United States
Environmental Protection
Agency
Office of
Toxic Substances
Washington, D.C. 20460
EPA 560/4-91-012
June 1991
Office of Toxic Substances
Asbestos in Schools:
Evaluation of the Asbestos Hazard
Emergency Response Act (AHERA):
A Summary Report
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Asbestos in Schools:
Evaluation of the Asbestos Hazard
Emergency Response Act (AHERA)
A Summary Report
By:
Alexa Fraser
Robert Clickner
Naomi Everett
Susan Viet
Westat, Inc.
1650 Research Boulevard
Rockville, MD 20850
Prepared for:
Economics and Technology Division
U.S. Environmental Protection Agency
Washington, D.C. 20460
June 1991
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AHERA EVALUATION
TABLE OF CONTENTS
Chapter Page
1 INTRODUCTION 1-1
2 IDENTIFICATION AND ASSESSMENT OF MATERIAL 2-1
3 MANAGEMENT PLAN EVALUATION 3-1
4 RESPONSE ACTION EVALUATION 4-1
5 ORIGINAL AHERA INSPECTION EVALUATION 5-1
6 PROCESS OF NOTIFICATION 6-1
7 MAINTENANCE AND CUSTODIAL WORKER TRAINING
AND EXPERIENCE 7-1
8 GLOSSARY 8-1
List of Exhibits
Exhibit Page
2-1 Universe of suspect materials in school buildings 2-1
2-2 Percent of suspect materials identified 2-2
2-3 Percent of suspect material quantities identified 2-3
2-4 Percent of buildings with asbestos-containing
material quantity properly estimated 2-4
2-5 Percent of areas with suspect materials present and
recorded in management plans 2-5
3-1 Management plan completeness scores by sub-area 3-1
3-2 Management plan completeness scores 3-2
3-3 Number of usability elements found in management
plans 3-3
4-1 Recommended response actions 4-2
4-2 Percent of school buildings with one or more
remediations 4-3
iii
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AHERA EVALUATION
List of Exhibits (continued)
Exhibit Page
4-3 Adequacy of remediations 4-3
5-1 School average inspection scores 5-2
7-1 Percent of schools providing some training
to maintenance workers 7-2
7-2 Percent of schools providing some training to
custodians 7-2
7-3 Percent of schools providing various lengths of
training to maintenance and custodial workers 7-3
IV
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AHERA EVALUATION
1. INTRODUCTION
n Fall 1989, the United States Environ-
mental Protection Agency's (EPA's)
Office of Toxic Substances asked Westat, Inc., a
survey research firm, to perform an evaluation of
the initial 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 long-term tasks.
The AHERA evaluation study focused on occu-
pied school buildings in the United States with
students in any of grades 1 through 12. There
were a few exclusions: buildings constructed
after October 1988,1 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. Westat estimates that the
schools in the target population, from which the
sample for this evaluation was drawn, represent
approximately 80 percent of all 106,000 schools
in the nation.
building constructed after this date was not required to
be inspected under AHERA. These buildings must, how-
ever, have a signed statement by the building's architect,
project engineer, or an accredited inspector stating that no
ACBM was specified or used in construction.
The AHERA evaluation was conducted in a na-
tional statistical sample of 30 communities, in
which Westat visited a total of 198 schools and
207 school buildings. Participation in this eval-
uation was voluntary and approximately 25 per-
cent of the originally sampled schools elected
not to participate. Specially selected and
trained inspectors thoroughly reinspected2 each
participating school building; their findings were
compared with the original AHERA inspection at
each school as reported in the school's man-
agement plan. In-person interviews were con-
ducted with each school principal and AHERA
designated person (ADP) for each Local Educa-
tion Agency (LEA). In addition, telephone inter-
views 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
Westat reinspections, the inspectors looked for
suspect building materials. Suspect building
materials are construction materials thought to
contain asbestos because of past practices in
their formulation and manufacture. Laboratory
analysis of a bulk sample is required to deter-
mine if a particular suspect material in fact con-
tains asbestos. Since AHERA required the
identification of suspect material, bulk sampling
2For purposes of this report, reinspection refers to the work
done under this evaluation and not the triennial reinspec-
tion.
1-1
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AHERA EVALUATION
was not needed as part of this evaluation. In-
stead, we focused on evaluating how well the
original AHERA inspections identified, as-
sessed, described, and quantified suspect ma-
terials. (AHERA does not require bulk sampling.
Suspect material may be treated "as if" it con-
tains asbestos.)
To supplement the statistical data, a number of
focus groups (i.e., guided group discussions for
in-depth exploration of a topic) were undertaken
in communities nationwide. Four focus groups
were held with parents and teachers not asso-
ciated with schools in our sample. In addition,
five focus groups were held with school mainte-
nance and custodial workers also not associ-
ated with our sampled schools. In both cases,
participants in the focus groups were selected in
a non-random, non-statistical manner. Rather,
as is usually the case in a focus group, partici-
pants were invited purposefully to create a
group with many different types of people.
While this small sample of focus groups is not a
reliable basis for statistical estimates (and has
not been used in such a way), it did provide
useful qualitative insights into the notification
process and maintenance and custodial training
and experience.
The AHERA evaluation assessed the imple-
mentation of the initial phase of AHERA and did
not attempt to study compliance with all ele-
ments of the AHERA legislation. First, schools
that did not have a management plan were ex-
cluded, thus separating out this category of non-
compliers. Second, certain activities required
under AHERA were not evaluated. These in-
cluded reviewing the "process" of carrying out
response actions, such as verifying that appro-
priate containments were used when required
and appraising Operations and Maintenance
(O&M) Plans. Also, not all possible suspect
items were included in the suspect materials
category for this evaluation. For example, wall-
board, cement and cinderblock, and flooring
under wall-to-wall carpeting were excluded from
the study, though they are included in AHERA.
Although we considered monitoring the air for
asbestos fibers, we rejected it in favor of inspec-
tion and assessment of building materials that
could potentially release asbestos fibers. This
approach was used for two reasons. First, be-
cause the AHERA regulations specifically call for
the inspection and assessment of building ma-
terials in schools, we wanted to determine how
well this was done. In this sense, AHERA serves
primarily as a preventive measure to ensure that
existing asbestos in schools does not become
friable or present a future exposure source.
Second, since air monitoring covers a short
period of time, sometimes air monitoring shows
no asbestos fiber release, even though release
can occur when asbestos-containing materials
are disturbed (through contact, maintenance,
renovation, etc.). Thus, air monitoring could
miss the times that fibers are released. AHERA
is concerned with preventing not only current
asbestos fiber release, but potential future re-
lease as well.
