United States
Environmental Protection
Agency
Toxic Substances
Office of
Toxic Substances
Washington, D.C. 0460
EPA 560/5-84 005
October 1984
                    Evaluation
                      of the
          ASBESTOS-IN-SCHOOLS
                Identification and
                Notification Rule

-------
                                             October  1984
       EVALUATION OF THE EPA ASBESTOS-IN-SCHOOLS
         IDENTIFICATION AND NOTIFICATION RULE
                          by
                   Janet Greenblatt
                     Westat, Inc.
                1650  Research Boulevard
              Rockville, Maryland   20850
           Subcontract No. A-3043(8149)-270
            BATTELLE COLUMBUS LABORATORIES
                 Washington  Operations
                 2030 M Street, N. W.
               Washington, D. C.  20036
                Contract No.  68-01-6721
    Cindy Stroup and Joseph J.  Breen,  Task Managers
Joseph S.  Carra and Frederick W.  Kutz, Project Officers
             Exposure Evaluation Division
       Office of Pesticides and Toxic  Substances
         U.  S.  Environmental Protection Agency
               Washington, D. C.  20460

-------
                           DISCLAIMER
     This report was prepared under contract to an agency of the
United States Government. Neither the United States Government nor
any of its employees,  contractors,  subcontractors,  or  their em-
ployees makes  any warranty,  expressed or implied,  or assumes any
legal liability or responsibility for  any third party's use of or
the results of such use of any information, apparatus, product, or
process disclosed in this report, or represents that its use by such
third party would not infringe on  privately owned  rights.

-------
                        ACKNOWLEDGEMENTS
     The author of  this report would like to thank all those whose
efforts contributed to the  success of the survey.  We acknowledge
with gratitude  the people from  the  EPA who  provided  technical
assistance and administrative support:  Cindy Stroup, Joseph Breen,
Joseph Carra and Frederick Kutz.  Connie DeRocco of OTS reviewed the
questionnaire at critical  stages in  its  creation.   Dave  Mayer
participated in several aspects of the study including review of the
questionnaire as well as training of  telephone  interviewers and
field investigators.  We would also like to thank Wolfgang Brandner
for his assistance  in training  the field  investigators.   David
Morganstein of  Westat and Bertram Price of Battelle contributed to
the planning stages of the survey. For  overall project management
support the author  thanks  David  Cox of  Battelle and Stephen Dietz
of Westat.   Additional administrative  support  was provided  by
Robert Learmonth of Westat.

     The success of the project depended directly on the staff that
performed the various tasks.  In particular the author wishes to
acknowledge:  Barbara Kreling of Westat who supervised the tele-
phone survey operations assisted  by Susan Englehart in the Westat
Telephone Research  Center; John Edmonds and Dahlia Kahane of Westat
who programmed  the  statistical analysis tables; and Joan Fried and
Mary Tarkowski  of Westat and Marilyn Gabriel of Midwest Research
Institute who conducted the field investigations.
                               111

-------
                         TABLE OF CONTENTS

SECTION                                                     PAGE

       EXECUTIVE SUMMARY	    ix


  1    INTRODUCTION 	    1-1
         Background	    1-1
         Survey Objectives  and Design 	    1-4


  2    CONCLUSIONS	    2-1

  3    QUALITY ASSURANCE PROGRAM	    3-1
         Sample Selection 	    3-1
         Data Collection	    3-2
         Response Rates 	    3-2
         Data Validation and Processing	    3-4
         Site Visits to LEAs	    3-4
         Results of Site Visits	    3-6
         Results of Comparison of Compliance Monitoring
         Efforts with Questionnaires for Selected LEAs. .    3-12

  4    SAMPLE DESIGN	    4-1
         Construction and Stratification of the Frame . .    4-1
         Probability Sample Design	    4-1
         Sample Size Specification	    4-2
         Precision of the Estimates	    4-2


  5    STATISTICAL ANALYSES OF TELEPHONE SURVEY DATA. . .    5-1
         Weighting	    5-1
         Variance Estimation	    5-2
         Results of Statistical Analyses	    5-3

  6    METHODOLOGICAL REPORT	    6-1
         Overview of Survey	    6-1
         The Questionnaire	    6-2
         Pretest	    6-3
         Interviewer Training 	    6-4
         Survey Response and Follow-Up Procedures ....    6-4
         Telephone Quality Control and Data Retrieval  . .    6-5
         Data Processing	    6-6
                                 v

-------
                  TABLE OF CONTENTS (continued)




                       LIST OF APPENDICES




SECTION                                                     PAGE




  A    STATISTICAL TABULATIONS	   A-l




  B    QUESTIONNAIRE   	   B-l




  C    INTERVIEWER PROCEDURES MANUAL  	   C-l




  D    QA VISIT FIELD MANUAL   	   D-l
                                 Vl

-------
                  TABLE OF CONTENTS (continued)

                         LIST OF TABLES


Number                                                      Page

  1       Results of site visits to LEAs	3-8

  2       Results of site visits to and inspections
          of schools	3-10

  3       Results of comparison of  EPA compliance
          monitoring reports to LEA questionnaires  	  3-14

  4       Coefficients of variation, standard errors,
          and confidence boundaries for selected totals.  .  .  5-4

  5       Characteristics of public and private  LEAs
          as of January, 1984	5-7

  6       For LEAs claiming exemption to rule, reason
          for exemption	5-8

  7       The use of the EPA Technical Assistance
          Program	5-10

  8       Number of LEAs that had and used EPA guidance
          documents to conduct inspections 	  5-11

  9       LEAs with and without Form 7730-1,  "Inspections
          for Friable Asbestos-Containing Materials" ....  5-12

 10       LEAs that complied with the Asbestos-in-Schools
          Rule	5-14

 11       Asbestos-In-Schools Rule requirements  to be met
          by June 28, 1983	5-15

 12       Compliance requirements for LEAs that  met
          most aspects of the Rule	5-15

 13       Areas of noncompliance with most aspects
          of the Asbestos-In-Schools rule by January 1984. . 5-16

 14       Results of inspections in schools
          as of January, 1984	5-17

 15       Total square footage, employees and students
          in schools with asbestos-containing friable
          materials and total square  footage by
          abatement work completed  	 5-18
                               VII

-------
                   TABLE OF CONTENTS  (continued)

                           LIST OF TABLES


Number                                                      Page

 16       Percent asbestos-containing friable materials
          in pipe wrap in LEAs	5-20

 17       Schools where ACFM were found,
          by construction date	5-22

 18       Compliance with employee notification
          requirements for LEAs that found asbestos-
          containing friable materials 	 5-24

 19       Schools that provided notice to parents and
          date first notice made from LEA with
          asbestos-containing friable materials	5-25

 20       Number of schools doing abatement, by type
          of abatement and status of abatement work	 5-27

 21       Average cost per square foot of abatement in
          schools in which work has been completed	5-29

 22       Average square feet in schools by method
          of abatement for schools that have
          completed work	5-29

 23       Response rates for Asbestos-In-Schools
          telephone survey	6-2

 24       Final status of telephone interviews for
          Asbestos-In-Schools Survey 	 6-5
                              Vlll

-------
                          FINAL REPORT

           EVALUATION OF THE EPA ASBESTOS-IN-SCHOOLS
              IDENTIFICATION AND NOTIFICATION RULE

                       EXECUTIVE SUMMARY
     The U.S. Environmental Protection Agency's Office of Toxic
Substances has an ongoing program concerning asbestos in schools.
As part of this program, the EPA Identification and Notification
Rule was promulgated in 1982.  The rule,  effective June 28,
1982, requires local education agencies (LEAs)  to conduct
inspections for friable materials, take samples and analyze  them
using polarized light microscopy (PLM), inform employees and
parents of findings and keep records of inspection results at
the LEA and schools.  LEAs were required to comply with all
aspects of the rule by June 28, 1983.

     In order to evaluate the effectiveness of the regulation,
EPA conducted a national survey of 2,600 LEAs.  The survey was
conducted with two overall objectives:  (1) to determine how
many local education agencies have complied with the rule by the
end of the compliance period; and (2) to describe local education
agencies' inspection methods, results, and asbestos abatement
plans.

     A national sample of 1,800 public school districts and
800 private schools was randomly selected and a questionnaire
was administered by telephone.  The  telephone survey was begun
on December 12, 1983 and completed on February 10,  1984.  The
sample sizes were large enough to produce national  total esti-
mates and reliable statistics for subpopulations of  interest.
                                IX

-------
An overall  response rate of  96.5  percent  was  achieved during  the
survey.

     A quality assurance plan was implemented which covered all
aspects of  this study:   construction  of LEA sampling lists,
sample selection,  questionnaire design, data  collection and
analysis.   A subsample  of eight metropolitan  areas was selected
for on-site inspections of LEAs to verify the information
obtained during the telephone interviews.  The information
gathered during quality assurance visits  was  generally consistent
with that from the telephone  survey on all but one variable—the
number of schools  with  friable materials.  One reason for this
disparity is that  schools do  not  know whether to report friable
materials which have been encapsulated or enclosed.  It was also
discovered  that LEAs missed friable materials in 25 out of
90 schools  previously inspected by the LEAs and the majority (in
20 of the 25 schools) of overlooked friable materials were
limited to  boiler  rooms.   This suggests that LEAs do not realize
that boiler rooms  require inspection.  This finding also indi-
cates that  the survey estimate of  the number of schools with
asbestos-containing friable materials (ACFM) may be an under-
estimate.
SUMMARY OF THE SURVEY RESULTS

     A detailed statistical analysis of the data collected during
the telephone survey was conducted.  For some estimates, a dis-
tinction is made between sprayed- or trowelled-on ACFM and boiler/
pipe ACFM.  The reasons for the distinction include:  1) direct
access to boiler/pipe insulation is typically limited to custodial
and maintenance personnel; and 2) it is difficult to provide
accurate square footage estimates for pipe/boiler insulation
materials.  It must be noted that the airborne transport of

-------
asbestos released from boiler/pipe insulation sites to adjacent
and remote areas within a building is possible and is therefore
of concern to other building occupants.

     The statistics in this report are estimates derived from a
sample survey and, as such, are subject to errors of response
and reporting as well as to sampling variability.  For this
reason intervals have been constructed with a prescribed con-
fidence that they include the average result over all possible
samples.  Estimates of percentages presented in this section are
followed by their 95 percent confidence intervals.  Results  are
expressed in terms of LEAs and schools.   There are 32,946 LEAs,
with at least one school built before January 1979; 14,505 are
public LEAs, 18,441 are private LEAs.  There are 95,566 schools
in these LEAs; 76,118 are public and 19,448 are private schools.

     Presented below are the major findings of our data collection
efforts for the two LEA subgroups:  public school districts and
private schools.  Five categories of statistics are presented:
inspection, abatement, compliance, exposure and quality assurance.
Inspection Results

     .    83% + 3% (27,422) of the LEAs have begun or completed
          inspections for friable materials; 94% + 3% (13,673)
          of the public and 75% + 5% (13,749) of the private
          LEAs.
     .    31% + 3% (8,565) of the LEAs that have begun or
          completed inspections used the EPA Technical Assistance
          Program (TAP) which consists of a toll-free number,
          regional technical advisors to assist LEAs and written
          guidelines for conducting inspections; 36% + 3%  (4,894)
          of the public and 27% + 5% (3,671) of the private LEAs.
          94% + 3% (8,080) of the LEAs that used the TAP said  it
          met their needs; 94% + 3% (4,583) of the public  and
          95% + 5% (3,497) of the private LEAs.
                                XI

-------
          93% + 5%  (89,312) of  schools have been  inspected for
          friable materials;  98% +  6%  (74,607) of the public and
          76% + 8%  (14,705) of  the  private schools.

          40% + 7%  (11,031) of  the  LEAs that  inspected found
          ACFM in one or more of their schools; 50% + 5%  (6,842)
          of the public and 30% + 15%  (4,189) of  the private
          schools.

          35% + 3%  (30,830) of  inspected schools were found to
          contain ACFM; 35% + 4% (26,137) of  the public and 32%
          + 7% (4,693) of the private schools.

          45% + 3%  (4,971) of the LEAs that inspected and found
          ACFM in one or more schools, have asbestos materials
          limited to boiler/pipe insulation and not in sprayed-
          or trowelled-on material; 40% + 4%  (2,710) of the
          public and 54% + 7% (2,261) of the  private schools.
Abatement Programs


     There are a total of 11,031 LEAs with at least one school
that contains ACFM, 6,842 public and 4,189 private.  There are

30,830 schools with ACFM; 26,137 public and 4,693 private.


     •    67% + 5% (20,598) of the schools with ACFM have some
          type of abatement work completed or in progress; 67% +
          6% (17,627) of the public and 63% + 14% (2,972) of the
          private schools.

          23% + 5% (7,134) of the schools with ACFM are planning
          some type of abatement action; 23% + 6% (6,014) of the
          public and 24% + 13% (1,120)  of the private schools.

          29% + 5% (3,193) of LEAs with ACFM are using removal
          as the sole method of abatement;  32% + 4% (2,158)  of
          the public and 25% + 8% (1,035)  of the private LEAs.

          28% + 4% (3,055) of LEAs with ACFM are using special
          operations and maintenance procedures and periodic
          reassessment as the sole method of abatement;  29%  + 4%
          (1,955)  of the public and 25% + 8% (1,060)  of  the  ~
          private  LEAs.

     •     The remaining  LEAs are using  more than one method  of
          abatement.
                               XII

-------
          Following is a distribution  of  the  schools with ACFM
          using each abatement method.  These percentages add to
          more than 100% because some  schools use  more  than  one
          method.
          -  Removal is used or will be used  by 39% + 5%  (12,053)
             of the schools.
             Enclosure is used or will be used by  15% + 3%  (4,560)
             of the schools.
             Encapsulation is used or  will be used by 40% +  4%
             (12,408) of the schools.
             Operations/maintenance is used by 41% + 4% (12,733)
             of the schools.
Compliance Results

     The following results present statistics on the number of
LEAs complying with the broad aspects of the Asbestos-In-Schools
Rule requirements.  Because of the limits when administering a
telephone interview, it was not possible to measure compliance
with every provision of the rule.  LEAs were required to
(1) inspect all school building for friable materials,
(2) sample all friable materials (at least three samples per
homogeneous sampling area) unless all friable materials are
declared in writing to contain asbestos, (3) analyze bulk
samples using polarized light microscopy (PLM), (4) notify
custodians, employees and parents if asbestos-containing friable
materials are found in writing and post EPA form 7730-3 in
certain areas of the school building, and (5) maintain records
at LEAs and schools on Form 7730-1 and keep records where
asbestos is located and copies of all notifications.

     Following are the compliance results for LEAs with at  least
one school built before January 1, 1979.  There are 32,946  such
LEAs; 14,505 public and 18,441 private.
                               Xlll

-------
          9% + 2% (2,899) of the LEAs were in compliance with
          all aspects of the rule by June 28, 1983; 11% + 2%
          (1,529) of the public and 7% + 3%  (1,370) of the
          private LEAs.

          11% + 2%  (3,638) of the LEAS were  in compliance with
          all aspects of the rule by January 1, 1984; 13% + 2%
          (1,943) of the public and 9% + 3%  (1,695) of the
          private LEAs.


     There were a number of LEAs that were not in strict compliance
with the rule but did make an effort to comply.  Frequent areas

of violation were an insufficient number of bulk samples taken
(less than 3) and the lack of use of the EPA forms.  The LEAs in

compliance with most aspects of the rule did (1) inspect all of
their schools, (2)  sample and analyze all friable materials,
(3) notify employees and parents, and (4) keep some documentation

on file.  Statistics are presented as of June 28, 1983, the date

required for compliance by the rule, and as of January 1, 1984,
which shows the compliance status at the time of this survey.

Following are the compliance results for these LEAs.


          24% + 2%  (7,999) of the LEAs were in compliance with
          most aspects of the rule by June 28, 1983, 25% + 2%
          (3,595) of the public and 24% + 3% (4,405) of the
          private LEAs.

     .    34% + 2%  (11,050) of the LEAs were in compliance with
          most aspects of the rule by January, 1984; 36% + 3%
          (5,179) of the public and 32% + 3% (5,871) of the
          private LEAs.


     Following are  the compliance results for LEAs with at least
one school with ACFM.  There are 11,031 such LEAs; 6,842 public
and 4,189 private.


          2% + 2% (212) of the LEAs with ACFM were in compliance
          with all aspects of the rule by June 28, 1983; 2% + 2%
          (122)  of the public and 2% + 2% (90)  of the private LEAs.

     .     4% + 2% (437) of the LEAs with ACFM were in compliance
          with all aspects of the rule by January 1, 1984; 3% +
          2% (226) of the public and 5% + 2% (211) of the private
          LEAs.
                               xiv

-------
     Following are the compliance results for the LEAs with at
least one school with ACFM that attempted to comply with most

aspects of the rule as defined above.


     •    6% + 2% (651)  of the LEAs with ACFM were in compliance
          with most aspects of the rule by June 28, 1983;  5% +
          2% (368) of the public and 7% + 2% (283) of the private
          LEAs.

