damage (PD)
Potential
H20 damage
1 = Yes
2 - No
1
2
1
2
2
1
2
2
1
2
1
2
2
1
2
2
1
2
1
2
2
1
2
2
General
access
1 = Yes
2 = No
1
1
1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
From Form W3
Maintenance
access
1 = Low
2 = High
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
2
2
2
2
2
2
2
2
1
1
1
1
1
1
1
1
Air
velocity
1 = None
2 = Low
3 = High
3
3
2
2
2
1
1
1
3
3
2
2
2
1
1
1
3
3
2
2
2
1
1
1
Effect of
vibration
1 = Low
2 = High
1 or 2
1 or 2
1 or 2
2
1
1 or 2
2
1
1 or 2
1 or 2
1 or 2
2
1
1 or 2
2
1
1 or 2
1 or 2
1 or 2
2
1
1 or 2
2
1
Generated
potential
for damage
1 = No PD
2 = PD
3 = Signif. PD
3
3
3
3
2
3
3
2
3
3
3
3
2
3
3
2
3
3
3
3
2
2
2
1
-------
Table L-2. Computer-Generated AHERA 1-7 Categories and Expanded AHERA 1-7 Categories
From Form W3
Generated
potential
Suspect
material
key code
S or M
S or N
S or N
S or M
S or M
S
S
S
S
S
M
N
N
N
M "
T
T
T
T
T
T
T
T f
Friable
1 = Yes
2 = No
3 = Not req'd
3
2
1
1
1
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1 or 2
1. 2 or 3
1. 2 or 3
1. 2 or 3
1, 2 or 3
1. 2 or 3
1. 2 or 3
1, 2 or 3
1, 2 or 3
Local
damage
1 » <1X
2 = 1-25X
3 - >25X
(terminate)
1
1
1
1
1
2
2
3
1, 2 or 3
1
2
2
3
1. 2 or 3
1
1
1
1
2
2
3
1, 2 or 3
Dispersed
damage
1 = <1X
2 = 1-10X
3 = >10X
1
1
1
1
2
2
1
1 or 2
3
2
2
1
1 or 2
3
1
1
1
2
1
2
1 or 2
3
for damage
from Table 1-1
1 =
2 =
3 =
.1.
1.
1.
1.
1,
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
1.
No PD
PO
Signif. PD
2. or 3
1
2
3
2 or 3
2 or 3
2 or 3
2 or 3
2 or 3
2 or 3
2 or 3
2 or 3
2 or 3
2 or 3
1
2
3
2 or 3
2 or 3
2 or 3
2 or 3
2 or 3
AHERA 1-7
category
NATO
NA
7
5
6
2
3
2
3
3
4
4
4
4
4
7
5
6
1
1
1
1
1
Expanded
AHERA 1-7
category
NATD
NA
7
5
6
2
3
2
3
3
1a
4b
4a
4b
4b
7
5
6
1a
1a
1b
1b
1b
NATO « Not able to determine/no access to material.
NA » Not applicable/AHERA 1-7 is not determined for these materials.
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