The AHERA evaluation research consisted of six
separate Research Areas. Each Research Area
addressed a different aspect of the AHERA pro-
gram: school building inspections, manage-
ment plans, response actions, original AHERA
inspection evaluation, notification, and mainte-
nance and custodial worker training. The EPA,
in consultation with Westat and the technical
consultants who worked on this project, devel-
oped specific research questions for each Re-
search Area. The goal of the evaluation re-
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AHERA EVALUATION
search was then to collect and analyze data to
answer the questions. A summary of the re-
search questions and the study findings is pre-
sented in the following six chapters.
The statistical estimates presented in this report
were derived through the use of standard statis-
tical packages. They are often followed by a
number in parentheses, for example,"... 80 per-
cent (± 6%) of schools nationally ..." The num-
ber in parentheses may be used to form a 95
percent confidence interval3 for the estimated
value. In the example, the 95 percent confi-
dence interval would be 74 percent to 86 per-
cent, and there is one chance in 20 that the dif-
ference between the estimate and the unknown
population parameter exceeds 6 percent.
For greater detail, the full findings of the
evaluation have been published by EPA under
the title Evaluation of the Asbestos Hazard
Emergency Response Act (AHERA) Final Report.
The publication number is 566/4-91-013.
Additional information concerning this, and
other reports, can be obtained through the
TSCA Assistance hotline. The number is (202)
544-1404.
A confidence interval is a measure of the statistical preci-
sion of the estimate. Roughly, we are 95 percent confident
that the ranges defined by the limits of the confidence
interval include the unknown population parameter. More
precisely, 19 samples out of 20 will yield computed inter-
vals that include the estimated parameter.
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AHERA EVALUATION
2. IDENTIFICATION AND
ASSESSMENT OF MATERIAL
Was all the suspect material found at the original AHERA inspection?
Was the asbestos found at the original AHERA inspection properly
assessed?
T
he goal of this Research Area was to
estimate how much of the suspect
material was found in the original AHERA in-
spections and how much of the asbestos-
containing material was assessed in
conformance with AHERA regulations. "How
much" was measured in three ways:
(1) How many of the individual suspect
materials in school buildings were
identified;
(2) To what extent quantities of identified
materials were properly estimated; and
(3) What percentage of the areas with
each type of suspect material was
recorded in the original AHERA
inspection.
Exhibit 2-1 illustrates the universe of suspect
materials in school buildings and some of the
difficulties inherent in evaluating building in-
spections after the passage of several months
or more. Areas A, B, and C together represent
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 in the original
AHERA inspection. The circle on the right
(areas B and C) represents materials found in
the reinspection.
Exhibit 2-1.
Universe of suspect materials in school
buildings1
Found in
original
AHERA
inspection;
not found in
reinspection
Found both
in original
AHERA
inspection
and in
reinspection
Not found
in original
AHERA
inspection;
found in
reinspection
1 Diagram for illustration only. Ratios in actual data not
shown.
2-1
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AHERA EVALUATION
To estimate the percent of suspect materials
identified in the original AHERA inspections,
it is necessary to make two assumptions. First,
materials found in the original AHERA in-
spection, but not in the reinspection (area A) are
assumed to have been removed in the interim
between the two inspections. Second, materials
found in the reinspection but not in the original
AHERA inspection (area C) are assumed to
have been missed in the original inspection,
rather than added after the original inspection.
Under these assumptions, the ratio A + B _
provides an estimate of the percent of suspect
materials identified in the original inspections. In
addition, we would also like to estimate the frac-
tion of total quantity that the original inspector
found for square or linear feet. Unfortunately,
the quantity already abated (A) is not known.
B
However, we can calculate
These lower bound esti-
B
bound on
- A + B + c
mates are reported later in this section.
Identification of Materials. We first address
how well the original AHERA inspections identi-
fied suspect materials. Suspect asbestos-
containing materials include every material in a
school building which has not been sampled
and analyzed by a NVLAP-accredited labora-
tory2 for asbestos content. Suspect asbestos-
containing building materials include specific
thermal insulation, surfacing, and miscellaneous
materials (defined by the EPA in the AHERA
regulation and supporting documents) which
have not been sampled and analyzed by a
NVLAP-accredited laboratory for asbestos
2National Voluntary Laboratory Accreditation Pro-
gram, a proficiency program for laboratories that
perform bulk sample analysis by polarized light
microscopy, established by the National Institute of
Science and Technology.
content. Asbestos-containing materials and
asbestos-containing building materials are those
materials which have been sampled and ana-
lyzed by an accredited laboratory and found to
contain more than one percent asbestos.
The question of how well the original AHERA in-
spection identified suspect materials is impor-
tant because, if a material was not identified, it
was not sampled to determine asbestos con-
tent. Moreover, it would not have been included
in the asbestos management program, even if it
contained asbestos.
An estimated 70 percent of the 971,000 individ-
ual suspect materials still present in school
buildings at the time of reinspection was identi-
fied in the original AHERA inspections; 72 per-
cent of the 506,000 suspect friable materials was
identified. Thermal system insulation (TSI) was
more likely to be identified than either miscella-
neous or surfacing materials (see Exhibit 2-2).
Exhibit 2-2.
Percent of suspect materials identified
Percent
identi- «*
fed 30%
TSI Suffering Vliscelloneous
Material type
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AHERA EVALUATION
Many types of materials were identified in the
vast majority of inspections, including floor tile,
ceiling tile, and all types of thermal system in-
sulation. However, certain types of materials
were not regularly identified: vibration damp-
ening cloth, fire doors, and linoleum.
When the numbers of the individual suspect
materials identified were translated into quanti-
ties, 89 percent of the 4.7 billion square feet of
suspect material present was identified. Sus-
pect materials are generally quantified as square
feet of surface covered by the material. A few
materials, most notably pipe wrap, are quanti-
fied as linear feet of insulated pipe; 94 percent of
the 89 million linear feet present of these materi-
als was identified. (As discussed above, these
quantity estimates are lower bounds.)
Over 90 percent of the total amount each of the
following materials was identified in the original
AHERA inspections: floor tile, ceiling surfacing
material, and several categories of thermal sys-
tem insulation-tank insulation, elbow/fitting/
valve insulation, pipe insulation, and boiler in-
sulation (see Exhibit 2-3). Materials that were
highly likely to be identified accounted for most
of the quantity of material. For example, there is
an estimated 1.8 billion square feet of floor tile in
the schools, 245 million square feet of ceiling
surfacing material, and 65 million linear feet of
pipe insulation. The least frequently identified
suspect materials were vibration dampening
cloth, fire doors, duct insulation, and linoleum.