          21% + 3% (2,348) of the LEAs with ACFM were in
          compliance with most aspects of the rule by January 1,
          1984; 20% + 4% (1,393) of the public and 23% + 6%
          (955) of the private LEAs.


     An analysis was conducted of the LEAs that did not comply

with most aspects of the rule by January 1984.  The purpose was

to ascertain the effect each of the primary rule requirements

(inspection, sampling, notification and documentation) had on

the compliance statistics.  There are 32,946 LEAs with at least

one school built before January 1, 1979; 14,505 public and

18,441 private.  The results of this analysis are as follows:


          19% + 3% (6,405) of the LEAs failed to comply because
          they did not complete inspections of all of their
          schools; 10% + 3% (1,497) of the public and 27% + 5%
          (4,908) of the private LEAs.

          20% + 2% (6,738) of the LEAs failed to comply because
          they did not document inspection results; 16% + 3%
          (2,325) of the public and 24% + 5%  (4,413) of the
          private LEAs.

          13% + 3% (4,417) of the LEAs failed to comply with
          more than one aspect of the rule; 20% +  3%  (2,853)  of
          the public and 8% + 4%  (1,564) of the private LEAs.


     The same examination was made  of LEAs with ACFM  that  failed

to comply with most aspects of  the  rule by January 1984.   There

are 11,031 LEAs with ACFM; 6,842  public and 4,189  private.   The

findings for these LEAs are:
                                xv

-------
           31% +  5%  (3,434)  of  the  LEAs with ACFM failed  to comply
           because they  did  not notify employees and/or parents
           of the presence of asbestos; 32% +  5% (2,198)  of the
           public and  30% +  8%  (1,236) of  the  private LEAs.


     All other reasons  for  noncompliance  were less than  10 percent,

The aggregated statistics reveal that:


           34% +  5%  (3,762)  of  the  LEAs with ACFM failed  to comply
           with more than one aspect of the rule; 35% + 5% (2,379)
           of the public and 32% +  8% (1,343)  of the private
           LEAs.
     These findings  show  that  inspection and documentation were
problem areas of  significant noncompliance.  For LEAs that found
ACFM, failure to  notify employees and/or parents was by far the
most prominant reason  for noncompliance.
Exposure to ACFM in Schools
          35% + 3% of inspected schools have ACFM; 34% + 3% of
          all students are enrolled in these schools.

          169,285,000 + 25,600,000 square feet of sprayed or
          trowelled-on ACFM was reported to be in schools.  This
          number does not include pipe or boiler insulation for
          which square footage is not available.

          15,035,000 + 1,514,000 students are in schools with
          ACFM:

               10,678,000 + 1,075,000 in schools with at least
               some sprayed or trowelled-on ACFM; and

               4,357,000 + 439,000 in schools with ACFM limited
               to pipe or boiler insulation.

          1,386,000 + 192,000 school employees are in schools
          with ACFM.
                               xvi

-------
Quality Assurance


     Quality Assurance (QA)  site visits  were  made  to  eight
metropolitan areas in which  38 LEAs  were visited  (17  public  and
21 private) and 94 schools within these  LEAs  were  inspected  (73

public and 21 private).   One superintendent refused to  allow the
monitor to visit, giving an  overall  LEA  response rate of
97.4 percent.  The purposes  of the site  visits  were  (1)  to
verify that the information  collected during  the telephone
interviews corresponded to what was  on file at  the LEA  and

(2) to validate that the information reported by the  LEA about
the schools matched the situation at the schools.


     The data collected during the site  visits  indicate that the
survey results matched the records on file at the  LEAs.   Areas
of disagreement could be accounted for and are  not believed  to

have any significant influence on the statistics reported on
herein.  Shown below are the major findings  from  the  site visits:


     .    Some LEAs and school officials are  unable  to  respond
          to questions about inspections in a valid  and reliable
          manner due to turnovers in personnel  and the  failure
          to maintain adequate records.   Although  this  is a
          potential source of error, the site visit  results show
          that such errors at times overestimated  and at times
          underestimated the number of schools  with  ACFM and
          therefore do not imply a consistent bias in the
          national estimates.

     •    Some schools, due  to inadequate inspections,  did not
          report friable materials on pipes and boilers that
          were present.  This may lead to an underestimate of
          the amount of friable material in schools  nationally.

     •    Some schools were more likely to report at the site
          visit the presence of friable materials which had been
          enclosed or encapsulated.  On the questionnaire, LEAs
          were requested to give the number of schools in which
          friable materials had been found regardless of whether
          those materials had been enclosed or encapsulated.
          This may lead to an underestimate of the amount of
          friable materials in schools nationwide.
                               xvi i

-------
          Some  schools  failed  to report  friable  insulation on
          pipes and boilers because they did not understand
          inspection of boiler rooms was required by the rule.
          This  will contribute to underestimating the amount of
          friable materials on pipes and boilers nationwide.

          On balance, we believe that our nationwide estimates
          of the presence of friable materials predominantly on
          pipes and boilers may be low.  An estimated 89% of the
          schools in the survey with friable materials also have
          ACFM; therefore the number of  schools with ACFM on
          pipes and boilers is also likely to be an underestimate,

          Most  LEAs are instructing their schools with ACFM to
          notify employees and parents,  but notifications are
          not being implemented by some  schools.

          Some  schools are reluctant to  notify parents in schools
          with ACFM when friable materials are limited to pipe
          wrap  in boiler rooms.
Examination of the EPA Compliance Monitoring Reports


     The EPA Regional Asbestos Coordinators' (RACs) Compliance
Monitoring Reports prepared as of February 1984 included 80 LEAs

that were in our selected sample.  These reports were used as
part of our QA program to verify questionnaire data.  Since RAG

reports were highly variable in information content and complete-

ness, there were only four items that were, included in all of

the RAC reports and so the comparisons were based on these items.

No significant differences were found when comparing the RAC

reports to the questionnaire data for the four items.
                              xvi 11

-------
                            SECTION 1
                          INTRODUCTION
BACKGROUND

     The widespread use of asbestos over the years has caused
concern about the risk of increased cancer and chronic respiratory
disease among various segments of the population.   Pulmonary
cancer, mesothelioma, and fibrosis of the lung are known  to be
associated with exposure to asbestos in certain work places,
such as where asbestos is mined and milled or where asbestos
materials and products are manufactured or used (NCI 1978;  Peto
et al., 1982; Zivy, 1982).  Currently there is considerable
concern that asbestos-containing materials, used extensively in
schools from 1945 to 1978 for fire-retarding purposes and acous-
tical or thermal insulation, are releasing asbestos fibers into
the air of the buildings.  The resultant exposure of the students,
teachers, and other school employees to the airborne asbestos
may result in asbestos-related diseases.  A rule proposed by the
U.S. Environmental Protection Agency (EPA) requiring the identi-
fication of friable* asbestos-containing materials in schools
and the notification of those exposed to the materials was
published in the Federal Register  (45 FR 61966) in September
1980.  The final rule was published May 27, 1982  in  the Federal
Register (47 FR 23360) and became  effective June  28, 1982.

     The EPA had been operating  a  voluntary Technical Assistance
Program (TAP) since March 1979 preceding  issuance of the
Asbestos-In-Schools  Identification and Notification  Rule.   The
*Friable materials are defined as any materials applied onto
 ceilings, walls, structural members, piping, ductwork, etc.,
 which when dry may be crumbled, pulverized or reduced to  powder
 by hand pressure.
                               1-1

-------
TAP, which continues to exist, was designed to help school dis-

tricts voluntarily identify and correct potential hazards due to
the presence of asbestos-containing materials in schools.  The

EPA found it necessary to promulgate the Identification and

Notification Rule, because information from the Regional Asbestos

Coordinators indicated that a large percentage of U.S. schools
had not been inspected or had been inadequately inspected under

the voluntary program.


     Under the Asbestos-In-Schools Identification and

Notification Rule, local education agencies (which include

public and private schools) were allowed 13 months to comply

with all portions of the rule.  The rule requires local

education agencies to comply by June 28, 1983, and to:


     1.   Inspect all areas of each school building within the
          agency for friable materials applied to structural
          surfaces in the building;

     2.   Take at least three samples of each distinct type of
          friable material found or treat all friable materials
          as asbestos-containing;

     3.   Have those samples analyzed using polarized light
          microscopy (PLM) for their asbestos content;

     4.   Post notice of inspection results in schools where
          friable asbestos-containing materials were found using
          Form 7730-3,"Notice to School Employees" and inform
          all employees of the location of these materials;

     5.   Distribute Form 7730-2, "A Guide for Reducing Asbestos
          Exposure"  to maintenance and custodial personnel;

     6.   Notify the parent-teacher groups or parents for
          schools found to contain friable asbestos-containing
          materials;  and

     7.   Maintain records of the findings of all inspections
          and analyses at the local education agency and in all
          schools using Form 7730-1.
                               1-2

-------
The rule does not require schools to take abatement action.
However, when asbestos-containing materials are identified,
schools may choose corrective action such as removal,  encapsu-
lation, enclosure, or an operations/maintenance plan.

     Schools that had already inspected,  sampled,  and  analyzed
friable asbestos-containing material under the voluntary TAP
only had to comply with the recordkeeping and notification pro-
visions of the rule.  Schools that contained no friable
asbestos-containing materials had to certify these results and
maintain the certification statement in their files.   Schools
that conducted abatement programs resulting in the elimination
or containment of all friable asbestos materials,  either by
removal or encapsulation of the materials before June  28, 1983
were exempt from all the requirements of the rule.

     The EPA conducted this telephone survey of LEAs to evaluate
compliance with the Asbestos-In-Schools Identification and
Notification Rule.  For the purpose of this study, LEAs are
defined in the following way.  For public schools the local
education agency was in most cases the school district.  In some
large cities, a central office reported for more than one school
district and was designated the responding local education agency.
For private non-Catholic schools, the local education agency was
in most cases the school, although occasionally a respondent
reported on more than one school under their control.   For
private Catholic schools, the local education agency was in most
cases the school, although some dioceses reported for the schools
under their jurisdictions.  In these instances, dioceses were
considered the local education agency.
                                1-3

-------
 SURVEY  OBJECTIVES AND DESIGN

      The survey was conducted with two overall  objectives:
 (1)  to  determine how many local  education agencies  had  complied
 with the rule by the end of the  compliance period;  and  (2)  to
 describe local education agencies'  inspection methods,  results,
 and  abatement plans.  To accomplish these objectives, the
 following information was collected:

      .     The number of  schools  that  were inspected for friable
           materials;
      .     The date that  the schools performed the inspection so
           that TAP inspections could  be differentiated  from rule
           compliance inspections;
      •     The number of  schools  with  friable asbestos-containing
           friable materials present;
      •     The number of  square feet of friable  asbestos-containing
           materials  present;
      •     The number of  people (by  subcategory, i.e., students,
           teachers,  custodians)  using buildings with friable
           asbestos-containing materials;
      •     The recordkeeping processes used;
      •     The processes  used to  notify employees and parents;
           and
      .     The number of  square feet of asbestos-containing
           materials  which had been  abated  or were scheduled for
           abatement  in the  future and the  types of  abatement
           used or  planned.

      The  survey called for  the collection  of information from
 1,800 public  LEAs, 400 private Catholic, and 400 private non-
 Catholic  schools.  As a  part of  the survey design,  eight metro-
 politan areas  were selected  as a quality assurance  subsample and
LEAs were visited  to verify  the  information given during the
 telephone interview.  In addition,  some schools were inspected
as part of the quality assurance plan.
                               1-4

-------
     The principal conclusions of the study are given in
Section 2.  The overall quality assurance program that was used
is described in Section 3.   The sample design that was the basis
for the survey is described in Section 4.  A discussion of the
telephone survey operations is given in Section 5.  A detailed
accounting of the analyses  that were performed and results
obtained is given in Section 6.
                               1-5

-------
                           SECTION 2
                          CONCLUSIONS
     The principal conclusions from the study are  presented
below.  They meet the objectives of the study which  were  to:

     1.   Determine the level and degree of  compliance  of the
          local Education Agencies (LEAs)  with the EPA
          Asbestos-In-Schools Identification and Notification
          rule; and
     2.   Collect ancillary information on:
          •    Potential exposures of school employees  and
               students to asbestos-containing friable
               materials;
          .    The amount of these materials present;  and
          •    Various abatement activities  to contain  and/or
               monitor these materials when  present.

     The major findings from this survey are the national estimates
from the survey data.  The numbers are statistically unbiased
estimates based on a national probability sample and represent a
census of the target universe of LEAs and schools.  For some
estimates, a distinction is made between sprayed- or trowelled-on
ACFM and boiler/pipe ACFM.  The reasons for the distinction
include that direct access to boiler/pipe insulation is typically
limited to custodial and maintenance personnel and  it is difficult
to provide accurate square footage estimates for pipe/boiler
insulation materials.  It must be noted that the transport of
asbestos released from boiler/pipe insulation is possible and is
therefore of concern to other building occupants.
                               2-1

-------
     The statistics in this report are estimates derived from a
sample survey and, as such, are subject to errors of response
and reporting as well as to sampling variability.  For this
reason intervals have been constructed with a prescribed confi-
dence that they include the average result over all possible
samples.  Estimates of percentages presented in this section are
followed by their 95 percent confidence intervals.  Results are
expressed in terms of LEAs and schools.  The results apply to
LEAs with at least one school built before January 1, 1979,
since after that date materials containing more than one percent
asbestos were no longer allowed in the construction of buildings.
There are 32,946 LEAs, with at least one built before January
1979; 14,505 are public and 18,441 are private LEAs.  There are
95,566 schools in these LEAs; 76,118 are public and 19,448 are
private schools.  Five categories of statistics are presented:
inspection, abatement, compliance, exposure and quality assurance.
Inspection Results
          83% + 3% (27,422)  of the LEAs have begun or completed
          inspections for friable materials; 94% + 3% (13,673)
          of the public and  75% + 5% (13,749) of the private
          LEAs.
          31% + 3% (8,565)  of the LEAs that have begun or
          completed inspections used the EPA Technical Assistance
          Program (TAP) which consists of a toll-free number,
          regional technical advisors to assist LEAs and written
          guidelines for conducting inspections; 36% + 3% (4,894)
          of the public and  27% + 5% (3,671) of the private LEAs.
          94% + 3% (8,080)  of the LEAs that used the TAP said  it
          met their needs;  94% + 3% (4,583) of the public and
          95% + 5% (3,497)  of the private LEAs.
          93% + 5% (89,312)  of schools have been inspected for
          friable materials; 98% + 6% (74,607)  of the public and
          76% + 8% (14,705)  of the private schools.
                              2-2

-------
          40% + 7% (11,031) of the LEAs that inspected found
          ACFM in one or more of their schools; 50% + 5% (6,842)
          of the public and 30% + 15% (4,189)  of the private
          schools.

          35% + 3% (30,830) of inspected schools were found to
          contain ACFM; 35% + 4% (26,137) of the public and 32%
          + 7% (4,693) of the private schools.

          45% + 3% (4,971) of the LEAs that inspected and found
          ACFM in one or more schools, have asbestos materials
          limited to boiler/pipe insulation and not in sprayed-
          or trowelled-on material; 40% + 4% (2,710) of the
          public and 54% + 7% (2,261) of the private schools.
Abatement Programs


     There are a total of 11,031 LEAs with at least one school

that contains ACFM, 6,842 public and 4,189 private.  There are

30,830 schools with ACFM; 26,137 public and 4,693 private.


     .    67% + 5% (20,598) of the schools with ACFM have some
          type of abatement work completed or in progress; 67% +
          6% (17,627) of the public and 63% + 14%  (2,972) of the
          private schools.

     .    23% + 5% (7,134) of the schools with ACFM are planning
          some type of abatement action; 23% + 6%  (6,014) of the
          public and 24% + 13% (1,120) of the private schools.

     .    29% + 5% (3,193) of LEAs with ACFM are using removal
          as the sole method of abatement; 32% + 4%  (2,158) of
          the public and 25% j- 8% (1,035) of the private  LEAs.

          28% + 4% (3,055) of LEAs with ACFM are using special
          operations and maintenance procedures and periodic
          reassessment as the sole method of abatement;  29% +  4%
          (1,955) of the public and 25% + 8%  (1,060)  of  the
          private LEAs.

     •    The remaining LEAs are using more  than one  method of
          abatement.
                               2-3

-------
          Following is a distribution of the schools with ACFM
          using each abatement method.  These percentages add to
          more than 100% because some schools use more than one
          method.
          -  Removal is used or will be used by 39% + 5% (12,053)
             of the schools.
             Enclosure is used or will be used by 15% + 3% (4,560)
             of the schools.
          -  Encapsulation  is used or will be used by 40% + 4%
             (12,408) of the schools.
             Operations/maintenance is used by 41% + 4% (12,733)
             of the schools.
Compliance Results

     The  following results present statistics on the number of
LEAs complying with  the broad aspects of the Asbestos-In-Schools
Rule requirements.   Because of  the limits when administering a
telephone interview,  it was not possible to measure compliance
with every provision of the rule.  LEAs were required to
(1) inspect all  school building for friable materials,
(2) sample all friable materials  (at least three samples per
homogeneous sampling area) unless all friable materials are
declared  in writing  to contain  asbestos, (3) analyze bulk
samples using polarized light microscopy (PLM), (4) notify custo-
dians, employees and  parents if asbestos-containing friable
materials are found  in writing  and post EPA form 7730-3 in
certain areas of the  school building, and (5) maintain records
at LEAs and schools  on Form 7730-1 and keep records where
asbestos  is located  and copies  of all notifications.