Less than 50 percent of these materials was
identified in the original AHERA inspections.
These least frequently identified materials tend
to be small quantity materials. Together, they
account for an estimated 59 million square feet
of suspect material present in schools, of which
only 19 million square feet is friable.
Despite the relatively high percentage of materi-
als identified and material quantities reported,
Exhibit 2-3.
Percent of suspect material quantities
identified
TSI (linear TSI (square Surfacing Miscellaneous
feet) feet)
Material type
82 percent of school buildings3 had at least one
material unidentified in the original AHERA in-
spection. As would be expected from the previ-
ous paragraph, the unidentified materials
tended to be the small quantity and nonfriable
materials, such as vibration dampening cloth or
fire doors. On the other hand, while ceiling tile
and floor tile are present in about 85 percent of
schools, they were not identified in 23 percent
and 11 percent, respectively, of the school
buildings containing them.
Estimation of Material Quantities. We exam-
ined the original AHERA inspector's ability to
provide accurate information about the quan-
tities of identified materials. Local Education
Agencies need reasonably accurate quantifica-
3Some schools have more than one building.
2-3
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AHERA EVALUATION
lions of the asbestos materials in their schools
to be able to estimate the costs of remediations.
In determining underestimated amounts of ma-
terial, we recognized that deviations in mea-
surement among inspectors are fairly broad.
Our expert consultants agreed that an original
AHERA inspection quantity within 20 percent of
the reinspection quantity should be considered
an acceptably accurate estimate. Further, un-
derestimated amounts calculated in this manner
would clearly be attributable to the original
AHERA inspector, rather than to differences in
such factors as material description or archi-
tectural nomenclature.
Original AHERA inspectors estimated the quan-
tity of each asbestos-containing material cor-
rectly in over 60 percent of buildings (see Exhibit
2-4).
Exhibit 2-4.
Percent of buildings with asbestos-containing
material quantity properly estimated
Percent of
buildings
Sq'Fl ' All Friable All Friable
TSI» Surfacing material Miscellaneous material
Suspect material category
*TSI is always considered friable; 83% of buildings had TSI measure in linear feet.
The overall quantity of asbestos-containing ma-
terial estimated properly ranged from 91 percent
(for thermal system insulation) to 45 percent (for
friable miscellaneous materials). Our estimates
for friable asbestos-containing miscellaneous
materials and TSI are both based on so little
data as to be subject to considerable error.
More buildings have properly estimated quanti-
ties of asbestos-containing surfacing materials
and thermal system insulation (about 75%) than
miscellaneous materials (about 50%).
Recording Material Locations. This section
continues the analysis of the original AHERA in-
spectors' ability to provide accurate information
about identified materials. It addresses the
question, "For materials which were identified at
the original AHERA inspection, was every area
where the material was present recorded?"
AHERA requires the locations of suspect mate-
rials to be clearly indicated in the management
plan by blueprints, diagrams, or written descrip-
tion so that school employees and parents can
have reliable information about the location of
asbestos-containing materials. In particular,
school maintenance workers should know
where to use appropriate work practices to pro-
tect themselves from potential exposure to as-
bestos fibers and where such work practices are
unnecessary. Clear records of the locations of
asbestos-containing materials and non-as-
bestos materials give workers information for
differentiating among similar materials.
Areas in school buildings were divided into three
types for this analysis: mechanical areas,
which include boiler rooms, elevator shafts,
mechanical rooms, air and duct shafts, tele-
phone closets, and electrical closets; limited
student access areas, which include offices,
supply rooms, teachers' lounges, janitors' clo-
sets, and kitchens; and general access areas,
which include classrooms, gymnasiums, audito-
riums, cafeterias, restrooms, and hallways.
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AHERA EVALUATION
Once a material was identified, original AHERA
inspectors recorded its location in 56 percent of
the areas where the material was present
(Exhibit 2-5). This reflects a tendency among
inspection reports to either not indicate areas
where materials are present or to do so incom-
pletely. There were no patterns of differences
between areas with limited student access and
general access areas in recording locations of
material.
Exhibit 2-5.
Percent of areas with suspect materials
present and recorded in management plans
80%
10%
60%
50%
Percent 40%
of ,._
areas30**
20*
10%
0%
-t-
H
All areas Mechanical areas General access Limited student
areas access areas
Type of area
For all three types of areas, surfacing and
miscellaneous suspect materials were recorded
in about 45 to 55 percent of the areas where
they were located. On the other hand, thermal
system insulation was significantly more likely
to be recorded in mechanical areas than in non-
mechanical areas. It was recorded in 74 percent
(± 10%) in mechanical areas, in 48 percent
(± 10%) of general access areas, and in 57 per-
cent (± 7%) of limited student access areas.
Assessment of the Asbestos-Containing Ma-
terial. This component of the AHERA evalua-
tion checks the internal consistency of the ma-
nagement plan's logic and whether it complies
with AHERA's assessment classification of ma-
terials. No comparisons were made between
assessment categories reported in the man-
agement plans and the categories observed in
the reinspection. Such comparisons would not
be valid because there were numerous oppor-
tunities for changes in the assessment category
in the year or two between the inspections.
Materials may have been repaired or removed
or, conversely, they may have suffered further
damage or deterioration.
The first part of this analysis considers how of-
ten asbestos-containing materials were assess-
ed appropriately in the original AHERA inspec-
tion. Assessment refers to the consideration of
factors that may contribute to increased fiber
release from a material. An assessment is
appropriate if, at a minimum, it considers the
condition of a material or amount of damage to
thermal system insulation and other friable
materials. An inappropriate assessment was
one in which a damage rating was not included.
AHERA regulations do not require nonfriable
materials to be assessed, although this was
occasionally done. Assessed nonfriable materi-
als were included in the count of total number of
materials assessed and were counted as ap-
propriately assessed. Ninety-two percent of the
asbestos-containing materials that should have
been assessed according to AHERA were in-
deed assessed and were assessed appropri-
ately.
The second part of this analysis addresses how
often the seven AHERA assessment categories
were employed in the original AHERA inspection
and how often they were appropriately assign-
ed. An appropriate assessment means the ori-
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AHERA EVALUATION
ginal AHERA inspector assigned the AHERA
catgory number (1 through 7) or wording cor-
rectly, based on material type, reported amount
of damage at the original inspection, and report-
ed potential for damage. Forty-four percent of
original AHERA inspections used the AHERA
categories. Of those inspections which used the
categories, 93 percent applied them appropri-
ately.