     Following are the compliance results for LEAs with at least
one school built before January 1, 1979.  There are 32,946 such
LEAs; 14,505 public and 18,441 private.
                               2-4

-------
     .     9% + 2% (2,899)  of the LEAs were in compliance with
          all aspects of the rule by June 28, 1983;  11%  + 2%
          (1,529) of the public and 7% + 3% (1,370)  of  the
          private LEAs.

     •     11% + 2% (3,638) of the LEAS were in compliance with
          all aspects of the rule by January 1, 1984;  13% + 2%
          (1,943) of the public and 9% + 3% (1,695)  of  the
          private LEAs.


     There were a number of LEAs that were not in strict compliance

with the rule but did make an effort to comply.  Frequent areas
of violation were an insufficient number of bulk samples taken
(less than 3) and the lack of use of the EPA forms.   The LEAs in

compliance with most aspects of the rule did (1) inspect all  of
their schools, (2) sample and analyze all friable materials,

(3) notify employees and parents, and (4) keep some documentation
on file.  Statistics are presented as of June 28, 1983,  the date
required for compliance by the rule, and as of January 1, 1984,
which shows the compliance status at the time of this survey.

Following are the compliance results for these LEAs.


     •     24% + 2% (7,999) of the LEAs were in compliance with
          most aspects of the rule by June 28, 1983, 25% + 2%
          (3,595) of the public and 24% + 3% (4,405) of the
          private LEAs.

     •     34% + 2% (11,050) of the LEAs were in compliance with
          most aspects of the rule by January, 1984; 36% + 3%
          (5,179) of the public and 32% + 3% (5,871) of the
          private LEAs.


     Following are the compliance results for LEAs with at least

one school with ACFM.  There are 11,031 such LEAs; 6,842 public

and 4,189 private.


          2% + 2% (212)  of the LEAs with ACFM were in compliance
          with all aspects of the rule by June 28, 1983; 2% +  2%
          (122) of the public and 2% + 2% (90) of the private
          LEAs.
                               2-5

-------
          4% + 2% (437) of the LEAs with ACFM were in compliance
          with all aspects of the rule by January 1, 1984; 3% +
          2% (226) of the public and 5% + 2% (211) of the private
          LEAs.
     Following are the compliance results for the LEAs with at

least one school with ACFM that attempted to comply with most

aspects of the rule as defined above.


     •    6% + 2% (651) of the LEAs with ACFM were in compliance
          with most aspects of the rule by June 28, 1983; 5% +
          2% (368) of the public and 7% + 2% (283) of the private
          LEAs.

          21% + 3% (2,348) of the LEAs with ACFM were in
          compliance with most aspects of the rule by January 1,
          1984; 20% + 4% (1,393) of the public and 23% + 6%
          (955) of the private LEAs.


     An analysis was conducted of the LEAs that did not comply
with most aspects of the rule by January 1984.   The purpose was

to ascertain the effect each of the primary rule requirements

(inspection, sampling, notification and documentation) had on

the compliance statistics.   There are 32,946 LEAs with at least

one school built before January 1,  1979;  14,505 public and

18,441 private.  The results of this analysis are as follows:


          34% + 2% (11,050)  of the LEAs complied with most
          aspects of the rule; 36% + 3% (5,179)  of the public
          and 32% + 3% (5,871) of the private LEAs.

          19% + 3% (6,405)  of the LEAs failed to comply because
          they did not complete inspections of  all of their
          schools; 10% + 3%  (1,497)  of the public and 27% + 5%
          (4,908)  of the private LEAs.

          20% + 2% (6,738)  of the LEAs failed to comply because
          they did not document inspection results;  16% + 3%
          (2,325)  of the public and  24% +  5% (4,413)  of the
          private LEAs.

          3%  +  2%  (902)  of  the LEAs  failed to comply because
          they  did not sample or  analyze friable materials;  3% +
          2%  (453)  of  the public  and 2% +  3% (449) of the
          private  LEAs.
                              2-6

-------
          13% + 3% (4,417)  of  the LEAs  failed  to comply with
          more than one aspect of the rule;  20%  + 3%  (2,853)  of
          the public and 8% +  4%  (1,564)  of  the  private LEAs.


     The same examination was  made of LEAs with  ACFM  that  failed

to comply with most aspects of the rule by January 1984.   There
are 11,031 LEAs with ACFM;  6,842  public and  4,189 private.  The

findings for these LEAs are:


          21% + 3% (2,347)  of  the LEAs  with  ACFM complied  with
          most~aspects of the  rule; 20% + 4% (1,393)  of the
          public and 23% + 6%  (955) of  the private LEAs.

     .     31% + 5% (3,434)  of  the LEAs  with  ACFM failed to
          comply because they  did not notify employees and/or
          parents of the presence of asbestos;  32% +  5% (2,198)
          of the public and 30% + 8% (1,236) of  the private
          LEAs.

          7% + 2% (788) of the LEAs with ACFM failed  to comply
          because they did not sample or analyze friable
          materials; 6% + 2% (387) of the public and  10% + 3%
          (401) of the private LEAs.

          4% + 2% (484) of the LEAs with ACFM failed  to comply
          because they did not document the  results of the
          inspections; 4% + 2% (269) of the  public and 6% + 2%
          (254) of the private.

          2% + 2% (216) of the LEAs with ACFM, all of them
          public, failed to comply because they did not inspect
          all of their schools.

          34% + 5%  (3,762) of the LEAs with ACFM  failed to
          comply with more than one aspect of the rule; 35% + 5%
          (2,379) of the public and 32% + 8% (1,343)  of the
          private LEAs.


     These findings show that inspection and documentation were

problem areas of significant noncompliance.  For LEAs that found

ACFM, failure to notify employees  and/or parents was  the  most

prominant reason for noncompliance.
                                2-7

-------
Exposure to ACFM in Schools
           35% +  3% of  inspected schools have ACFM; 34% + 3% of
           all students are enrolled in these schools.
           169,285,000  +  25,600,000 square feet of sprayed or
           trowelled-on ACFM was reported to be in schools.  This
           number does  not include pipe or boiler insulation for
           which  square footage is not available.
           15,035,000 + 1,514,000 students are in schools with
           ACFM:
               10,678,000 + 1,075,000 in schools with at least
               some sprayed or trowelled-on ACFM; and
               4,357,000 + 439,000 in schools with ACFM limited
               to pipe or boiler insulation.
           1,386,000 + 192,000 school employees are in schools
           with ACFM.
Quality Assurance

     Quality Assurance (QA) site visits were made to eight
metropolitan areas in which 38 LEAs were visited (17 public and
21 private) and 94 schools within these LEAs were inspected (73
public and 21 private).  One superintendent refused to allow the
monitor to visit, giving an overall LEA response rate of
97.4 percent.  The purposes of the site visits were (1) to
verify that the information collected during the telephone
interviews corresponded to what was on file at the LEA and
(2) to validate that the information reported by the LEA about
the schools matched the situation at the schools.

     The data collected during the site visits indicate that the
survey results matched the records on file at the LEAs.  Areas
of disagreement could be accounted for and are not believed to
                               2-8

-------
have any significant influence on the statistics  reported  on

herein.  Shown below are the major findings  from  the  site  visits:


     .    Some LEAs and school officials  are unable to  respond
          to questions about inspections  in  a valid and reliable
          manner due to turnovers in personnel and the  failure
          to maintain adequate records.   Although this  is  a
          potential source of error, the  site visit results show
          that such errors at times overestimated and at times
          underestimated the number of schools with ACFM and
          therefore do not imply a consistent bias in the
          national estimates.

     •    Some schools/ due to inadequate inspections,  did not
          report friable materials on pipes  and boilers that
          were present.  This may lead to an underestimate of
          the amount of friable material  in  schools nationally.

     .    Some schools were more likely to report at  the site
          visit the presence of friable materials which had been
          enclosed or encapsulated.  On the  questionnaire, LEAs
          were requested to give the number  of schools  in  which
          friable materials had been found regardless of whether
          those materials had been enclosed  or encapsulated.
          This may lead to an underestimate  of the  amount  of
          friable materials in schools nationwide.

     •    Some schools failed to report friable insulation on
          pipes and boilers because they did not understand
          inspection of boiler rooms was required by the rule.
          This will contribute to underestimating the amount of
          friable materials on pipes and boilers nationwide.

     •    On balance, we believe that our nationwide estimates
          of the presence of friable materials predominantly on
          pipes and boilers may be low.  An estimated 89%  of the
          schools in the survey with friable materials also have
          ACFM; therefore the number of schools with ACFM on
          pipes and boilers is also likely to be an underestimate.

     •    Most LEAs are instructing their schools with ACFM to
          notify employees and parents, but notifications are
          not being implemented by some schools.

     •    Some schools are reluctant to notify parents  in schools
          with ACFM when friable materials are limited  to pipe
          wrap in boiler rooms.
                               2-9

-------
Examination of the EPA Compliance Monitoring Reports

     The EPA Regional Asbestos Coordinators' (RACs) Compliance
Monitoring Reports prepared as of February 1984 included 80 LEAs
that were in our selected sample.  These reports were used as
part of our QA program to verify questionnaire data.  Since RAC
reports were highly variable in information content and complete-
ness, there were only four items that were included in all of
the RAC reports and so the comparisons were based on these
items.  No significant differences were found when comparing the
RAC reports to the questionnaire data for the four items.
                              2-10

-------
                           SECTION 3
                   QUALITY ASSURANCE PROGRAM
     Quality assurance was an important consideration in the
design and management of this study.   It covered the organiza-
tion and operation of all aspects of  the work.   The major
components of the quality assurance program are summarized
below.
SAMPLE SELECTION

     The sampling list or frame used to select public school
districts and private schools was purchased from Market Data
Retrieval, Inc., a company which maintains current, regularly
updated files.  Totals of private and public school enrollments
from the data file were aggregated and compared to totals pro-
vided by the National Center for Educational Statistics (NCES).

     The frame was stratified by type of school district or
school (public, private Catholic and private non-Catholic) then'
sorted by the LEAs'  enrollments within state.  Systematic
samples for each type of school were selected with the
probability of selecting any one school proportionate to the
square root of enrollment.  The computer programs written to
construct the sample were carefully checked to assure accuracy.
The sample was weighted by the inverse of the probability of
selection and weighted up to provide national totals.  These
totals were compared to NCES statistics and to the totals from
Market Data Retrieval, Inc. for comparability.
                                3-1

-------
 DATA  COLLECTION

      A questionnaire  was  developed based on  Inspections for
 Friable Asbestos-Containing Materials  (EPA form  7730-1).
 Project personnel  from the EPA headquarters  and  regions provided
 advice on a regular basis during  this  time.  The questionnaire
 was pretested  on 10 public and private LEAs.  A  three-day
 training program was  conducted to instruct experienced telephone
 interviewers about the questionnaire and the use of special
 survey procedures.  During the first week of the survey, every
 interviewer was monitored.  Thereafter 10 percent of all inter-
 views were monitored.   During the interview period computerized
 control  systems were  used to provide managers with information
 on survey progress, quality, schedule  and cost.
RESPONSE RATES

     An important aspect of the validity of survey data is the
response or cooperation rate achieved.  In a voluntary survey
such as this one, one does not generally achieve full partici-
pation as some contacts exercise their right to refuse partici-
pation.

     Nonresponse was minimized in this study through the
recruitment of experienced telephone interviewers.  An extensive
effort to contact nonresponding LEAs was undertaken employing
interviewers who demonstrated skill in achieving high response
rates.  At least three phone calls were made to responding LEAs
that needed more time to gather all the required information.
Due to these efforts an excellent overall response rate of 96.5
percent was achieved.
                               3-2

-------
     The total number of completed responses and the final

response rates by type of LEA are as follows:
    Type of school

Public

Private Catholic

Private non-Catholic
   Sample
    size

   1,800

     400

     400
   Number of
   responses

     1,742

       387

       379
       Proportion
       responses

          96.8%

          96.8

          94.8
     Reasons for noncooperation are shown below.  Overall, three

percent refused to participate.  Less than one percent of the

schools had closed.  In some places, one office provided infor-
mation for more than one city school district which had been

selected to be in the sample.   Although we only completed one

questionnaire for all such school districts, the other districts

were considered completes since information was gathered about

them.  These schools are shown below as "Schools covered by

another questionnaire."  The final status of all LEAs was:
                          Public     Private
                          school      non-
                         districts  Catholic
Refused to participate

Schools closed

Military schools on base
   (exempt)

No answer after
  8 callbacks

Completed questionnaires

Schools covered by
  another questionnaire
   48

    1
    9

1,701


	40

1,800
 17

 15
  3

363


	1

400
 Private
Catholic

   13

    0
  0

374


 13

400
        Total

            78

            16
               12

            2,438


            	54

            2,600
                                3-3

-------
DATA VALIDATION AND PROCESSING

     Data collected during the survey operations were manually
edited, coded, keypunched and then computer edited to produce a
clean data tape.  Coders/editors were trained in a session which
included a review of the code design and practice coding of
scripted questionnaires.  Each coder's first day's work was 100
percent verified and 10 percent of subsequent work was verified.
As questionnaires were coded and verified they were sent to be
keypunched into a form that could be read by a computer.  All
keypunching was 100 percent verified.
SITE VISITS TO LEAs

     Eight metropolitan areas were purposefully selected to
receive a site visit by a field investigator.  The primary pur-
pose of the visit was to verify that the information collected
during the telephone interviews corresponded to that of the LEA.
The field investigator was also to validate that the information
reported by the LEA about_the schools matched the situation at
the schools.  Three investigators were employed.
Selection of Cities/ LEAs and Schools

     The cities were selected to cover a wide range of geographic
areas in the United States and as many EPA regions as possible.
Each city had to (1) have schools with and without asbestos-
containing friable materials and (2) have been adequately
                               3-4

-------
represented in the sample to assure the investigators a full
work load.

     Each investigator was given the names of at least two public
school districts, two private Catholic schools and two private
non-Catholic schools to visit.  LEAs that had already been
inspected by the EPA Compliance Monitors were excluded as were
those that had refused to participate in the survey or had not
inspected any of their schools.  When possible, LEAs that had at
least one school with ACFM were selected.  Within the public
school districts, a subsample of schools was to be chosen by  the
field investigators to be inspected.

     The contact person at the LEA provided the QA Monitors with
a list of the schools in their district built before January  1,
1979, marked to show which schools had ACFM and which had boilers,
The complete instructions to QA monitors for selecting schools
are included in Appendix D, QA Visit Field Manual, under Task 2.
Monitors were instructed to start at the top of the list and
select at least one school which met each of the following cri-
teria, if available, listed in order of their importance:

     1.   A school reporting no ACFM but with a 'boiler.
     2.   A school reporting ACFM with a boiler.
     3.   A school reporting ACFM without a boiler.
Training of Field Investigators

     A training session was held on February  22,  1984  to explain
the purpose of the site visit, the requirements of  the Asbestos-
In-Schools rule, and to outline the series of events that  should
take place during a QA visit.  A QA Visit Field Manual was
                                3-5

-------
prepared, a copy of which is included in Appendix D.  The Field
Manual provides a copy of the forms to be filled in at each site
and an explanation of procedures to be followed during the visit.
The three field investigators met in Kansas City on March 12,
1984.  They accompanied the EPA Region VII Asbestos Coordinator
on compliance monitoring inspections of two LEAs.  The three
investigators then completed inspections of one LEA and three of
its schools, and two private schools in Kansas City.  The Kansas
City experience provided the investigators with valuable training
in the inspection of schools for friable materials as well as
alerting them to what forms they should expect to find on file
at the LEA and at the schools.  By inspecting the Kansas City
sites together, the three investigators standardized their per-
formance objectives so as to provide a uniformity of effort
during the remaining site visits.
 RESULTS OF SITE VISITS

     In the 8 metropolitan areas, 17 public and 21 private LEAs
 were visited.   One public LEA superintendent refused  to allow
 the Monitor to visit,  giving  us  an  LEA response rate  of
 97.4 percent.   No officials refused to allow inspections  of
 schools and inspections  were  completed in  73 public and 21 pri-
 vate schools.   Overall,  the LEAs and schools cooperated fully
 with the field investigators,  who had no problem  obtaining
 access  to school  records  or buildings.  The major problem
 encountered with  the site  visits was the turnover in personnel
 and the failure of LEAs  to maintain  records about inspections.
 The new principal, superintendent, or maintenance custodian
 might be  unfamiliar with the asbestos inspection program.   The
 following  sections detail  the results of site visits to public
 and  private LEAs and inspections of public and private schools.
                              3-6

-------
Results of Site Visits to LEAs

    The information collected during the site visits was in
general agreement with that from the questionnaires  and  in  almost
complete agreement on seven of the eight key items.   While  the
results of site visits to public LEAs showed discrepancies
between records at the site and what was reported during the
telephone interview, the differences were found almost exclu-
sively in two LEAs.  One LEA conducted 15 inspections after the
telephone interview was made, but before the site visit. At the
second LEA, the superintendent was new on the job and found two
asbestos files after the telephone interview had been completed.
These two LEAs accounted for 80 percent of the variation found
in site visits.  The LEAs were asked to describe the situation
at their schools as it existed in January, 1984 at the time of
the telephone interview.  Table 1 shows the results of visits to
public LEAs at the time of the site visit and at the time of the
telephone interview.  The results as of January, 1984 at the
sites are comparable to what was obtained in the telephone inter-
view for most items.  Although the differences were not statis-
tically significant, 7 out of 17 public LEAs reported a different
number of schools in their school districts at the site visit
than on the questionnaire.  The only item that proved to be
significantly different from zero was the number of schools with
friable materials for public LEAs.  On the  telephone question-
naire, some LEAs did not report they had friable materials  if
such materials had been removed, enclosed,  or encapsulated  or  if
the friable materials were solely found  in  boiler rooms while
LEAs were more likely to report these friable materials at  the
site visit.  Private LEA results agreed  very closely between
site visits and questionnaires.  However, more  private  LEAs said
they found friable materials  on the  site visit  than they did on
the questionnaire.  None of  the differences found in private
LEAs were statistically  significant  at  the  95  percent confidence
level.
                               3-7

-------
     Table 1.  Results of site visits to LEAs
Item
1. Number of schools in LEA
2. Number of students in LEA
3. Number of schools inspected
4. Number of schools with friable
materials
5. Number of schools with asbestos-
containing friable materials
6. Number of LEAs with Form 7730-1
on file
7. Number of schools that notified
employees in LEA
8. Number of LEAs that notified PTA
Public LEA
Site
visit
387
226,883
361
*128
101
8
77
9
Ques-
tion-
naire
401
236,743
367
105
98
9
81
10
Private LEA
Site
visit
315
116,248
314
278
264
7
264
8
Ques-
tion-
naire
309
116,186
308
265
265
7
265
10
Total
Site
visit
702
343,131
675
406
365
15
341
17
Ques-
tion-
naire
710
352,929
675
370
363
16
346
20
to
I
00
      Number Public LEAs visited  = 17
      Number Private LEAs visited = 21
     *Test  on differences between site and questionnaire data  are  significantly different from zero
      at  a  5 % level of significance.
      Situation at LEA as of January,  1984

-------
Inspection of Schools

    The field investigators inspected 73 public and 21 private
schools.   Three public schools and one private  school  had  not
been inspected prior to the site visits.   The investigators
found friable materials that the schools  missed during the LEAs'
inspections in 25 out of the 90 schools (28%).   Eleven of  these
25 did report some friable materials as present but their
reporting was incomplete; 14 of the 25 did not  report  any
friable materials present.  It is not known if  the friable
materials found during the site visits contain  asbestos as
these materials were not sampled or analyzed.   Twenty  of these
25 schools (80%) had friable materials which were limited  to the
boiler room.   Table 2 shows the results of the  school  inspections
Summary of Findings from Site Visits

    The results obtained during the site visits to LEAs compare
favorably to those obtained during the telephone interview for
both public and private schools (when restricting the public
school site visit data to the situation as it existed in January
of 1984).  The differences are small and seem to reflect a
degree of uncertainty at the LEA.  For instance, 6 of the 15
LEAs visited reported a different number of schools in their
LEAs at the time of the site visit than the numbers given on the
questionnaire.  The most common reason for differences is the
rapid turnover in personnel and the generally poor recordkeeping
at the LEAs and more often at the schools.  Although the sites
selected to be visited were purposefully drawn, the LEAs visited
in each site were urban and rural, large and small, and
represented a variety of socio-economic groups.  These LEAs  are
therefore felt to be generally representative of the population.
The statistics gathered during the  site visits  compared  favorably
with the survey statistics reported on  in  this  report.
                                3-9

-------
      Table 2.      Results of site visits to and inspections of schools
Item
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
Schools inspected by QA Monitor
Schools with friable materials
Schools with samples taken
Schools with lab reports on file
Schools with asbestos-containing friable materials
Schools that informed employees of ACFMs
Schools that posted Form 7730-3
Schools that notified parents
Schools with copies of notifications on file
Schools in which inspectors found friable materials
that schools missed
Schools in which inspectors found friable materials
in boiler rooms that schools missed
Public
schools
73
45
37
23
37
22
18
11
9
21
16
Private
schools
21
11
9
9
11
11
11
11
9
4
4
Total
schools
94
56
46
32
48
33
29
22
18
25
20
Ul
I

-------
    Sixty percent of public LEAs stated that they had informed
employees and parents in schools with asbestos-containing fri-
able materials.  An inspection of a number of schools in each
LEA revealed that some schools had informed employees and par-
ents and some had not.  The schools were more likely to inform
their employees than to inform parents.   In 8 of the 14 (57%)
public LEAs that found asbestos-containing friable materials,
the notification situation at the schools agreed with the infor-
mation given on the questionnaire.  In four LEAs (29%)  the
results were mixed; some schools had notified and some had not.
Two public LEAs (14%) said at the site visit and on the ques-
tionnaire that employees and parents had been notified, but this
proved not to be true according to the school officials.  It
appears that often LEAs are instructing their schools to notify
employees and parents, but this is not being carried out by the
schools.

    Three LEAs  said  they had  encapsulated, removed,  or  enclosed
their friable materials and therefore did not have to inform
parents under the provisions of the Rule.  LEAs were particularly
reluctant to inform parents when friable materials were found
only in boiler rooms.  In many schools, only the custodians are
informed when asbestos is limited to boiler rooms.

    In  25 out  of  90  schools  inspected by the field investigators,
friable materials were found  that the school officials  had missed
during their inspections.  In these 25 schools, 14 said they
had no friable materials prior to the field  inspection  and 11
said they found some friable materials.  The friable materials
found by the field investigators were limited to pipe wrap in
boiler rooms in 20 out of the 25 schools.  These findings would
indicate that the number of schools found  to contain friable
materials in the telephone survey is an  underestimate.  From  the
data collected during the telephone survey,  we  have  estimated
                               3-11

-------
 that 89 percent of the schools with friable materials have
 asbestos-containing friable materials.  Therefore, the estimated
 number of schools with ACFM and the estimate square footage of
 ACFM found in this survey are also likely to be low.  It is not
 possible to indicate the magnitude of the underestimate from the
 site visit data as the schools inspected were not selected to be
 statistically representative of any larger population but rather
 were selected to maximize the probability of finding problem areas


RESULTS OF COMPARISON OF  COMPLIANCE MONITORING EFFORTS WITH
QUESTIONNAIRES FOR  SELECTED LEAs

     The Environmental  Protection Agency has established Regional
Asbestos Coordinators  (RACs) and inspectors in each of its ten
regions to monitor  compliance with the Asbestos-In-Schools rule.
The inspector's responsibilities are to:   (1) inspect public
school districts, public  schools, and private schools;
(2) review records  kept at LEAs and at schools;  (3) ascertain if
warnings and notifications to employees and parents have been
properly made; and  (4)  determine if compliance with all Rule
requirements has been achieved.  The inspectors prepare an
asbestos compliance inspection report on each LEA visited.  The
reports for LEAs that matched those included in the sample for
this study were made available for comparison.  There were 80
matching compliance reports; 66 for public school districts and
14 for private schools.   The RAC reports were highly variable in
information, content, and completeness.  The RAC reports often
did not contain the same  information as did the questionnaires.
For example, on many forms the RAC reports told the number of
schools the inspectors  had visited, rather than the total number
of schools that had been  inspected in the LEA.  The latter was
needed to be comparable to the questionnaire data.  In addition,
the RAC inspectors  usually visited a subsample of schools in
each LEA.  The information given in the report referred to this
                                3-12

-------
subset of schools, rather than to all  the schools  in  the  LEA,
the unit of analysis on the questionnaire.   The  four  data items
common to the inspection reports and the telephone survey on
which the reports were compared are:

     1.   Number of schools in school  district;
     2.   Number of schools inspected;
     3.   Number of schools with friable materials, and
     4.   Number of schools where friable materials were
          sampled.

     Table 3 depicts the results of this analysis.

     We are using the paired t-test as a tool to assess whether
there are any important differences between the  RAG reports and
the questionnaire data.  The RAC reports do not  represent a
random sample as RAC inspectors are more likely  to visit  LEAs
they suspect are not in compliance with the rule.   It can be
hypothesized that larger differences would be found among these
LEAs as they would theoretically be more likely to conceal their
noncompliance during the telephone interview.  Based on the
results of the paired t-test, however, there is  no evidence to
suggest a significant difference between the RAC reports and the
questionnaire data.  The differences are approximately normally
distributed, that is, they do not tend to go in only one
direction.  For example, the RAC reports do not consistently
show more schools with friable materials than do  the question-
naire data.

     The paired t-test on the two comparisons showed that  there
were no significant differences between  the data  reported  by  the
RAC investigators and  the data collected during the  telephone
interviews.  The  test  conducted at  a  five  percent level  of
significance showed that the differences are not  significantly
different from  zero for each of the four variables.
                               3-13

-------
Table 3.      Results of comparison of EPA compliance  monitoring
              reports to LEA questionnaires
Item
1.
2.
3.
4.
Number of schools in LEA*
Number of schools inspected*
Number of schools with
friable materials**
Number of schools with
samples taken for analysis***
Number of
matching
pairs
74
68
51
34
Compliance
monitoring
report
3,274
1,720
752
457
LEA
question-
naire
3,221
1,651
748
481
  * p >.20
 ** p >.60
*** p >.10
Note:  A small P-value  (less than  .05) indicates that the results
       are unusual and  would cause us to reject the null hypothesis
       that the two samples are alike (within normal variability
       limits).  With large P-values, such as those above, we
       can conclude that there is no statistically significant
       difference between the compliance monitoring reports and
       questionnaire results.
                              3-14

-------
                           SECTION 4
                         SAMPLE DESIGN
     This section outlines the sample design and  selection  of
LEAs for this evaluation of the Asbestos-In-Schools  Identification
and Notification Rule.
CONSTRUCTION AND STRATIFICATION OF THE FRAME

     The study population was defined as all public and private
schools in the United States.  The frame from which the sample
was drawn consisted of a computer tape of public school districts
and private Catholic and non-Catholic schools.  The tape,  pro-
vided by Market Data Retrieval, Inc.  (MDR)  was current and
updated regularly.   The MDR data file consists of 34,195 public
and private local education agencies  which represent 101,121
schools nationwide.  Special schools, adult education or voca-
tional technical schools were not included in the sample leaving
98,756 schools in the target universe to whom the survey results
apply.

PROBABILITY SAMPLE DESIGN

     The frame was stratified by type of school (public, private
Catholic, private non-Catholic).  It was then sorted by state
and within state by enrollment.  A systematic sample of school
districts arid private schools was selected proportionate to the
square root of enrollment.  Probability proportionate to size
allocation is generally the most efficient system for aggregate
statistics in which the large units contribute disproportionately
to the aggregates;  equal probability is generally the best scheme
for estimates of proportions.  Since this survey was concerned
                               4-1

-------
with both types of statistics, allocation proportionate to the
square root of enrollment was a compromise between the two types
of estimates resulting  in substantially lower sampling errors
for proportions and only moderate increases for aggregates.
SAMPLE SIZE SPECIFICATION

     A sample of 1,800 public school districts was selected,
For private schools,  400 private Catholic and 400 private
non-Catholic schools  were selected.  The two private school
samples were combined to produce the analysis tables.
PRECISION OF THE ESTIMATES

     A variety of estimates are presented in this report
providing measures for characteristics of interest.  These
include estimates of  the percentages and totals of LEAs and
schools with a particular characteristic of interest and total
quantities such as total pupils and employees in schools with
ACFM.  It is important to keep in mind that these are survey
estimates and as such are subject to errors which can be
classified into two general categories:  sampling error and
nonsampling error.

     A measurement of sampling error is an assessment of the
precision of estimates obtained from a sample.  An estimate from
a sample will usually differ from the value derived from a com-
plete census of the study population.  Confidence intervals and
standard errors (standard deviations of an estimate) are
measures of the variability inherent in selecting a sample.  If
the sampling error is relatively small, the sample estimate is
likely to be close to the population measure that would have
                                4-2

-------
been obtained through a census, assuming that the effect of
nonsampling error on the estimates is minimal.

     Nonsampling error refers to all other sources of error that
might occur in a survey.  These include mistakes in entering
values on a questionnaire, misinterpretation of questions,
undetected data entry errors and nonresponse.  A census, as well
as a sample, is subject to nonsampling errors.   In general,
nonsampling errors cannot be measured from the data collected in
a survey.  Nevertheless, for this survey efforts have been  made
to assess the possible magnitude of such errors through site
visits to selected LEAs and a comparison of an independent  data
collection source (RAC reports) to the questionnaire data (see
Section 2) .

     The desired degree of precision and the expected losses in
the data collection process due to nonresponse were taken into
account when determining the sample size for this survey.  The
precision, or sampling variance, is a function of the population
variance, the sample design and the sample size.  The influence
of the sample design, called the design effect, was not a factor
in this study because a systematic sample  (which was used to
select our sample) is analogous to simple random sampling in
which there is no design effect.  To estimate the sample size
needed for this study, we calculated the confidence limits for
some proportions as:
                   Pq
               n = —
where E was the desired precision.  It was concluded that the
sample sizes specified above would be adequate to produce
national total estimates within a precision of 5 percent at  the
95 percent confidence level.  This indicates that one  can be
95 percent confident that the population percentage is within
plus or minus 5.0 percent of the estimate.
                               4-3

-------
                            SECTION  5
          STATISTICAL ANALYSES OF TELEPHONE SURVEY DATA
     After a clean edited data file was prepared, the file was
weighted to produce estimates of national totals.  The totals
and percentages presented in this report are estimates and were
calculated by multiplying the survey data collected by a sample
weight and a nonresponse adjustment (described below).

WEIGHTING

     The three samples — public school districts, private
Catholic, and private non-Catholic schools — were weighted
separately.  The weight is the inverse of the probability of
selection or the square root of enrollment divided by the
sampling interval.  A nonresponse adjustment was added to each
sample file.  Because the response rates were so high, overall
96.5 percent, the nonresponse adjustment had little effect on
the estimated percentages.  One nonresponse rate was created for
public school districts, one for private non-Catholic schools,
and one for private Catholic schools.  The nonresponse rates
were constructed using a ratio adjustment procedure to inflate
the sample results to the total number of school districts and
private schools in the universe file used to draw the sample.

     Tabulations were produced using the Statistical Analysis
System (SAS) package.  Totals may be off by one and percentages
by .1 due to rounding errors.
                               5-1

-------
VARIANCE ESTIMATION

     The survey  of LEAs  used a  fairly simple  sample design.
There were  three levels  of  stratification,  the  strata were
sorted by state  and  enrollment,  and  the  samples were selected
with probability proportionate  to  the square  root of enrollment.
A ratio estimation procedure was utilized to  adjust for
nonresponse.

     A balanced  half-sample replication  technique was used to
compute variance estimates  for  this  study.  This method requires
that the file be divided into strata of  two sets of selected
units each, and  that within each stratum one  set be assigned to
group 1 and the  other  to group  2.  Internal to  the computer
program used is  an orthogonal matrix which  designates (separately
for each stratum) whether it is  the  group 1 unit or the group 2
unit that is included  in the half  sample for  a particular repli-
cate.  To prepare the  data  file  for  variance  estimation, LEAs
were sorted in their order  of selection  and were grouped into
pairs to define  strata.   Identical statistics were prepared for
each replicate using the same weighting  procedure for each
replicate that was used  in  the survey itself.  The variation of
the estimates among  the  replicates provides a measure of the
survey sampling  errors for  the statistics.

     Variance estimates  were computed for 33  totals within the
following subgroups:

     1.   LEAs and schools  that  inspected for friable materials;
     2.   LEAs and schools  that  inspected and found friable
          materials; and
     3.   LEAs and schools  that  inspected,  sampled, and found
          asbestos-containing friable materials.
                                5-2

-------
     Totals of varying magnitude were chosen so that standard
errors were calculated for both common and rarer events.  The
coefficient of variation (CV) standardizes the standard deviation
by expressing it as a percentage of the mean (s/x).  Since
standard errors vary with different questions, the CVs can be
compared to describe the relative amount of variation in the
answers to each question.  The resulting coefficients of variation
for totals ranged from 1.5 percent for the number of public LEAs
with an inspection program to 26.8 percent for the number of
private schools with asbestos-containing friable materials that
scheduled abatement work in the future.

     As one would expect, estimates for small subpopulations
tended to have higher coefficients of variation.  Totals and
their estimated standard errors, coefficients of variations, and
upper and lower 95 percent confidence bounds follow in Table 4.