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AHERA EVALUATION
3. MANAGEMENT PLAN
EVALUATION
Do schools know and understand the regulation, as
shown by the completeness of the management plan?
his Research Area seeks to evaluate
management plans nationwide. Westat
considered five aspects of each management
plan:
Completeness
Usability
Detractions to use
Correct use of terms
Educational background required to
interpret plan
Completeness. In consultation with technical
consultants and two senior certified industrial
hygienists (CIH), Westat designed and imple-
mented a methodology to score each plan for
completeness. The scores provided a method
of comparing management plans from different
schools. The methodology awarded points for
the presence of selected features called for in
the EPA's guidance documents for manage-
ment plan preparers (see six sub-areas listed in
Exhibit 3-1). The points were converted to
scores ranging from 0 to 100 percent. All scor-
ing was assigned by two senior CIHs who are
also trained AHERA inspectors and manage-
ment planners with many years of experience in
asbestos abatement and inspection.
Based on the six subscores, an overall score
was computed for the total management plan.
The relative importance of each sub-area is re-
flected in its contribution to the overall score.
For example, 6 percent of points in the overall
score are based on the general inventory of
buildings. The sub-areas, the relative impor-
tance of each, and the average score for the
sub-area are provided in Exhibit 3-1.
Exhibit 3-1. Management plan completeness scores by sub-area
Sub-area of Completeness Score
General inventory of buildings
Exclusions and previous inspection information
Response action recommendations
Activity plans
Resource evaluation
Information on AHERA designated person
Overall
Relative
Importance
6%
42%
18%
24%
6%
4%
100%
Average
Score
92%
77%
77%
79%
82%
86%
81%
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AHERA EVALUATION
As shown in Exhibit 3-2, in regard to the overall
score, management plans were generally com-
plete with an overall average score of 81 per-
cent. Most scored 75 percent or higher. How-
ever, 5 percent (± 4%) of management plans
scored 64 percent or below, making it clear that
a few plans, even with Federal and State guide-
lines, were substantially incomplete. Points
were most commonly lost for items that were
not clearly defined in AHERA, or where State-re-
quired AHERA forms and checklists failed to
prompt for the specific information.
Exhibit 3-2.
Management plan completeness scores
50X-
40%-
20 30 40 50 60 70 BO
Normalized overall score
90 100
Of particular interest and importance were the
findings concerning the use of exclusion and
previous inspection information. This was the
single most important area evaluated for com-
pleteness in the plan. While a majority of the
plans received the maximum points allowed un-
der this heading, deficiencies were clustered in
the areas that follow. (The percentage of plans
nationally with the named deficiency are noted
in parenthesis. The last two deficiencies were
observed but not quantified.)
Location of homogeneous areas not
clearly described (42%)
Nonstandard or insufficient identification
of material type (55%)
Insufficient description of bulk sampling
locations (66%)
Bulk samples collected from incorrect or
undescribed locations (33% TSI, 58%
surfacing)
Date of analysis of bulk samples missing
(31%)
Failure to meet AHERA requirements
when previous inspection results were
used in the original AHERA inspection
Insufficient evidence of EPA-approved
accreditation for laboratories evaluating
bulk samples
Usability. The second aspect of the manage-
ment plan evaluation concerned usability.
Westat evaluated how useful a plan would be
and whether it could easily be used as a refer-
ence by its intended audiences, the public, and
custodial and maintenance workers. We looked
at seven elements of usability that would ease
use of a management plan, such as table of
contents, page numbering, and floorplans
showing sampling locations, homogeneous
areas, or ACBM. None of these elements is re-
quired by AHERA.
None of the plans contained all seven elements,
and 7 percent contained no elements of usabil-
ity. Exhibit 3-3 displays the distribution of plans
with increasing numbers of usability elements.
3-2
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AHERA EVALUATION
The curve begins at 100 percent, indicating the
percentage of plans with zero or more elements.
The curve drops to 93 percent to reflect the
number of plans with one or more elements,
and further drops to 76 percent representing the
number with two or more elements. The curve
ends at 0 percent, reflecting the fact that no
plans have all seven elements.
Exhibit 3-3.
Number of usability
elements found in management plans
Percent of
schools
0 or 1 or 2 or 3 or 4 or 5 or 6 or all 7
more more more more more more more
Usability elements
Detractions to Use. Beyond the usability ele-
ments, Westat went further to identify the fea-
tures of plans that detracted from their use. Ex-
amples are an unclear inspection report, failure
to use AHERA categories when assessing
ACBM, failure to explain standard forms, and
lack of floorplans. In total, 69 percent (± 9%) of
the plans had one or more features that de-
tracted from their ease of use.
Correct Use of Terms. Westat further found
that plans often used four AHERA-defined terms
incorrectly. These terms are "homogeneous
area", "functional space", "exclusion", and
"random sampling". For these four critical
terms, 37 percent (± 9%) of the schools used all
four correctly, 46 percent used no more than
three correctly, and 12 percent used only two
correctly. Five percent used one or none cor-
rectly.
Ease of Plan Interpretation. With regard to
ease of reading and understanding the plans,
we found that 39 percent (± 5%) of plans were
readily interpretable only by persons who had
some college coursework; 22 percent (± 6%)
required that the reader had specialized in-
struction in the use of the plan. Only 39 percent
(± 6%) of plans could be readily interpreted by
those with a high-school education or less. Of
those people who should be expected to under-
stand plans better -- school principals and cus-
todial workers -- a sound background in AHERA
inspections appeared more helpful than knowl-
edge of the building being reviewed.
3-3
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AHERA EVALUATION
4. RESPONSE ACTION
EVALUATION
What response actions were recommended in the management
plan?
Are they appropriate, given the assessed condition of the asbestos?
Have the remediations undertaken in the school been done
properly?
T
his Research Area is divided in three
sections corresponding to the above
questions. First, Westat analyzed the presence
and type of response actions included in man-
agement plans. Second, experts evaluated
whether the recommended responses quoted in
the plans were appropriate for the type and
severity of the problem as identified by the origi-
nal AHERA inspection. Third, on-site inspectors
evaluated whether the actions taken (i.e.,
"remedia-tions" taken) were done properly. The
first two questions study response actions which
included repair, encapsulation, enclosure, re-
moval, and the implementation of an Operations
and Maintenance (O&M) Plan. By contrast, the
third question concerns only remediations, de-
fined as repair, encapsulation, enclosure, and
removal. Remediation does not include O&M.