     Also included are the estimated percentages along with their
half-width 95 percent confidence interval.  To interpret the
plus or minus factor indicated in the table for an estimated
percentage of LEAs or schools, the true value of the percentage
with a particular characteristic is covered with 95 percent
confidence by an interval centered at the estimated percentage
and extended on either side of the estimate by the - percentage
shown.
RESULTS OF STATISTICAL ANALYSES
Characteristics of LEAs

     The universe used for this survey was public  school  districts
and private schools.  School districts that  included  only voca-
tional technical, special education, or adult education schools
                                5-3

-------
 Table 4.   Coefficients of variation, standard errors,  and confidence boundaries for selected totals
Item

LEAs
1. Total LEAs with inspection program
2. Public LEAS with inspection program
3. Private LEAs with inspection program
4. Total LEAs that completed
inspect ions**
5. Public LEAs that completed
inspections**
6. Private LEAs that completed
inspections**
7. Total LEAs with friable materials
8. Public LEAs with friable materials
9. Private LEAs with friable materials
10. Total LEAS with ACFK*
11. Public LEAs with ACFM*
12. Private LEAs with ACFM*
SCHOOLS
1 . Total schools inspected
2. Public schools inspected
3. Private schools inspected
4. Total schools with friable materials
5. Public schools with friable materials
6. Private schools with friable materials
7. Total schools with ACFM*
8. Public schools with ACFM*
9. Private schools with ACFM*
10. Total schools with ACFM* that
notified employees
11. Public schools with ACFM» that
notified employees
12.Privste schools with ACFM* that
notified employees
13. Total schools with ACFM* that
notified parents
14. Public schools with ACFM* that
notified parents
15.Privste schools with ACFM* that
notified parents
16. Total schools with completed or
ongoing abatement work
17. Public schools with completed or
ongoing abatement work
18. Private schools with completed or
ongoing abatement work
19. Total schools with abatement
work scheduled
20. Public schools with abatement
work scheduled
21. Private schools with abatement
work scheduled
Estimated
total


27,887
13,792
14,095

26,936

13,364

13,572
12,229
7,418
4,811
11,031
6,842
4,189

89,312
74,607
14,705
34,821
29,433
5,388
30,830
26,136
4,693

24,394

20,820

3,574

23,067

19,482

3,585

20,599

17,627

2,972

7,134

6,014

1,120
Coefficient
of variation


1.7
1.5
3.0

1.9

1.7

3.1
M
2.7
7.7
3.8
2.9
8.9

2.6
3.2
4.1
4.2
4.7
9.7
4.4
4.9
10.5

5.6

6.2

12.3

6.8

7.6

12.0

3.9

4.5

11.5

11.4

12.6

26.8
Standard
errors
variance
(000 's)


477
202
417

500

222

423
415
197
369
424
198
373

2,339
2,370
610
1,466
1,384
524
1,346
1,292
491

1,366

1,283

440

1,559

1,471

431

813

797

343

813

760

300
Confidence
interval
lower upper


26,951 28,822
13,396 14,188
13,277 14,913

25,956 27,916

12,928 13,800

12,743 14,401
11,416 13,042
7,031 7,805
4,088 5,534
10,200 11,862
6,454 7,230
3,458 4,919

84,729 93,897
69,961 79,253
13,510 15,901
31,948 37,694
26,721 32,145
4,362 6,415
28,191 33,469
23,605 28,668
3,731 5,656

21,716 27,072

18,306 23,334

2,713 4,436

20,012 26,123

16,599 22,366

2,741 4,429

19,005 22,193

16,065 19,189

2,300 3,643

5,540 8,729

4,525 7,503

533 1,708
Estimated
percentage


84.6
95.1
76.4

96.6

96.9

96.3
44.6
54.3
35.0
90.2
92.2
87.1

93.5
98.0
75.6
39.0
39.5
36.6
34.5
35.0
31.9

79.1

79.7

76.2

74.8

74.6

76.4

66.8

67.4

63.3

23.1

23.0

23.9
Half-widt-
95S confioe
interval o<
percentage ;


2.8
2.7
4.2

3.5

3.2

5.9
3.0
2.8
5.3
6.8
5.2
15.2

4.8
6.1
8.1
3.2
3.6
7.0
3.0
3.4
6.5

8.7

9.6

18.4

9.9

11.0

18.0

5.2

6.0

14.3

5.2

5.7

12.5
* Asbestos-containing friable material
••As of 1/1/84 for all LEAs
                                                                 5-4

-------
Table 4.  Coefficients of variation, standard errors,  and confidence boundaries for  selected  totals  (continued)
Item

COMPLIANCE
1. LEAs complying with all aspects
by June, 1983
2. Public LEAs complying with all
aspects by June, 1983
3. Private LEAs complying with all
aspects by June, 1983
4. LEAS with ACFM complying with
all aspects by June, 1983
5. Public LEAs with ACFM complying
with all aspects by June, 1983
6. Private LEAs with ACFM complying
with all aspects by June, 1983
Estimated
total



2,899

1,529

1,370

212

122

90
Coefficient
of variation



9.3

9.3

12.2

28.9

25.6

63.4
Standard
errors
variance
(OOO's)



142

142

171

61

31

57
Confidence
interval
lower upper



2,620 3,180

1,251 1,806

1,061 1,731

92 332

61 184

0 201
. Estimated
percentage



10.9

11.4

10.3

2.0

1.8

2.2
Half-wicrh
95S confidence
interval on
percentage •*•&



1.4

2.0

2.5

1.1

.9

2.6
* Asbestos-containing friable material
••As of 1/1/84 for all LEAs
                                                            5-5

-------
were  not  included.   In some instances,  a private school  reported
for more  than one school.   These private school  LEAs were either
dioceses  reporting for more than one Catholic  school under  its
jurisdiction or  private non-Catholic school  buildings  that  housed
more  than one school.

      For  this study, we are characterizing 34,195 LEAs;  14,593
are public school districts and 19,602  are private LEAs.  By
January 1, 1979  the spraying of materials containing more than
one percent asbestos and the installation of asbestos-containing
molded insulating material  in school buildings had been  forbidden
by law.   This study was restricted to LEAs with  at least one
school built before that date of which  there are 32,946; 14,505
are public and 18,441  are private LEAs.   There are 95,566 schools
in these  LEAs; 76,118  are public and 19,448  are  private  schools.
Table 5 presents a summary  of characteristics  of LEAs.

      There are an estimated 44,406,740  students  enrolled nation-
wide; 39,295,701 students are enrolled  in public schools and
5,111,039 in private schools.   There were 32,946 LEAs with  at
least one school built prior to January 1, 1979;  14,505  (99%) are
public and 18,441 (94%)  are private LEAs.  Of  these LEAs 27,887
(85%) have an inspection program;  13,792  (95%) of the public and
14,095 (76%)  of  the private LEAs.
Characteristics  of  Inspection Programs

     Of the LEAs that did  not have an inspection program, 2,626
(52%) claimed exemption  to the Asbestos-In-School Rule.  Of the
LEAs that claimed exemption, 2,167 (83%) were private schools.
The main reason  given for  the exemption claim, shown in Table 6,
was that the LEA could document that no asbestos-containing
materials were used in the construction of their schools.
                               5-6

-------
Table 5.  Characteristics of public and private LEAs as of January, 1984
a. Number of LEAs
b. Number of LEAs with schools
built before 1/1/79*
c. Number of LEAs that have
completed, begun or planned
an inspection program**
d. Number of LEAs that have
completed or begun •
inspections***
e. Number of LEAs with one
or more schools having
asbestos-containing
friable materials****
Public
14,593

14,505

13,792

13,673

6,842
Percent
100.0

99.4

95.1

94.3

50.0
Private
19,602

18,441

14,095

13,749

4,189
Percent
100.0

94.1

76.4

74.6

30.5
Total
34,195

32,946

27,887

27,422

11,031
Percent
100.0

96.3

84.6

83.2

40.2
*    %
**   %
***  %
**** %
b/a
c/b
d/b
e/d

-------
Table 6.  For LEAs claiming exemption to rule, reason for exemption1"
Reason
a. LEA was inspected,
sampled and analyzed
prior to the effective
date of the rule
b. The LEA can document
that no asbestos-
containing building
materials were used in
construction
c. Abatement programs have
resulted in elimination
of all friable
materials
No reason given
Total
Private
Estimate
40


331

35
53
459
Percent
8.7


72.2

7.6
11.5
100.0
Public
Estimate
152


1,586

52
377
2,167
Percent
7.0


73.2

2.4
17.4
100.0
Total
Estimate
193


1,917

86
430
2,626
Percent
7.3


73.0

3.3
16.4
100.0
*For LEAs with at least one school built before January 1, 1979 that have no
 inspection program.


                         Situation at  LEA as  of  January, 1984
                                       5-8

-------
     Most of the inspections (39%)  were conducted  by the  school
or school district.   Private companies or consultants conducted
26 percent of all inspections.   Some inspections were done  by
state or county agencies (19%)  or with the assistance of  the  EPA
compliance monitors (5%).   Overall, 75 percent of  all inspections
had been completed by the end of the compliance period, June  28,
1983.  As of the date of this survey, January, 1984, 98 percent
of all inspections (for LEAs that have an inspection program)  had
been completed or begun.  Of the LEAs with an inspection  program,
464 (2%) have scheduled an inspection for the future. Of the
planned inspections,  79 percent are scheduled to begin before
July, 1984; the remaining 21 percent do not know when they will
begin.

     EPA has an ongoing Technical Assistance Program (TAP)  for
friable materials inspections that includes a toll-free  number,
regional technical advisors to assist schools, and written guide-
lines for schools.  Table 7 shows that the TAP was used  by 4,894
(36%) of the public LEAs and 3,671 (27%) of the private  LEAs that
have begun or completed inspections.  Ninety-four  percent of the
public and 95 percent of the private LEAs that used the  TAP
reported that it met their needs.  Table 8 shows a list  of the
documents provided under the TAP and the number and percent of
LEAs that used each document for public and private LEAs.

     All LEAs that completed inspections were required by the
rule to maintain a copy of Form 7730-1, "Inspections for Friable
Asbestos-Containing Materials" on file.  Of the LEAs that had
completed or begun inspections, 5,468  (40%) of the public and
3,352 (24%) of the private LEAs had Form 7730-1 on  file.  Table 9
shows the LEAs that have the form on file and  the date they
completed it.  A small percentage  (2%)  of those who  did  not have
Form 7730-1 on file did have on file Form 7710-29,  "Asbestos
Survey Report," the form that was used  prior  to June 1982.  Of
                               5-9

-------
   Table  7.  The  use  of  the  EPA Technical Assistance Program*
Item
LEAs using EPA Technical Assistance
Program ( TAP ) :
LEAS that did not use TAP
LEAs that used TAP
TAP met needs
TAP did not meet needs
Public
Estimate

8,269
4,894
4,583
311
Per-
cent

64.2
35.8
93.6
6.4
Private
Estimate

9,005
3,671
3,497
174
Per-
cent

73.3
26.7
95.3
4.7
Total
Estimate

17,275
8,565
8,080
485
Per-
cent

68.8
31.2
94.3
5.7
Ul
I
   NOTE:   TAP consists of a toll-free telephone number,  regional  technical  advisors to
          assist schools, and written guidelines for schools.

   *For LEAs with at least one school built before January 1,  1979,  that  have
    begun or completed inspections.
    Situation at LEA as of January,  1984.

-------
Table 8.  Number of LEAs that had and used EPA guidance documents to conduct inspections*
Document
Total LEAs that have completed or begun
inspections as of January 1, 1984
1. "Compliance Assistance Guidelines:
Friable Asbestos-Containing Materials
' in Schools; Identification and
Notification Rule
2. "Asbestos-Containing Materials in School
Buildings: A Guidance Document, Part I"
(Orange Book)
3. "Asbestos-Containing Materials in School
Buildings: A Guidance Document, Part II"
(Orange Book)
4. "Asbestos-Containing Materials In School
Buildings: Guidance for Asbestos
Analytical Programs" (Black Book)
5. "Guidance for Controlling Friable
Asbestos-Containing Materials in
Buildings" (Blue Book)
6. Other Document
Private
Schools
Estimate
13,673
2,306
3,826
3,676
891
1,120
889
Per-
cent
100.0
19.0
28.0
26.9
6.5
8.2
6.5
Public
Schools
Estimate
13,749
1,017
2,546
2,426
394
601
1,091
Per-
cent
100.0
7.4
18.5
17.6
2.9
4.4
7.9
Total
Estimate
27,422
3,323
6,371
6,101
1,285
1,721
1,980
Per-
cent
100.0
12.1
23.2
22.2
4.7
6.3
7.2
* Percent of LEAs that have and used each document.
  Categories are not mutually exclusive.

-------
     Table 9.   LEAs with and without Form 7730-1,  "Inspections  for  Friable
               Asbestos-Containing Materials"
Status of Form 7730-1
Form 7730-1 not on file
Form 7730-1 on file
For LEAS WITH Form 7730-1 on file
Completed before 7/1/83
Completed after 7/1/83
Date not known
Public
Estimate
8,205
5,468
13,673

3,425
1,237
806
5,468
Per-
cent
60.0
40.0
100.0

62.6
22.6
14.7
100.0
Private
Estimate
10,397
3,352
13,749

2,000
845
507
3,352
Per-
cent
75.6
24.4
100.0

59.7
25.2
15.1
100.0
Total
Estimate
18,602
8,820
27,422

5,425
2,082
1,313
8,820
Per-
cent
67.8
32.2
100.0

61.5
23.6
14.9
100.0
Ul
     *For LEAs with at least one school built before January 1, 1979 that have begun or
      completed inspections.
      Situation at LEA as of January, 1984

-------
those that had Form 7730-1 on file, 5,425 (62%)  had completed the
form before the end of the compliance period, June 28,  1983.
Compliance Results

     Table 10 shows the LEAs that complied with all aspects of
the rule by the end of June, 1983.  An LEA was considered in
compliance if it met the criteria listed in Table 11.  LEAs were
considered in compliance with most aspects of the rule if they
met the criteria listed in Table 12.

     For Table 13, each of the four major provisions of the rule
was dropped one at a time from the analysis.  The purpose was to
highlight the major problem areas of noncompliance.  For LEAs
that completed inspections, a large number failed to comply with
the notification and the documentation aspects of the rule.
LEAs with at least one school with ACFM failed most often to
comply with the notification aspects of the rule.
Inspection Results

     The results of inspections detailed in this section apply
to LEAs that have at least one school built before January 1,
1979 and that have completed or begun inspections.  Table 14
shows the results of inspections for schools as of January 1,
1984.  Inspections had been completed for 74,607 (98%) of the
public schools and 14,705 (76%) of the private schools in the
nation.  Of the inspected schools, 29,433 (39%) of the public
and 5,388 (37%) of the private were found to contain friable
materials.  In public and in private schools with friable
materials, 30,830 (89%) of the schools were found to have
asbestos-containing friable materials.  Table 15 shows the
                              5-13

-------
      Table 10.   LEAs that complied with the Asbestos-In-Schools  Rule*

LEAs that complied
1. LEAs that complied with all aspects
of the Rule* by June 28 , 1983
Complied
Did not comply
2. LEAs that complied with most aspects
of the Rule by January, 1984**
Complied
Did not comply
3. LEAs with asbestos-containing friable
materials that have completed
inspections that complied with most
aspects of the Rule* by January, 1984**
Complied
Did not comply
4. LEAs that complied with most aspects of
the Rule (except notification) by
January, 1984***
Complied
Did not comply
Public

Estimate

1,529
12,976
14,505

5,179
9,326
14,505

1,393
5,449
6,842

7,377
7,128
14,505
Per-
cent

10.5
89.5
100.0

35.7
64.3
100 -.0

20.4
79.7
100.0

50.9
49.1
100.0
Private

Estimate

1,370
17,071
18,441

5,872
12,569
18,441

955
3,234
4,189

7,107
11,334
18,441
Per-
cent

7.4
92.6
100.0

31.8
68.2
100.0

22.8
77.2
100.0

38.5
61.5
100.0
Total

Estimate

2,899
30,047
32,946

11,050
21,896
32,946

2,348
8,683
11,031

14,484
18,462
32,946
Per-
cent

8.8
91.2
100.0

33.6
66.4
100.0

21.3
78.7
100.0

44.0
56.0
100.0
en
      *   See Table 11.
      **  See Table 12.
      *** 1.  All schools in LEA built before January 1, 1979 were inspected.
          2.  LEAs have some documentation on file describing inspection results.
          3.  LEA took some samples of friable materials for analysis.

-------
 Table 11.   Asbestos-In-Schools Rule requirements  to  be  met  by
            June 28,  1983*
 1.    Inspect all  school  buildings for  friable materials.

 2.    Sample all friable  materials (at  least three  samples  per
      homogeneous  sampling area)  unless all  friable materials are
      declared in  writing to contain asbestos.