Presence and Type of Response Actions in
Plans. Seventy-one percent (± 6%) of the plans
in our survey included recommendations for re-
sponse actions. That is, response actions were
included in plans of 126,282 of the estimated
179,093 school buildings with asbestos-con-
taining building materials (ACBM). As shown in
Exhibit 4-1, recognizing that each plan could
contain multiple recommendations, we found
that 55 percent (± 7%) of the recommendations
called for handling problems through regular
Operations and Maintenance techniques; 33
percent (± 8%) called for repair of the damaged
areas; 10 percent (± 2%) called for removal of
materials; and 2 percent (± 4%) recommended
encapsulation.
The distribution of recommended response ac-
tions varied with the type of ACBM. For exam-
ple, repair of damaged materials was recom-
mended for 56 percent (± 5%) of the occur-
rences of thermal system insulation. In contrast,
Operations and Maintenance was recom-
mended for miscellaneous materials in 93 per-
cent (± 4%) of the cases.
4-1
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AHERA EVALUATION
Exhibit 4-1.
Recommended response actions
Encapsulation
Repair
O&M
Removal
These results all pertain to the 71 percent of the
schools with ACBM whose plans include some
recommended actions. Of concern are the
plans in the 29 percent (± 18%) of the schools
which had no recommended actions despite the
documented presence of ACBM. In almost all
cases these schools had reported having
miscellaneous ACBM; in a few cases the as-
bestos was surfacing and/or TSI.
Appropriateness of Response Actions Re-
commended. Ninety-eight percent (± 1%) of
recommended response actions were appropri-
ate, that is, they were in accordance with
AHERA, given the reported condition of the
material. Examples of appropriate response ac-
tions are the recommendations of repair for
damaged TSI, encapsulation of a damaged area
of acoustical ceiling, and removal of asbestos-
containing ceiling tiles. Examples of inappropri-
ate response actions are recommendations of
O&M for damaged pipe insulation or signifi-
cantly damaged floor tile.
The finding that nearly all recommended re-
sponse actions were appropriate must be tem-
pered, though, by the observation that many of
these recommendations (80%) were generic
and failed to specify the locations where the re-
sponse action should be performed. Response
actions were considered generic if, for example,
they recommended removal of all damaged
material without indicating its locations. Exam-
ples of generic recommendations are "repair
damaged pipe elbow insulation" or "enclose or
encapsulate damaged ceiling tile," where the lo-
cation of the material is not specified. Generic
recommendations provide much less useful
guidance to the school than specific recom-
mendations.
A similar picture emerged when we computed
our findings based on the number of buildings
with ACBM instead of the number of recom-
mendations. Ninety-eight percent (± 1%) of the
buildings had appropriate response actions
recommended, and 70 percent (± 9%) of the
buildings had generic recommendations.
Evaluation of Remediations Conducted. An
estimated 246,260 remediations were per-
formed in approximately 36,390 school build-
ings, through Spring 1990. This represents 21
percent of the nation's school buildings with
ACBM.1 As shown in Exhibit 4-2, 16 percent of
the nation's school buildings have had one or
more removals of ACBM, while 6 percent have
had some ACBM repaired, and fewer have had
encapsulation or enclosure. Ninety-two percent
(± 7%) of the remediations that were visually
evaluated were judged to be adequate.
1 Remediation includes enclosure, encapsulation,
removal, and repair and does not include Operations
and Maintenance.
4-2
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AHERA EVALUATION
Exhibit 4-2.
Percent of school buildings with 1 or more
remediations
25% -r
20% --
15% --
Percent of
buildings
10% --
5X--
0%
Al biddings Enclosure Encapsulation Removal Repair
However, Exhibit 4-3 shows that only 12 percent
(± 12%) of the 4,376 performed enclosures
were adequate. When "buildings" is the unit of
analysis, inadequate remediations were found in
17 percent of school buildings where we were
able to visually evaluate remediation efforts.
Exhibit 4-3.
Adequacy of remediations
100% i
90%-
80%-
70%-
60%-
Percent of -
remediations
40%
30%
20%-
10%-
rw .
4
I
I
4
Enclosure* Encapsulation* Removal*
Visual determination of adequacy only.
Many methodological issues were encountered
in the evaluation process. Foremost, the reme-
diations studied occurred up to two and one-half
years ago. Only the results of each remediation,
and not the process, could be evaluated. Se-
cond, there are no industry-wide procedures or
guidelines for assessing remediations. Even
though guidelines were developed for this study,
our trained inspectors were frequently asked to
make judgments in the field. Finally, this study
categorized remediations in four categories -
enclosure, encapsulation, removal, and repair.
There are few industry-wide definitions of these
terms, and they are not mutually exclusive.
4-3
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AHERA EVALUATION
5. 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?
T
his Research Area required a compari-
son of the reinspection findings and the
findings presented in the management plan.
Westat performed this comparison by assigning
each inspection a rating using a scoring system
developed by the EPA and the research team in
consultation with our technical consultants. The
original AHERA inspectors were then inter-
viewed by telephone to gather information about
their education, experience, and background.
Where more than one inspector performed the
original AHERA inspection, only the most senior
inspector was interviewed. Statistical analyses
of the relationship between the inspection
scores and the inspectors' backgrounds were
conducted.
We found no statistically significant associa-
tions between any measured characteristic
(e.g., education) of the inspectors and the in-
spection scores. We suspect that this negative
finding occurred because all of our information
on the original AHERA inspections was obtained
from reviews of the management plans. Many
inspection companies use standard inspection
forms and pre-programmed management plan
outlines and shells. These standard forms and
the outlines tend to cancel out much of the vari-
ation among individual inspectors which, in turn,
negates the effects of their backgrounds.
As shown below, sub-elements of this compari-
son - the ratings found for the AHERA inspec-
tions and the assessment of inspectors back-
grounds - were interesting in their own right.
The inspection scoring system developed for
this Research Area identified six factors to mea-
sure dimensions of the quality of the inspection
and rated each material found using these crite-
ria. 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
these six components. The percentage follow-
ing each factor represents the frequency with
which each criterion was met.
5-1
-------
AHERA EVALUATION
The items are listed in descending order of
importance.
Was the suspect homogeneous material
identified? (70%, ± 5%))
Was the material assessed appropriately?
(67%, ± 4%)
Did the inspector identify at least 80 per-
cent of the areas in the school with the
material? (42%, ± 7%)
Was at least 80 percent of the material
quantified? (41%, ± 8%)
Were the correct number of bulk samples
taken? (68%, ± 5%)
Were the AHERA designated assessment
categories used appropriately? (31%,
± 6%)
These findings are consistent with those in
Chapter 2 where we reported that 70 percent of
all homogeneous suspect materials was identi-
fied by the original AHERA inspectors. Once a
material was identified, nearly all inspectors as-
sessed it appropriately and took the correct
number of bulk samples. Approximately 60
percent of materials was adequately located and
quantified.
The material scores were then averaged to ob-
tain a school average inspection score. The
percentage of inspections in each score cate-
gory is listed below.
16% Thorough inspection
On average, 16 percent (± 5%) of in-
spections satisfied the four most impor-
tant components, but may have failed on
one or both of the other two
components.
46% Some deficiencies
On average, 46 percent (± 10%) of in-
spections satisfied the two most impor-
tant factors, but failed either to accurately
quantify the material or to adequately lo-
cate it.
17% Deficient
On average, 17 percent (± 6%) of in-
spections satisfied the two most impor-
tant factors, but neither accurately quan-
tified the material nor adequately located
it.
21% Serious deficiencies
On average, 21 percent (± 6%) of in-
spections failed to identify the material or
assess it appropriately. Inspections may
have also failed to adequately quantify or
locate the material.
Exhibit 5-1 displays the average scores graphi-
cally.
Exhibit 5-1.
School Average Inspection Scores
Serious
deficiencies
Thorough
inspection
Deficient
Some
deficiencies
5-2
-------
AHERA EVALUATION
The primary causes of deficient inspections
were failure to identify all suspect material in a
school, to record the locations of the ACBM, or
to quantify it within acceptable standards of ac-
curacy. The percentage of "thorough inspec-
tions" declines as the number of materials in-
creases, from 29 percent (± 12%) in schools
with one to five materials, to 8 percent (± 8%) in
schools with nine or more materials. Similarly,
the percentage of "seriously deficient" scores in-
creases as the number of materials increases.
The methodology used to create average in-
spection scores balanced competing concerns.
The system began with a score applied to each
homogeneous suspect material identified in the
reinspection. Extreme care was taken to ac-
count for differences in inspection terminology,
protocol, and reporting format. To allow some
leeway, credit was given if the original AHERA
inspection reported a material present in at least
80 percent of the areas in which the reinspection
found the material. Likewise, credit was given if
the original AHERA inspection reported a total
quantity of a specific material which was within
20 percent of the quantity found by the rein-
spection. Finally, the scoring procedure gave
full credit to the original inspection when as-
bestos materials had been totally removed or
otherwise abated.
Inspector Experience. All original AHERA
inspectors had AHERA accreditation, had
conducted asbestos inspections for a median
14 months, and had inspected a median 45
schools. In addition, 65 percent (± 10%) had
non-AHERA training in asbestos, 50 percent had
finished college, and 46 percent had experience
in building trades, environmental occupations,
architecture, or engineering. A few inspectors
were professional engineers (PE), certified in-
dustrial hygienists (CIH), registered architects
(RA), or certified safety professionals (CSP).
5-3
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AHERA EVALUATION
6. PROCESSOR
NOTIFICATION
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 staff reactions be to differently worded
notification letters?
T
he goal of this Research Area was to
study parent and teacher reactions to
notification. Through interviews and focus
groups with principals, teachers, and with
parents who are active in their school's PTA, the
topic of notification was studied with consistent
results. In general, while principals recalled no-
tifying parents about the presence of a man-
agement plan, parents and teachers often did
not recall either being notified or the contents of
the notification. Specifically, 50 percent of
parents and 23 percent of teachers said they did
not receive or remember receiving notification
about AHERA. By contrast, 82 percent of prin-
cipals said that they had sent these notifications.
In the schools where school principals did recall
notification, 66 percent (± 10%) reported that
parents were notified more than once. How-
ever, of those who remembered being notified,
teachers in 62 percent (± 8%) of schools and
parents in 51 percent (± 8%) of schools recalled
being notified more than once.
Letters were the most common notification
method. For those who recalled being notified,
there were some serious differences in princi-
pals' and parents' recall of the presence of vari-
ous important elements in the notifications.
While 84 percent (± 7%) of principals recalled
notifying parents of the availability of a man-
agement plan, parents recalled that only 27 per-
cent (± 7%) of schools sent this information.
In the focus groups, Westat learned that both
parents and teachers believe letters are the
most effective method of notification, particularly
if mailed rather than hand-delivered to parents
by students. -
6-1
-------
AHERA EVALUATION
Both the survey and the focus groups showed
that parent reactions to notification tended to
be slight. According to the survey, parents in
less than 20 percent of schools reacted to notifi-
cation 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 predicted that they would react, both in the
survey and focus groups, the range of actions
was very small. They included only such activi-
ties as reviewing the management plan, calling
the ADP for additional information or, at the
most severe, requesting that a discussion of as-
bestos be added to a meeting agenda.
Through the use of focus groups, Westat also
explored preferences for types of notification.
Both parents and teachers were eager for a
more thorough level of notification than they had
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 ADP (or other school
representative such as the principal), a descrip-
tion of any planned response actions and the
associated timetable, and brief but informative
health risk information.
6-2
-------
AHERA EVALUATION
7. MAINTENANCE & CUSTODIAL
WORKER TRAINING
AND EXPERIENCE
Are maintenance and custodial workers trained to work with and
around asbestos?
What topics were included in this training?
m What tasks relative to asbestos or suspect ACBM are regularly required
of maintenance and custodial workers, and do these tasks correspond
to the level of training received?
T
his Research Area assessed the level of
training and types of work responsibil-
ities of maintenance and custodial personnel.
Two different research methods were used: in-
person interviews with AHERA designated per-
sons and a qualitative data collection effort. The
qualitative effort consisted of focus group inter-
views in five locations with maintenance workers
and custodians from schools where asbestos
was present. In each group there was a mix of
maintenance workers and custodians who
worked in various types of schools.
Maintenance workers, by definition, are
responsible for repair and upkeep of systems
such as plumbing, heating ventilation, and air
conditioning. Custodians by definition are
responsible for janitorial jobs and, in some
cases, minor maintenance such as changing
light bulbs. AHERA requires 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 two 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 addi-
tional training beyond that required for aware-
ness (a total of 16 hours).
Even though a person is classified as a mainte-
nance worker, he or she may not perform the
traditional maintenance worker activities. Con-
versely, custodians in some schools perform
more traditional maintenance worker activities.