 3.    Analyze bulk samples using  polarized light  microscopy.

 4.    Notify custodians (using Form 7730-2), all  employees  (using
      Form 7730-3) and parents if asbestos is found.

 5.    Keep records at LEA on Form 7730-1.   Schools  must  keep
      records on where asbestos is located and keep copies  of all
      notifications.
 Table 12.   Compliance requirements for LEAs that met most
            aspects of the Rule*


 1.   Inspect all school buildings for friable materials.

 2.   Sample any friable materials.

 3.   Notify employees and parents if asbestos is found.

 4.   Keep records at the LEA. .


*For LEAs with at least one school built before January 1, 1979
 that have completed inspections

 Situation at LEA as of January 1984.
                                5-15

-------
Table 13.  Areas of noncompliance with most aspects of the Asbestos-In-Schools Rule by January,  1984

Total LEAs with at least one school built before
January. 1979
LEAs that complied with most aspects of the rule
LEAs that did not complete inspections
LEAs that inspected, sampled and documented,
but did not notify employees and/or parents
LEAs that inspected, documented and notified,
but did not sample and analyze
LEAs that inspected, sampled, notified,
but did not document
LEAs that did not comply with more than one aspect
of the rule
Total LEAs with at least one school with ACFM
LEAs with ACFM that complied with most aspects
of the rule
LEAs with ACFM that did not inspect all their schools
LEAs with ACFM that inspected, sampled and documented,
but did not notify employees and/or parents
LEAs with ACFM that inspected, documented and notified,
but did not sample
LEAs with ACFM that inspected, sampled, notified,
but did not document
LEAs with ACFM that did not comply with more than one
aspect of the rule
Public LEAs
Estimate
14,505
5,179
1,497
2,198
453
2,325
2,853
6,842
1,393
216
2,198
387
269
2,379
Percent
100.0
35.7
10.3
15.2
3.1
16.0
19.7
100.0
20.4
3.2
32.1
5.7
3.9
34.8
Private LEAs
Estimate
18,441
5,871
4,908
1,236
449
4,413
1,564
4,189
955
-
1,236
401
254
1,343
Percent
100.0
31.8
26.6
6.7
2.4
23.9
8.5
100.0
22.8
-
29.5
9.6
6.1
32.1
Total LEAs
Estimate
32,946
11,050
6,405
3,434
902
6,738
4,417
11,031
2,347
216
3,434
788
484
3,762
Percent
100.0
33.5
19.4
10.4
2.7
20.5
13.4
100.0
21.3
2.0
31.1
7.1
4.4
34.1

-------
     Table  14.   Results of  inspections in schools  as  of  January,  1984
Item
a. Number of schools built before
January lf 1979
b. Number of schools inspected
c. Number of schools with .friable materials**
d. Number of schools with samples
analyzed for asbestos*** *
e. Number of schools with asbestos-containing
friable materials****
f . Number of schools with abatement work
completed or begun*****
Public
schools
Estimate
76,118
74,607
29,433
24,379
26,136
17,627
Per-
cent
100.0
98.0
39.5
32.6
35.0
67.4
Private
schools
Estimate
19,448
14,705
5,388
4,259
4,693
2,972
Per-
cent
100.0
75.6
36.6
29.0
31.9
63.3
Total
Estimate
95,566
89,312
34,821
28,638
30,830
20,598
Per-
cent
100.0
93.5
39.0
32.1
34.5
66.8
en
I
     *     Some LEAs  treated  all  friable  materials as asbestos-containing and did not sample.
     **    % = c/b
     ***   % = a/b
     ****  % = e/b
     ***** % = f/e

-------
 Table 15.  Total square footage, employees and students in schools with asbestos-containing
            friable materials and total square footage by abatement work completed**/
Item
1. Total area in square feet
of all friable asbestos-
containing materials.
2. Total number of school employees
who regularly work in school-s
where asbestos-containing friable
materials were found.**
3. Total number of teachers.
administrators and other
professional staff in schools
where asbestos-containing friable
materials were found.
4. Total number of custodians in
schools where asbestos-containing
friable materials were found.
5. Total number of other
non-professional and support
staff in schools where asbestos-
containing friable materials
were found.
6. Total number of students enrolled
in schools where asbestos-
containing friable materials
were found.
7. Total number of square feet
that have been removed.
8. Total number of square feet
that have been enclosed.
9. Total number of square feet
that have been encapsulated.
10. Total number of square feet being
monitored by an operations/
maintenance/reassessment program.
Public
Estimate
153,547,168


1,237,970



804,646




96,162


222,568




13,401,796



28,819,874

5,144,349

41,037,348

14,510,668


% of
Total
90.7


89.3



88.2




87.5


90.7




89.1



95.1

87.9

94.0

96.2


Private
Estimate
15,738,086


147,746



107,989




13,734


22,819




1,632,778



1,484,887

705,221

2,597,107

568,638


% of
Total
9.3


10.7



11.8




12.5


9.3




10.9



4.9

12.1

6.0

3.8


Total
169,285,254


1,385,716



912,635




109,896


245,387




15,034,574



30,304,761

5,849,570

43,634,455

15,079,306


— For LEAs with at least one school built before January 1, 1979, that have begun or completed
  inspections.

  Situation at LEA as of January, 1984

 *Does not include pipe wrap and not adjusted for item nonresponse.

**Some LEAs reported "total" but did not break figures down by category; hence (3, 4 and 5)  do not
  total to (2).
                                            5-18

-------
total square footage, employees and students in schools with
asbestos-containing friable materials.

     There is a total of 169,285,254 square feet of asbestos-
containing friable materials in schools.  This figure does not
include pipe wrap as it is difficult for LEAs to provide accurate
estimates for pipe/boiler insulation.  In addition, a small
percentage of LEAs (8%) did not know the square footage of ACFM
in their schools.  No adjustment was made for these nonresponding
LEAs.  Of the square footage reported in schools, 18 percent
(30,304,761) had been removed, 3 percent (5,849,570) had been
enclosed in an air-tight barrier, and 26 percent (43,634,455)
had been encapsulated using a sealant.  Special operations and
maintenance procedures and periodic reassessment are being
conducted on nine percent (15,079,306) of the square footage
with ACFM.

     There are 15,034,574 students and 1,385,716 employees in
schools where ACFM has been found.  Of all public schools
inspected, 35 percent have asbestos-containing friable materials,
and 34 percent of all students are enrolled in public schools
where asbestos-containing friable materials were found.  Among
private schools, 32 percent have asbestos-containing friable
materials and 32 percent of all students are enrolled in such
schools.  Overall, 4,971 (45%) of the LEAs reported that the
friable materials found were limited to pipe wrap  in boiler
rooms; 2,710 (40%) of the public and 2,261  (54%) of the private
LEAs.  Direct access to boiler/pipe insulation is  usually  limited
to custodial and maintenance personnel.  However,  asbestos  fibers
released from insulation can be transported to other areas  of  a
school and is therefore of concern.  Table  16  shows the percent
of asbestos-containing friable materials found in  pipe wrap at
LEAs.  Of the LEAs with ACFM, 7,869  (71%) reported finding some
in pipe wrap.
                               5-19

-------
       Table 16.   Percent of asbestos-containing friable materials in pipe wrap in LEAs'
Percent pipe wrap
0 (No ACFM found in .pipe wrap)
1-24
25-49
50-74
75-99
100 (All ACFM found in pipe wrap
Not specified
Total
Public LEA
Estimate
1,939
1,373
218
251
274
2,710
78
6,842
Percent
28.4
20.1
3.2
3.7
4.0
39.6
1.1
100.00
Private LEA
Estimate
1,222
433
21
41
161
2,261
50
4,189
Percent
29.2
10.3
0.5
1.0
3.9
54.0
1.2
100.00
Total
Estimate
3,162
1,806
238
292
435
4,971
127
11,031
Percent
28.7
16.4
2.2
2.6
3.9
45.1
1.2
100.00
in
I
       For LEAs with at least one school built before January 1, 1979, that inspected
       and found asbestos-containing friable materials in one or more schools.
       Situation at LEA as of January 1984.

-------
Date of Construction

     Table 17 shows the number of schools by decade that were
found to have asbestos-containing friable materials.  It also
shows the percentage of all schools built during each decade
that have asbestos-containing friable materials.  The table
shows the use of asbestos-containing materials dropped con-
siderably from 1969-1978.  The use of asbestos-containing
materials in schools from 1899-1968 remained fairly constant by
decade.
Sampling and Analysis Information

     There were 10,261 LEAs that sampled friable materials and
sent them to be analyzed; 6,490 of the public and 3,772 of the
private LEAs.  Public LEAs reported that, on the average, 2,231
(34%) took fewer than the required three samples of friable
materials from each homogeneous sampling area.  Similarly,
private LEAs reported that 1,367 (36%) took fewer than three
samples per sampling area.  Complete test results were received
from samples of friable materials by the end of the compliance
period, June 28, 1983 for 4,580 (71%) of the public and 2,701
(72%) of the private LEAs.
                                5-21

-------
       Table 17.   Schools where ACFM were found, by construction date*
Period of Construction
1969-1978
1959-1968
1949-1958
1939-1948
1929-1938
1919-1928
1909-1918
1899-1908
Before 1899
Public schools
Estimate
1,472
6,073
7,072
1,627
2,132
2,453
1,198
556
348
Percent**
13.5
34.3
37.8
32.2
32.6
36.1
35.2
39.4
37.1
Private schools
Estimate
126
1,368
1,337
429
302
349
331
132
311
Percent**
3.7
28.3
30.1
33.1
31.6
20.2
34.3
19.6
31.2
All schools
Estimate
1,598
7,441
8,409
2,055
2,434
2,802
1,529
688
659
Percent**
11.1
33.0
36.3
32.4
32.5
32.8
35.0
33.0
34.1
Ul
I
NJ
to
      *For inspected schools built before January 1, "1979 in which asbestos-containing
       friable materials were found  for which the date of construction was known.
       Situation at LEA as of January, 1984.


     **The percents in this table are the estimated schools with ACFM in decade divided by the
       estimate of the total number of schools built during the same decade (see Table 2 in
       Appendix A).

-------
Notification to Employees and Parents

     The following results apply to schools built before
January 1, 1979 and that have completed inspections and that
were found to have asbestos-containing friable materials.   There
are 11,031 LEAs with at least one school with ACFM; 6,842  of the
public and 4,189 of the private.  There are 30,830 schools with
ACFM; 26,127 of the public and 4,693 of the private.  Table 18
shows the number of schools that complied with the requirement
to notify school employees.  In public schools, 20,820 (80%)
notified their school employees.  In private schools, 3,574
(76%) notified school employees.  Of the LEAs that notified
school employees, 2,519 (46%) public and 1,275 (39%) private
used EPA Form 7730-3, "Notice to School Employees."   By the end
of the compliance period, June 28, 1983, 16,724 (69%) of the
schools had at least begun to notify school employees in their
schools with ACFM.

     Table 19 shows the results of notifications to PTAs or PTA
equivalents for public and private schools.  Public schools
reported to have informed parents in 19,482 (75%) of their
schools, while private schools informed 3,586  (76%) of their
students'  parents.  Fifty-two percent (4,196 out of 8,088) of
LEAs that informed parents had begun to notify them before the
end of the compliance period.
Abatement Work in Schools with ACFM

     The rule does not require schools to take abatement action.
However, when asbestos-containing friable materials are identi-
fied, schools may choose to undertake corrective action.  There
are four basic types of abatement:   (1) removal of all friable
material containing asbestos;  (2) enclosure of the material with
                              5-23

-------
      Table  18.
Compliance with employee notification requirements for LEAs that found asbestos-containing
friable materials*

Item
Schools with asbestos-containing friable materials
Schools notified employees
Schools did not notify employees
Total
Schools that notified employees
Date 1st notice provided to a school in the LEA
Before 7/1/83
After 7/1/83
Date not known
Total
LEAs with at least one school with ACFM
LEAs that notified employees
LEAs that did not notify
Total
LEAs that notified employees
Method used to inform
Used Form 7730-3
Notice posted/official letter
Staff meeting
Other
Total
Public
Estimate

20,820
5,316
26,136


14,600
5,319
901
20,820

5,529
1,313
6,842


2,519
1,239
933
836
5,529
Percent

79.7
20.3
100.0


70.1
25.6
4.3
100.0

80.8
19.2
100.0


45.6
22.4
16.9
15.1
100.0
Private
Estimate

3,574
1,119
4,693


2,124
1,100
350
3,574

3,242
947
4,189


1,275
515
1,169
284
3,242
Percent

76.2
23.8
100.0


59.5
30.7
9.8
100.0

77.4
22.6
100.0


39.3
15.9
36.0
8.8
100.0
Total
Estimate

24,394
6,436
30,830


16,724
6,429
1,251
24,394

8,771
2,260
11,031


3,794
1,755
2,102
1,120
8,771
Percent

79.1
20.9
100.0


68.6
26.3
5.1
100.0

79.5
20.5
100.0


43.2
20.0
24.0
12.8
100.0
Ul
       *For LEAs with at least one school built before January 1, 1979, that inspected and found asbestos-containing
        friable materials in one or more schools.
        Situation at LEA as of January 1984.

-------
     Table  19.   Schools  that provided notice to parents  and date  first notice made from LEA with
                 asbestos-containing friable  materials*
Item
Schools with asbestos-containing
friable materials
School did not notify parents
School notified parents
Total
Date first notice made from LEA
Before 7/1/83
After 7/1/83
Date not known
Total LEAs that notified parents
Public
Estimate
6,654
19,482
23,136
2,701
1,549
585
4,835'
Per-
cent
25.5
74.5
100.0
55.9
32.0
12.1
100.0
Private
Estimate
1,108
3,586
4,693
1,495
1,435
323
3,253
Per-
cent
23.6
76.4
100.0
46.0
44.1
9.9
100.0
Total
Estimate
7,763
23,067
30,830
4,196
2,984
908
8,088
Per-
cent
25.2
74.8
100.0
51.9
36.9
11.2
100.0
en
I
to
     *For LEAs with at  least one  school built before January  1,  1979, that inspected and

      found asbestos-containing friable materials  in one or more school.
      Situation at LEA as of January,  1984

-------
 an  air-tight,  impact resistant barrier;  (3)  encapsulation  of  the
 friable material  by the use of a sealant;  and  (4)  special  opera-
 tions  and maintenance procedures and periodic  reassessment which
 can be used to monitor the building for  needed abatement
 activities at  a future time.   It should  be noted  that  the  results
 presented here do not distinguish between  abatement  for spray-
 applied ceiling,  wall and structural steel coatings  and pipe/
 boiler/hot water  tank insulation.   The following  survey results
 apply  only to  LEAs and schools in which  some asbestos-containing
 friable materials were found and reflect the status  of the LEA
 or  school as of January, 1984.

     Abatement work has been completed in  11,436  (44%) of  the
 public schools and in 2,050 (44%)  of the private  schools with
 ACFM.   Abatement  work is currently ongoing in  6,191  (24%)  of the
 public schools and in 922 (20%)  of the private schools.  In
 public schools, 6,014 (23%) are planning abatement for the
 future as are  1,120 (24%) of the private schools.  Nine.percent
 of  the public  schools and 12 percent of  the  private  schools have
 no  abatement plans.  Table 20 shows the  status of abatement work
 in  schools by  the method of abatement.   Public schools have
 encapsulated in 8,335 (78%) of the schools and enclosed friable
 materials in 2,216 (62%)  of the schools.   Costs are  given  for
 removal,  encapsulation and enclosure work  that has been completed.
 It  should be noted that an effective enclosure or encapsulation
 effort must also  include an operations maintenance and periodic
 reassessment (0/M/R)  program for the remainder of the time the
 asbestos-containing friable materials stay in  the building.
 O/M/R  costs are not readily quantifiable but are  incurred  for
 maintenance repairs,  frequent visual  inspections, and annual
 re-evaluations.   These costs  are not  included  in  the data
presented in Table 21.   The actual  costs of  future abatement per
 square  foot may increase  greatly from those  shown in Table 21
depending on the  size of  the  project, the  field conditions, the
                               5-26

-------
Table 20.  Number of schools doing abatement,  by type  of abatement  and  status  of
           abatement work*
Status of
abatement work
in schools
Public Schools
Completed
Ongoing
Planned
Total
Private Schools
Completed
Ongoing
Planned
Total
Type of abatement
Removal
Estimate
6,064
486
3,772
10,323
1,050
116
565
1,730
Per-
cent
58.8
4.7
36.5
100.0
60.7
6.7
32.6
100.0
Enclosure
Estimate
2,216
564
818
3,598
774
49
139
962
Per-
cent
61.6
15.7
22.7
100.0
80.4
5.1
14.5
100.0
Encapsulation
Estimate
8,335
618
1,698
10,651
1,343
107
306
1,757
Per-
cent
78.3
5.8
15.9
100.0
76.5
6.1
17.4
100.0
Monitoring
Estimate
2,545
6,461
2,370
11,377
255
819
282
1,356
Per-
cent
22.4
56.8
20.8
100.0
18.8
60.4
20.8
100.0
Note:  Categories are not mutually exclusive.
       A school may be doing more than one type of abatement work.
*For inspected schools built before January 1, 1979 in which asbestos-containing
 friable materials were found and which use some method of abatement.
                            Situation at LEA as of January, 1984
                                        5-27

-------
necessary reconstruction items, the stringency of the specified
work practices, and the acceptable quality assurance.  The cost
estimates presented in Table 21 are based on small numbers of
respondents and are therefore subject to large sampling errors.

     Table 22 shows the average number of square feet abated
which has been completed in schools.  Most asbestos-containing
friable materials have been maintained and periodically
reassessed (9,780 square feet per school in public and 3,869
square feet per school in private schools on the average).  More
friable materials have been encapsulated (an average 7,341 square
feet in public and 3,291 square feet in private schools) than
were removed.  On the average, 4,823 square feet in public and
1,515 square feet in private schools have been enclosed.

     Nationwide an estimated 30,304,761 square feet of ACFM have
been removed from schools, 43,634,455 square feet of ACFM have
been encapsulated using a sealant and 5,849,570 square feet of
ACFM have been enclosed in an air-tight impact resistant barrier.
                              5-28

-------
Table 2'1.   Average cost per square foot of abatement in schools
           in which work has been completed1'  2,  3
Type of abatement
Removal
Enclosure
Encapsulation
Average cost
Public
schools
3.37
2.84
2.42
Private
schools
3.06
6.12
4.84
Total
schools
3.34
3.99
2.65
Table 22.  Average square feet in schools by method of abatement
           for schools that have completed work1
                                  Average square feet abated
Type of abatement
Removal
Enclosure
Encapsulation
Operations/maintenance/
reassessment
Public
schools
6,908
4,823
7,341
9,780
Private Total
schools schools
2,400
1,515
3,291
3,869
6,338
3,958
6,853
9,293
 For inspected schools built before January 1, 1979 in which
 asbestos-containing friable materials were found and which use
 some method of abatement.


"These estimates are based on reports from a small number of
 of respondents and are therefore subject to large sampling error.


 Actual cost of future abatement per square foot may increase
 greatly depending on size of project, field conditions,
 necessary reconstruction items, stringency of specified work
 practices and level of acceptable quality assurance.

 Situation at LEA as of January 1984.
                               5-29

-------
                           SECTION 6
                     METHODOLOGICAL REPORT
OVERVIEW OF SURVEY

     The evaluation of the Asbestos-In-Schools Identification
and Notification Rule was designed to gather information through
a telephone interview.  Completed questionnaires were weighted
and aggregated to provide national estimates for the universe of
public school districts and private schools that were subject to
the rule.

     The questionnaire requested basic information about the
schools such as number of students and number of employees.   In
addition, questions were asked about the inspection activities
of the schools.  When friable materials were found, the sampling
activities were explored.  Schools were required to describe the
results of the analysis and their current and planned abatement
work.

     The sample design was a stratified systematic sample with
probability proportionate to the square root of school enroll-
ment.  Samples of 1,800 public school districts, 400 private
non-Catholic and 400 Catholic schools were selected.

     Approximately two weeks before the questionnaire was to be
administered by telephone, a letter from the Office of Toxic
Substances and a questionnaire were mailed to each superintendent
or school principal in the sample.  Copies of the  letter and  the
questionnaire are included in Appendix B.  Also enclosed in  the
package was a card to be returned with the name of the person
responsible for the asbestos inspections.
                               6-1

-------
     The total number of completed responses, along with the
final response rates are summarized in Table 23.  The overall
response rate for the survey was 96.5 percent.


     Each completed response was weighted to provide estimated
totals of interest such as the number and percent of schools
with asbestos-containing friable materials.


     This section includes sections on questionnaire development,
data collection, data processing.
Table 23.  Response rates for Asbestos-In-Schools
           telephone survey

                         Sample    Number of      Proportion
     Type of school       size     responses      responses

  Public                  Ir800      1,742          96.8%

  Private Catholic          400        387          96.8%

  Private non-Catholic      400        379          94.8%
THE QUESTIONNAIRE


     A questionnaire based on "Inspections for Friable

Asbestos-Containing Materials" (EPA form 7730-1) was developed

for use in telephone interviews.


     The questionnaire development followed the following steps:


     1.   Outline all issues to be addressed;

     2.   Review outline with EPA staff and obtain agreement;

     3    Translate each item in the outline into a question and
          determine the response mode;
                               6-2

-------
     4.   Determine "best wording"  for each question;
     5.   Arrange/order questions for ease of  communication with
          respondents and efficient use by interviewers  and
          coders; and
     6.   Format questionnaire for  efficient editing,  coding,
          and keypunching.

     The questionnaire, after review by the EPA staff, was sub-
mitted to OMB for clearance, and was received in October,  1983.
A pretest of the questionnaire was  conducted November  14-16.
Composing and printing took place during early December,  and the
first mailout of the questionnaire took place in mid-December,
1983.
PRETEST

     A pretest of the questionnaire was conducted on November 14
through 16, 1983.  The pretest was to ensure that (1) there were
no conflicts in the instructions to the interviewers, and (2)
the questions were understood by the respondents.  Ten interviews
were completed in seven public school districts and three private
schools.  Each of the sampled schools/districts was sent (1) a
letter one week before the telephone call explaining the purpose
of the study, and (2) a copy of the questionnaire to be completed
in advance of the telephone interview.

     Interviewers had no problems reaching the person responsible
for the asbestos inspections.  Seven of the ten respondents  had
filled in the questionnaire prior to the phone call which sub-
stantially reduced the amount of time required to complete  the
interview.  No problems were encountered with wording or meaning
of any of the questions.  Except for minor modifications to
correct skip patterns or typing errors, the questionnaire was
not changed following the pretest.
                               6-3

-------
INTERVIEWER  TRAINING

     A  training  program was  conducted  December  12  through
December  13,  1983  to provide interviewers with  an  in-depth
understanding of the EPA questionnaire and  all  special proce-
dures to  be  used during the  survey.  Special attention was paid
to providing trainees with the  information  they needed to
adequately answer  any questions a respondent might have had
about why or how the survey  was being  conducted.
SURVEY RESPONSE AND  FOLLOW-UP PROCEDURES

     Nonresponse  on  this  survey was minimized by the recruitment
of experienced telephone  interviewers and careful training for
this study.  An extensive effort to contact nonrespondents was
undertaken, employing  interviewers who have demonstrated skill
in achieving high response rates.

     Table 24 shows  the final status of all sample schools/
districts.  Overall  three percent refused to participate.  Less
than one percent  of  the schools had closed.  In some places, one
office provided all  the information for more than one city
school district,  all of which had been selected to be in the
sample.  Although we only completed one questionnaire for all
the city school districts, the other districts were considered
as completed questionnaires as well since information was
gathered about them.   These schools are shown in Table 24 as
"Schools covered by another questionnaire."
                               6-4

-------
Table 24. Final status of telephone interviews for Asbestos-In-
          School Survey

                               Public     Private
                               school      non-    Private
                              districts  Catholic  Catholic  Total
Refused to participate

Schools closed

Military schools on base
  (exempt)

No answer after 8 callbacks

Completed questionnaires

Schools covered by
  another questionnaire
48

 1
40
                                1,800
17

15
         400
13

 0
          13
         400
78

16
1
9
1,701
1
3
363
0
0
374
2
12
2,438
         54
      2,600
TELEPHONE QUALITY CONTROL AND DATA RETRIEVAL


     After completing each interview, the interviewers reviewed

everything they recorded for editing.  In addition to this

editing process, the receipt control staff scanned all work to

make sure it was properly coded.  If an error or inconsistency

was found during the scan, the questionnaire was returned to the

interviewer and the school or district was called to resolve the

problem.  Callbacks to LEAs were also done by the coding staff

during the coding/editing phase of data collection.
                                6-5

-------
DATA PROCESSING

     As the questionnaires were completed, they passed through
several stages of data processing.  The first step was
scan-editing.  The questionnaires were given a preliminary check
to make sure that skip patterns were followed and that the
responses were logical and complete.  Any questionnaires with
missing or inconsistent data were brought to the attention of
the Coding Supervisor,- and these respondents were called for
additional clarifying information.

     When a questionnaire was found to satisfy these initial
qualifications, it was then coded in preparation for keypunching,
Most items on the questionnaire were preceded and codes were
directly noted on the questionnaire.  Responses to several
"Other (Specify)" categories were analyzed and grouped.  Some
receding was done to retain the most frequent responses.

     After the coding and checking was completed, the responses
were keypunched and 100 percent key-verified.  Each batch of
questionnaires was subjected to machine-editing designed to
uncover coding errors and errors in logic.  Each error was
checked against the questionnaire and corrected.  Machine-
editing was continued until a clean data set was produced which
was used to produce the statistical analysis tables.  Weights
were applied to the file and tabulations produced according to
the specifications presented in the Analysis Plan.

     The clean data tape and a copy of the machine-edit coding
manual were provided to the EPA.
                               6-6

-------
      APPENDIX A






STATISTICAL TABULATIONS

-------
                             Titles


Table

  1       Local Education Agencies by type of agency

  2       Schools by date of construction

  3       Current student enrollment

  4       LEAs with some schools built before
          January 1, 1979

  5       LEAs that have an inspection program

  6       Type of agent inspecting at LEAs with inspection
          programs

  7       Starting date of inspections

  8       Completion status of inspections as of January 1,  1984

  9       Date inspections completed in LEA

 10       Scheduled inspection date in LEAs
          planning inspections

 11       Date inspections begun in LEAs initiating inspections

 12       Use of EPA's Technical Assistance Program
          by LEA

 13       How well TAP met needs of LEA

 14       EPA Documents at LEA using the Technical Assistance
          Program

 15       LEAs with Form 7730-1 on file

 16       Date Form 7730-1 completed for LEAs with
          Form 7730-1 on file

 17       Source of information used to answer questionnaire

 18       Number of schools inspected for friable
          materials

 19       Number of LEAs in which  friable materials
          were found
                                A-l

-------
                       Titles (continued)

Table

 20       Number of inspected schools with friable materials

 21       Number of schools in which samples were analyzed

 22       Number of LEAs with one or more schools having
          asbestos

 23       Number of inspected schools finding asbestos

 24       Average number of square feet of asbestos-containing
          friable materials per school

 25       Number of employees in LEAs where asbestos-containing
          friable materials were found

 26       Number of teachers/custodian/other staff in LEAs where
          asbestos-containing friable materials were found

 27       Distribution of LEAs by number of students exposed to
          asbestos-containing friable materials

 27A      Distribution of inspected LEAs by enrollment

 28       Average samples per area analyzed for asbestos

 29       First date samples taken at LEAs analyzing friable
          materials

 30       Last date samples taken in LEAs analyzing friable
          materials

 31       First date friable material samples sent for analysis

 32       Last date friable material samples sent for analysis

 33       First date test results received from friable samples

 34       Last date test results received from friable samples

 35       Schools where asbestos-containing friable materials
          were found by date of construction

 36       Number of schools which provided notice to employees
                                A-2

-------
                       Titles (continued)

Table

 37       Method used by LEA to notify employees

 38       First date notice provided to employees in LEA

 39       Number of schools providing notice to parents and/or
          PTA

 40       Method used by LEA to notify PTA

 41       Date first notice made to any PTA from the LEA

 42       Method used by LEA to notify PTA equivalent

 43       First date LEA notified any PTA equivalent

 44       Number of schools with abatement completed, ongoing or
          planned

 45       Status of removal work in schools using this method

 46       Average square feet of asbestos-containing friable
          materials in schools using removal abatement

 47       Average cost per square foot to remove
          asbestos-containing friable materials

 48       Intended start of removal in LEAs planning removal

 49       Schools using enclosure abatement by status of
          the work

 50       Average square feet of asbestos-containing
          friable materials in schools using enclosure abatement

 51       Average cost per square foot to enclose
          asbestos-containing friable materials

 52       Intended start of enclosure in LEAs planning enclosure

 53       Schools using encapsulation abatement  by  status
          of the work

 54       Average square feet of asbestos-containing
          friable materials in schools with encapsulation
          abatement
                                A-3

-------
                       Titles (continued)

Table

 55       Average cost per square foot to encapsulate
          asbestos-containing friable materials

 56       Intended start of encapsulation in LEAs planning
          encapsulation

 57       Schools using operations/maintenance/reassessment
          abatement by status of the work

 58       Average square feet of asbestos-containing
          friable materials in schools using operations/
          maintenance/reassessment abatement

 59       Intended start of operations/maintenance/reassessment
          in LEAs planning operations/maintenance/reassessment
          abatement

 60       LEAs that claimed exemption from the Asbestos-In-Schools
          Rule

 61       Percent of asbestos-containing materials found in pipe
          wrap at LEAs

 62       LEAs complying with all aspects of the rule by
          June 30, 1983

 62A      LEAs with asbestos that complied with most aspects of
          the rule by January, 1984

 62B      LEAs with asbestos that complied with most aspects of
          the rule (except notification)  by January, 1984

 63       LEAs that complied with most aspects of the rule by
          January, 1984

 63B      LEAs complying with most aspects of the rule (except
          notification) by January, 1984

 64       Square footage of asbestos-containing friable
          materials found in schools
                              A-4

-------
                          FAtiLt  I.  LUi.AL EDUCATJUiJ  AGENf.itS 8V  HPt UP AGLNCY

1
Y
PL UF AGLuLt
PUBLIC LtA *
Ph<
1
0
I
1
NATIONAL ES
tSUMAI

VATE LtA . | 1
t
4593
9602
AL 1 34l9b
1
1
1
1
1
1
IMAIE
PtRCtN
4<>.
b7.
IUO.

I
68
3
-------
TABLE 2. SCHOOLS BY DATE OF CONSTRUCTION *

CONSTRUCTION TIME
BUILT BEFORE 1/1/79
TYPE OF AGENCY 1 !
	 	 l 1
PUBLIC LEA 1
ESTIMATED SCHOOLS 1
ESTIMATE (PERCENT 1
1 1
1 1
715071 90.201
BUILT AFTER 1/1/79 1 31581 3.981
DATE NOT SPECIFIED 1 46111 5.821
TOTAL 1 792761 100. 001
PRIVATE LFA 1 TOTAL j
ESTIMATED SCHOOLS 1 ESTIMATED SCHOOLS 1
ESTIMATE (PERCENT 1 ESTIMATE (PERCENT 1
(I II
II 1 '
193211 99.191 908281 91.971
321 0.161 31901 3.231
1271 0.651 47381 4.801
194791 100.001 987561 100.001
*For LEAs with at least one school  built before January 1, 1979
       Situation at LEA as of January, 1984

-------
4.  CURKENr  SlUDkM  ENROLLMENT


FVPL Uh AGEfcLY
PUBLIC LEA
PRIVATE LEA
TUIAL
1
1
1
1
1
1
NATIONAL ESI
ESTIMATE

39^95701
51U039
W06740
IMATE
IPERLEN1
1
1 «6.«9
1 11. bl
1 1UO.UO
   as of January, 1984

-------
                                a.  LbAC>  i.Uh  SUMt  SCHOOLS  HUlLf  I'fcFllKfc JANUAHY  1,  19/9

ll^.f MU1LT
MhFIJKt 1/1//9
lYPt OF Al
PUhLlC LhA
KP 1 1UNAL ESTlMAl t
LSIlNAl'F IPtKLtN
1
1
145051 99.
AF IhK 1/1/79 1 881 U.
Mul AbCEKfAlNtD 1 01
(DIAL 1 145931 100.
1
1
T 1
1
1
001
01
001
• EIMLY

PP-lVAFt LfcA
NATTtlWAL tST
ESTIMATt 1
1
1
16441 |
1141 I
21 1
196021
IMAIt
PtRCtN
94.
5.
0.
100.
1
1
1
1 1
1
1
061

101
001
IUI AL

NATIUhiAL tST
ESTIMATE
32946
1229
dl
34195
1
1
1
1
1
1
1

1MAIE


PEKCtNl
96
3
0
100
.35
.59
.06
.00
I
CO
                                          Situation at LEA as of January, 1984

-------
                                       5.  LLAS IHAI HAVt  AN INSPECTION PRUURAM  *





INSPECTION PROGRAM

>ES, HAS PROGRAM
NO PROGRAM, EXEMPTION CLAIMED
NO PROGRAM, NO EXEMPTION
CLAIMED
NOT ASCERTAINED
101 AL
1

1
1
l
1

1
1
1
1

1
IYKE lif-

1 UHL1C LEA
WAIJUWAL hSUMATE
ESTIMATE IPERCEN1
1

137921 95.06
4591 3.16
1
1641 1.13
901 0.62
145051 100.00
A

1
1
1
1
I
l
1
1
1
1
1
1
KtNCY

PRIVATE LEA
NATIONAL ESTl^AlE
ESTIMATE IPERCEN
1

140951 76.
21671 11.
1
14101 7.
7661 4.
164411 100.
1
— 1
1
1
1 1
1
i
i
43 1
751
1
651
171
001

V
I01AL
NATIONAL Eb 11 MA IE
ESTIMATE IPERCEN
1
1
276871 64.
26261 7.
1
15741 4.
6591 2.
329461 100.




1


64
97

76
61
00
I
vo
                  *For LEAs with at least one school built before January 1, 1979
                   Situation at LEA as of January,  1984

-------
FA-iLL  b
1 rPt UP
                                              |NSPH;'TifU; A I HAS rt]FH  1NSPELTIUN  PKUGK^MS  *




lUSPkCTUK
SCHOUL/DISFK1C 1
UUISIOt AGENCY
HUFH
EPA/hEUEKAL 6UVT
UNKNUWN
TUTAL

MjbLiL L.t
NA 1 J UNAL t S I
ES I.i MAT I IP
I
52471
1 6HH5I
1 7841
1 3621
1 494 1
1 13/921
1 YPE
A
IMATE
LKCEN

38.
49.
5.
2.
3.
100.
IF 'A
1
1
F 1
1
041
921
691
771
581
001
iENCY
PRiVAJE
NATIONAL t
EST IMATE

5664
6236
623
601
749
14095


5
1
1
1
1
1
1
1
1

LEA
T1MAIE
PEHCtN

40.
44.
4.
5.
5.
100.