7-1
-------
AHERA EVALUATION
Training of Maintenance and Custodial
Workers
The first question in this Research Area consid-
ered training of maintenance and custodial
workers. The issues were addressed through
an in-person survey of the ADP from each sam-
pled school and through focus groups with
maintenance and custodial workers.
Survey Results. The survey results presented
for this Research Area are based on the esti-
mated 83,840 schools nationally that performed
an AHERA inspection, found asbestos-contain-
ing materials, and wrote a management plan.
The level of training reported by the ADPs may
not reflect that actually received by maintenance
workers and custodians. The ADPs may be
motivated to overreport the number of training
courses to show a greater level of compliance
with the AHERA regulation than actually oc-
curred. Also, there may be a difference between
the percentage of schools that offer training and
the percentage of maintenance workers and
custodians actually trained (e.g., due to absen-
teeism, not all maintenance workers or cus-
todians in a school will be trained through any
given course).
In general, ADPs reported that the length of
training received by maintenance workers was
somewhat below that required by AHERA for
workers who work directly with ACBM. Specifi-
cally, 87 percent (± 9%) of schools provided
asbestos-related training to maintenance work-
ers in the post-AHERA period, while 7 percent
(± 5%) offered no training, and 7 percent
(± 6%) of schools did not have this type of em-
ployee (see Exhibit 7-1).
Exhibit 7-1.
Percent of schools providing some
training to maintenance workers
No training
Training provided
No maintenance workers
Training for custodial workers was not statisti-
cally different than that for maintenance workers.
Ninety-five percent (± 6%) of schools had con-
ducted training classes that met the AHERA re-
quirement for awareness training for custodial
workers since October 1987 (Exhibit 7-2). Three
percent offered no training, and 2 percent of
schools did not hire any custodians.
Exhibit 7-2.
Percent of schools providing some
training to custodians
No
training
No custodians
Trailing provided
7-2
-------
AHERA EVALUATION
Schools that did not provide training may not
employ staff requiring training under AHERA.
For instance, if a worker's responsibilities do not
require work in a building with ACBM, he or she
may not require training. Statistical information
about worker responsibilities cannot be learned
from the AHERA evaluation.
A closer look at the training of maintenance and
custodial workers employed by the school dis-
trict shows that 85 percent (± 10%) of schools
have conducted both maintenance worker and
custodial training since October 1987. Three
percent (± 3%) of schools have not trained ei-
ther their maintenance or custodial workers at
all.
The duration of training received by custodians
and maintenance workers varied. Twenty-two
percent (± 5%) of schools that trained their
maintenance workers provided 16 or more
hours of training. AHERA requires 16 hours of
training for staff with traditional maintenance
worker responsibilities in schools in which as-
bestos-containing materials were found. Work-
ers not required to work in any buildings with
ACBM could require less than the 16-hour
training mandated by AHERA.
Eighty-nine percent (± 5%) of schools trained
custodians two hours or longer or, stated differ-
ently, nine out of ten schools' custodial training
courses are in compliance with the AHERA
guidelines for the length of awareness training
required for workers who do not come into
contact with ACBM. Exhibit 7-3 shows that five
percent (± 6%) of the courses were under two
hours, indicating that a small percentage of
schools does not meet the minimum length re-
quirement for AHERA awareness training. On
the other hand, 12 percent (± 8%) of custodians
received a 16-hour training, indicating the
school's awareness that some custodial work-
ers do come into direct contact with ACBM.
Exhibit 7-3.
Percent of schools providing various lengths
of training to maintenance and custodial
workers
< 2 hours 2 hours
I Maintenance workers O Custodians
3-15
hours
>= 16 No training No workers
hours
Maintenance and Custodial Worker Focus
Group Results. A majority of the maintenance
workers who participated in the focus groups
reported receiving at least the AHERA-required
hours of training, given their specific job respon-
sibilities. However, there were workers who
work with and potentially disturb ACBM and re-
ceived only an awareness training. These
workers' training did not meet AHERA re-
quirements relative to their job responsibilities.
In addition, there were few maintenance workers
who received no training at all, but were simply
told not to work near asbestos. Since these
workers reported working in buildings with
ACBM, they should have received an awareness
course at a minimum.
7-3
-------
AHERA EVALUATION
Most custodians reported receiving two to four
hours of training since October 1987 and thus
met or exceeded the required level of awareness
training. However, many custodians also re-
ported disturbing ACBM and said they had not
received the AHERA-required 16-hour minimum
training.
Curriculum of Training
The second question in this Research Area con-
sidered training curriculum and was addressed
through in-person interviews with ADPs and fo-
cus group discussions with maintenance and
custodial workers. Survey results are presented
for schools that employ their own maintenance
and custodial workers.
Survey Results. This study examined course
content from the perspective of whether training
included a description of the locations of ACBM.
Up to 25 percent (± 8%) of schools did not
include such a description for their maintenance
workers. Moreover, 18 percent (± 7%) of the
schools did not describe the locations of ACBM
to their custodians.
Of the courses that did provide location descrip-
tion, three methods stand out. The most com-
mon method of presentation was through a ver-
bal description of the locations of ACBM in the
school. Ninety-two percent (± 4%) of the
schools used this method in training mainte-
nance workers, while 91 percent used it for
training custodians (± 5%). The second most
common method was presenting the floorplan
of the building [81% (± 10%) for maintenance
workers and 75% (± 11%) for custodians].
Third, approximately half of the schools pro-
vided a walkthrough to both types of workers.
These methods do not total 100 percent as
schools often used more than one training
method.
Maintenance and Custodial Worker Focus
Group Results. Many maintenance workers
and custodians reported course content as con-
sistently containing similar items. Maintenance
workers who received 16 hours of training were
told about the health effects of asbestos and
were presented the standard information for an
awareness course. Most were shown some
safety procedures to follow when working
around asbestos. Whenever films, videos, or
slides were used, a knowledgeable person was
present to answer questions. In a few situations
the workers recalled that the location of ACBM
was discussed during the training.
Based on discussion in the focus groups, it
appears that the curriculum meets the require-
ments outlined by AHERA, though the lack of
knowledge about specific locations of ACBM
suggests that it may be inadequate for promot-
ing good work practices.
Many of the participants stated that they did not
believe they retained much of the training infor-
mation.
Approximately half the maintenance workers re-
ceived training on respirator use, learning how
to perform positive and negative pressure test-
ing. However, 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 exami-
nation and other requirements for respirator use.
No custodians, whatever their responsibilities
around ACBM, reported receiving respirator
training or having access to a respirator.
7-4
-------
AHERA EVALUATION
Tasks Required of Maintenance and
Custodial Workers
The third question in this Research Area consi-
dered the tasks relative to asbestos or suspect
ACBM regularly required of maintenance and
custodial personnel, and whether tasks corres-
ponded to the level of training received. This
topic was addressed solely through focus group
discussions with maintenance and custodial
personnel.
Maintenance and Custodial Personnel Focus
Group Results. Although the length of training
appears adequate for both types of workers, the
focus group findings show that frequent unpro-
tected and inappropriate work practices are
used in schools in the five communities in which
focus groups were held. On the whole, these
inappropriate work practices were performed
while cleaning up fiber release episodes of less
than three linear or square feet, or as routine
maintenance/custodial activities. Because the
workers were unaware that a material might
contain asbestos, because of inadequate or no
training, or because of pressure to act immedi-
ately in an "emergency" situation (such as a
leaking roof), it is almost certain that exposure
to asbestos occurs and that appropriate proce-
dures are followed in only a few cases. Most
workers did not express concern that they might
disturb asbestos and create 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 da-
maged.
Many maintenance and custodial workers re-
ported being concerned about the security of
their jobs if they "say anything about asbestos"
or take the time to follow appropriate working
practices around asbestos. Only one mainte-
nance worker claimed to have faced the loss of
his job over asbestos issues, though other
workers expressed concern for job security.
7-5
-------
AHERA EVALUATION
8. GLOSSARY
ACBM: Asbestos-containing building material is
surfacing ACM, thermal system insulation ACM,
or miscellaneous ACM that is found in or on in-
terior structural members or other parts of a
building.
ACM: Asbestos-containing material is, when
referring to school buildings, any material which
contains more than one percent asbestos.
Activity Plans: Written procedures in a school's
management plan which detail the steps an LEA
will follow in performing the initial and additional
cleaning, operations and maintenance program
tasks, periodic surveillance, and reinspections
required by AHERA.
AHERA Designated Person (ADP): A person
designated by the Local Education Agency to
ensure that the AHERA requirements are pro-
perly implemented.
Assessment (1-7): Evaluation of the physical
condition and potential for damage of all friable
ACM and thermal system ACM. AHERA re-
quires classification of each ACBM assessed
into one of seven categories based on material
type and damage/potential for damage.
Bulk Sample: A small portion (usually about
thumbnail size) of a suspect asbestos-
containing building material collected by the as-
bestos inspector for laboratory analysis to de-
termine asbestos content.
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 airtight, impermeable, perma-
nent barrier around asbestos-containing mate-
rial to prevent the release of fibers.
Exclusion: 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.
Friable: Material that, when dry, can be crum-
bled, pulverized, or reduced to powder by hand
pressure.
Functional Space: Under AHERA, a room,
group of rooms, or homogeneous area desig-
nated by a person accredited to prepare man-
agement plans, design abatement projects, or
conduct response actions.
Homogeneous Area: In accordance with
AHERA definitions, an area of surfacing mate-
rial, TSI, or miscellaneous material that is uni-
form in color and texture.
Local Education Agency (LEA): An educa-
tional agency at the local level that exists pri-
marily to operate schools or to contract for edu-
cational services. This includes primary and se-
condary public and private schools.
8-1
-------
AHERA EVALUATION
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, in-
cluding: building inspections to identify
asbestos-containing materials, response ac-
tions, and operations and maintenance pro-
grams to minimize the risk of exposure to as-
bestos in school buildings.
Material Category: Broad classification of sus-
pect materials into TSI, surfacing material, and
miscellaneous material.
Material Type: Classification of suspect mate-
rial by its specific use or application, e.g., pipe
insulation, fireproofing, and floor tile.
Miscellaneous Material: Interior building mate-
rial on structural components, such as floor or
ceiling tiles. Does not include TSI or surfacing
material.
Operations and Maintenance Program
(O&M): Program of work practices to maintain
friable ACBM in good condition, ensure cleanup
of asbestos fibers previously released, and pre-
vent future release by minimizing and controlling
friable ACBM disturbance or damage.
Original AHERA Inspection/Original Inspec-
tion/Inspection: Examination of school build-
ings arranged by Local Education Agency, pur-
suant to AHERA, to identify asbestos-containing
materials, evaluate the condition of those mate-
rials, and take samples of materials suspected
to contain asbestos. Inspections are to be per-
formed by inspectors accredited by the EPA.
OSHA: Occupational Safety and Health
Administration.
PSU: Primary Sampling Unit, a geographic
area, usually a county or group of counties, de-
fined by the Census Bureau for survey sampling
purposes.
Random Sample: Method of collecting bulk
samples of asbestos that assures statistical ran-
domness.
Reinspection: The examination of homo-
geneous materials in which an original AHERA
inspection has been performed previously. For
this study, reinspections were performed without
knowledge of the results of the original AHERA
inspection.
Remediation: For the AHERA evaluation, re-
pair, encapsulation, enclosure, or removal of
greater than 3 linear feet or square feet of
ACBM.
Removal: The taking out or stripping of ACBM
from an area, a functional space, or a homo-
geneous area.
Repair: Procedures used to patch or cover
damaged asbestos-containing materials other
than enclosure or encapsulation. Examples in-
clude covering the damage with plastic sheet-
ing, duct tape, or plaster.
Response Actions: Any of the following ac-
tions taken in school buildings in response to
AHERA, to reduce the risk of exposure to as-
bestos in school buildings: removal, encapsula-
tion, enclosure, repair, and Operations and
Maintenance.
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AHERA EVALUATION
Surfacing Material: Material sprayed or trow-
eled onto structural members (beams, columns
or decking) for fire protection; or on ceilings or
walls for fireproofing, acoustical or decorative
purposes. Includes fireproofing, textured
plaster, and other textured wall and ceiling sur-
faces.
Suspect Material: Building material suspected
of containing asbestos because of past prac-
tices in its manufacture and use; includes sur-
facing material, floor tile, ceiling tile, thermal
system insulation, and miscellaneous other
materials. Suspect materials are classified as
ACM or non-ACM by analyzing bulk samples to
determine asbestos content.
TSI: Thermal System Insulation; i.e., in-
sulation applied to steam and hot and cold
water systems and HVAC systems to prevent
heat transfer and water condensation. Includes
pipe insulation; pipe joint, valve, fitting and
elbow insulation; and insulation applied to
boilers, water tanks, compressors, air-handling
equipment, radiators, ducts, etc.
8-3
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