F

33
2b
42
68
31
00
1
1
1
1
1
i
i
1
1
1
1
1
1

TOIAL
NATIONAL EST
ESTIMATE IP
1
i
i
10931 1
131231
14071
11631
12431
2/86/1


iHAlb
EKCLN

39.
4/.
5.
4.
4.
100.



r

20
06
05
24
46
00
I
M
o
                   *For LEAs with at least one  school  built before January 1, 1979
                    that have an inspection program.
                    Situation  at  LEA as of January, 1984

-------
                  TA8LE 7.  STARTING DATE OF INSPECTIONS *



iNSPECTllih DATE
BEFORE 6/1/82
1 YPfc UF' AUF.NLY 1
— . 	 1
PUHLIt LtA | PRIVATE LEA |
NATIONAL FSF
IMATE i NATIONAL EST
TOTAL

IMAFE 1 NATIONAL ESTIMATE
fcSfJMATE IPERCENT 1 ESTIMATE IPERCENT 1 ESTIMATE IPtKtENF
.1
1"
66061
6/1/82 - 7/1/03 1 5561 I
AFTER 7/1/83 1 10041
NOT STAKTEU YET ' 1 211
UNKNOWN 1 6001
TOTAL 1 137921
i
i
i
47.901
40.321
7.281
0.151
4.351
100.001
1
1
32031
80531
21R1 1
01
6571
140951
1
I
22.731
57.141
15.461
01
4.661
100.001
1
98091
136151
31851
211
12571
278671

35.16
46.62
11.42
0.07
4.51
100.00
*For LEAs with at least one school built before January 1, 1979
 that have an inspection program.
 Situation at LEA as of January, 1984

-------
                      TABLE 8,
COMPLETION STATUS OF INSPECTIONS AS OF JANUARY 1, 19*4 *

INSPECTION STATUS
COMPLETED


TYPE OF
PUBLIC LEA
NATIONAL ESTIMATE
ESTIMATE
13364
UNDERWAY 1 309
SCHEDULED 1 118
TOTAL 1 13792
1
1
1
1
1
1
1
PERCENT
96.90
2.24
0.86
100.00
AGENCY
1
1
1
1
1
1
1
1
1
PRIVATE
LFA
NATIONAL EST
ESTIMATE
13572
177
346
14095
TMATE
(PERCENT
1
1
1
1
1
1
96.29
1.26
2.45
100.00
1
1
1
1
1
1
1
1
1
1
1
TOTAL
NATIONAL EST
ESTIMATE
26936
486
464
27887
IMATE
(PERCENT
i
i
i
i
i
i
96.59
1.74
1.66
100.00
I
I-'
N)
                *For LEAs  with at least one school built before January 1, 1979
                 that  have an inspection program.

-------
                               TABLE 9.  DATE. INSPECT UitoS CUMPLFTE IN LEA *
l
M
U)

TUSPtCT IUU OAlt
liKFUPF. 7/1/84

1 YPE
UP
PUBLIC LF.A
NA 1 IUNAL t S
ESTIMATE 1
1
1
OO1/1I
AF ThR 7/1/03 1 14271
iiMKrviiji^N 1 20231
IUIAL 1 133641
1 1MATE

PLKCLNT
74.
10.
15.
100.
19
67
14
00
AGl-NCY
1
1
1
1
\
1
1
1
1
PRIVATE
NATIONAL ES
ESTIMATE 1
1
1
104531
22851
B34I
135721
LEA
1 IMAlt
1
I
1
PERCENT 1
77.
16.
6.
100.
1
1
021
631
151
001
TOTAL
NATIONAL tS
ESTIMATE
20367
3711
2b5B
26936
1
1
1
1
1
1
1
TlMAlh
PEHLEU
75.
13.
10.
100.

T
61
7b
61
00
               *For  LEAs with at least one school built before January 1, 1979
                that have an inspection program.
                Situation at LEA as of January, 1984

-------
IAHLF. 10. SCHElJULU' UiSPELllON HATE 1

PLAiji-ib-L- liMSPELIlUN DA TF.
MLUlKE 7/1/84
TU'k UF
PUBLIC LEA
NATIONAL F.8 1 IMA it
ESUMATt IPEKCEN1
1
1
871 73.42
AF IhK 7/l/8'4 1 81 fa. 98
U(\iKMO*vN 1 231 19.60
IUUL I ' 1181 100.00
vj
*
1
1

1
1
1
1
1
1
LFAS PLANNING INSPECT 1
(iUiCV
PRIVATE
NAT TONAL ES
ESTTMATE 1
1
1
2791
21 1
a7i
3461

LF.A
riMAFF.
PEKCEN
80.
b.
li.
100.
1
1
1
T 1
1
1
591
951

001
UNS *
IUIAL
NATIONAL LS
ESTIMATE 1
1
1
3661
» Q 1
701
4641


T 1MA1L
PEKCEN 1
78.76
6.21
15. Oi
100.00
*For LEAs with at least one school built before January 1,  1979
 that have an inspection program.
 Situation at LEA as of January, 1984

-------
                         11.   UAIh  JigbHtf.l JONS HtGUN I IM LKA3 INITIATING INSPECTIONS *




INSPECTION DA IE
HfcFOKf. 7/1/U3
APTKK 7/1/83
UNKNOWN
TOTAL

PUHL1L
NAlldwAL ^
ESTIMATE

11975
1 1068
1 631
1 13673

L
S
1
1
1
1
1
1
1 YPE
hA
1 1MATE
PEKCEN

87.
7.
4.
100.
OF A
1
1
T 1
1
I
581
81 1
61 1
00!
GENCr
PRIVATE
NAT IOIMAL ES
tSTlMAft: 1
1
1
109521
19031
8941
137491

LEA
TIMAIE
PF.HCEN

79.
13.
6.
100.
1
1
1
T 1
1
6bl
841
5UI
001

TOTA
NATIONAL t
ESTIMATE

22928
2971
1524
27422

L
S
1
1
i
i
1
1
1
1

\>
1 IMA it
PEKCEN

83.
10.
5.
100.



T

61
83
56
00
I
H
in
                  *For LEAs  with  at least one school built before January 1, 1979
                  that have begun or completed inspections.
                   Situation at LEA as of January,  1984

-------
1AHLE
                               USt. Uf- t-PA lEUlfoiCAL ASS IS UNlJF. PNMUHAM HY LhA * **

USE OF EPA "1ATEUJ ALb
USED T«P
IYHE
HUhLJC l.EA
NATIONAL E.STIMAIE
ESTIMATE IPEKLEN
1
1
I)1U NU1 USE 1 82691 60.
UNKNUiMM ! 5101 3.
TUTAL 1 136731 100.
UK AUENCY
1
1
\ 1
1
»
791
461
731
001
PRIVATE
NATIONAL E
ESTIMATE
3b71
9005
1073
13749
LEA
ST
IMAIE
IPEKCEN
1
1
1
1
1
1
26.
65.
7.
100.
1
1
1
T 1
1
1
701
501
eoi
001
lui AL
NAT IONAL EST IMAIE
ESTIMATE
8565
17275
15«3
27422
IPEKCENT
1
1
1 31.
1 62.
1 5.
1 100.
23
99
77
00
I
H
en
             *For LEAs with  at  least  one  school  built before January 1,  1979
             that have begun or  completed  inspections.
           **TAP consists of  a  toll-free telephone number,  regional
              technical  advisors to assist schools, and written guidelines
              for schools.
              Situation at LEA as of January,  1984

-------
                         I 3.   HOW  fcf.LL  IAP MM hfifhS Uh LfcA *  **




010 EPA :">AlfcRJ ALS MEF. T hlEfcl>3 ?
YtS
i-Ji)
UKKlMUlMJ
lUf AL

PUBLIC I
NAI IUNAL FS
bSIIMAIh I
1
45831
26SI
461
48941
lYPb (JF A
tA I
tlMAlt I
PtKCtNT 1
1
94.641
. b.421
0.941
1UU.OOI
UthiCY
PRIVATE Lt
HAT TONAL ESTI
Kg IT MA It IPfc
1
34971
1141
601
36711

A
MATt
RLtNl

95.26
3.11
1.63
100.00
1
1
1
1
1
1
1
1
1
1

HI1A
NATURAL t
tSTIMAlE

8080
379
106
8565

L
S
1
1
1
1
1
1
^

I IMAIt
HhHCEN

V4.
4.
1.
100.



T

33
43
24
00
 *For LEAs with at least one school built before January 1, 1979
  that have begun or completed inspections.
**TAP consists of a  toll-free  telephone  number,  regional
  technical advisors to assist schools,  and written  guidelines
  for schools.
  Situation  at  LEA as of January, 1984

-------
14.   EPA  DOCUMENTS  AT LFAS USING TECHNICAL ASSISTANCE PROGRAM *



1
TYPE UF AGENCY 1
1 PUBLIC LFA (PRIVATE LEA 1 ALL LEAS
1 NATIONAL 1 NATIONAL 1 NA
1 ESTIMATE 1 ESTIMATE 1 ES
IIONAL
TlMATfc
t ESTIMATE 1 ESTIMATE 1 ESTIMATE
TYPfc UF
UOCUMKmT
ASSISTANCE
GUIDELINES
1 DOCUMENT USE
1
(HAVE/
(HAVE,
(USE
AND USED
UlU NOT
IHAVt* USE
(UNKNOWN

OKANGE BOOKLET,
HAKT i
JNANGF. fiUiJKLET,
HAH r -?
BLACK HOUKLEI
fjLl/E HOOK LET
IQU NUT
(HAVE/
(HAVE/
IU5L
I UIMKUUW
(DO NUT
IHAVt/
IHAVt/
(USE
IHAVt/
lUNKNUh
IUU IvOl
IHAVt,
IHAVt/
(USE
IHAVt,
100 NOI
IHMVt /
HAVE
AND USED
DID NOT
USt
N
HAVE
AND USED
UID NOT
USE
fu
HAVE
ANb USED
DID NOT
USE
N
HAVE
ANI; USED
1
1

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
23061
1541
1
771
23581
38261
1
2501
1
1221
6971
3t>76l
1
3071
1
1281
7831
8911
1
1141
1
101
388UI
1 1201
1
1
1
10171
1111
1
24891
25461
1
1451
1
1981
7821
24261
1
2001
1
1981
M48I
3941
1
531
1
151
32091
601 1
3323
265
131
4847
6371
395
319
1479
6101
507
326
1630
1285
166
25
7089
1721
                         A-18

-------
       KPA UUtUiithiTS Al  LFAS USING HCHNICAL ASSISTANCE PHUGHAM *
i rm UF AGENCY i
I-... .....................)
1 PUBLIC LFA (PRIVATE LEA 1 ALL LEAS
1 NATIONAL 1 NATIONAL 1 NATIONAL
1 ESTIMATE 1 ESTIMAIE 1 ESTIMATE
1 ESTIMAU 1 ESTIMATE 1 ESTIMATE
1YPE UF
DilCUMFNT
BLUE rtOUKLEI




(JTHFK DOCUMENT





IDULUNiHNT USE
1
(HAVE, UID NOT
(USE
IMAVt» USE

IDU NUT HAVE
IHAVLr AND USED
IHAVtf DID NUT
(USE
(HAVE* USE
(UNKNUnN
IDU NUT -HAVE
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1771
1
361
35611
B89I
1
501
1
2121
374
-------
1
sums UH HIKM ; 730-1
YfcSt H.)KM 7/30-1 UN FILE

ItPfc HP AUEM. Y
MIBLlt LLA 1
1
PRIVATE LEA |
fUlAL
NAIIUNAL HSUMATE i NAIIONAL ESTIMATE i NATIONAL ESI

1MATE
tSUMATE IPEKLENl 1 ESTIMATE (PERCENT 1 EST1MAIE IKERCENT
1
1
NU, 7/30-1 NUl UN FiLE 1 72691
UNKNOWN 1 9361
IUTAL 1 136/31
1
1
39.991
53.161
6.651
100.001
1
1
33521
8951 1
14461
137491
1
1
24.381
65.101
10.521
100.001
1
1
6621 1
162191
23621

32.17
59.15
6.69
100.00
I
to
o
                    *For LEAs with at least one school built before January 1, 1979
                     that have begun or completed inspections.
                     Situation at LEA  as  of  January,  1984

-------
  I ABLE  Ib.   DAlt  H-KM 7730-1  COMPLETED FUh* LFAS WITH FORM  UN  FILE  *

hAlF. FUKM COMPLETED
HtFllkh 7/1/83

IVPE'
UF
PUBLIC LEA
NATIONAL KS
ESTIMATE 1
1
1
34251
AF1FR 7/l/a3 1 12371
UNKNOWN 1 8061
TOTAL 1 54681
11 MATE
PtHCEN
62.
22.
14.
100.

r
64
62
74
00

1
1
1
1
1
1
1
1
1
AUENCY
PRIVATE



LEA
NATIONAL ESTIMATE
ESTIMATE
2000
646
507
3352
1
1
1
1
1
1
1
PERCENT
59.65
25.22
15.12
100.00
1
1
1
1
1
1
1
1
1
1
1
TUTAL
NATIONAL ES
ESTIMATE 1
1
1
54251
P062I
13131
8621 1
%
1 IMA IE
PERLEN
61.
23.
14.
100.


I
51
61
69
00
*For LEAs with at least one school built before January 1, 1979
 that have begun or completed inspections.
 Situation at LEA as of January, 1984

-------
             TABLE 17.  SOURCE OF INFORMATION AT LEA USED TO ANSWER QUESTIONNAIRE *

oU'-MARY 0(jCUiv'F.N 1
N.J.*

iv PL I'F A(;er-
HIJMLiL LErt 1
llAl 1UHAL KSI IMA IE 1 IMA
ESTIMATE IPI
1
1
HUKM 7/SO-l 1 434SI
L Ah/IfMSPF.LT iUfv Ktf'ORTS 1 23271
STATE AGENCY PECURUS 1 13061
iiUT ASCERTAINED 1 36071
IU1AL 1 136731
CY
1
PRIVATE LEA 1
IUTAL
THMMAL ESTIMATE 1 NATIONAL ESI

IMAIE
-.HCEwT 1 tSTTMATE IPEKCENl 1 ESTIMATE IHEKCEN!
1
1
15.27!
31.781
17.021
9.551
26.381
100.00)
1
1
39901
2481 1
33621

35071
137491
1
1
29.021
18.04)

2.981
25.511
100.001
1
1
60781
68261
56891
17151
71141
274221
22.16
24.89
20.75
b.26
25.94
100.00
I
to
to
                    *For LEAs with at least one school built before January 1, 1979
                     that have begun or completed inspections.
                     Situation at LEA as of January,  1984

-------
       TARLE 18.  NUMHER OF SCHOOLS INSPECTED FOR  FRIAHLF  MATERIALS




INSPECTION STATUS


INSPECTED SCHOOLS
TYPE OF AGENCY 1
PUBLIC SCHOOLS 1 PRIVATE SCHOOLS 1

TOTAL
ESTIMATED SCHOOLS 1 ESTIMATED SCHOOLS I ESTIMATED SCHOOLS
ESTIMATE (PERCENT 1 ESTIMATE (PERCENT I ESTIMATE 1 PERCENT
II II
II II
746071 98.021 147051 75.611
NOT INSPECTED/UNKNOWN 1 15111 1.981 47431 24.39|
TOTAL 1 761181 100.001 1944RI 100.001
jp *For LEAs with at least one school built before January 1, 1979
i that have begun or completed inspections.
to
U)
1
1
893121 93.46
62541 6.54
955661 100.00



Situation at LEA as of January,  1984

-------
      TARLE  19.   NUMBER  OF  LEAS  IN  WHICH  FRIABLE MATERIAL FOUND «

FRIABLE MATERIALS FOUND
YES* FRIABLE MATERIALS

PUBLIC LEA


TYPE

OF

ESTIMATED LEAS
ESTIMATE
7418
NO FRIABLE MATERIALS 1 5915
NOT ASCERTAINED 1 337
TOTAL 1 13670
1
1
1
1
1
1
1
PERCENT
54
43
2
100
.27
.27
.46
.00

1
1
1
1
1
1
1
1
1
AGENCY 1
PRIVATE LEA 1
ESTIMftTEO LEAS 1
ESTIMATE IPERCENT 1
1 1
1 1
48111 34.991
88481 64.361
90) 0.651
137491 100.001
TOTAL
ESTIMATED LEAS
ESTIMATE 1
1
1
122291
147631
4261
274191


PERCFNT
44.60
53.84
1.56
100.00
>
 I
to
*For LEAs with at least one school built before January 1, 1979

 that have begun or completed inspections.
 Situation at LEA as of January,  1984

-------
                                TA»3LF 20.  NUMBER OF INSPECTED SCHOOLS WITH FRIA9LE MATERIAL *

FRIABLE MATERIALS FOUND
FRIABLE MATERIALS PRESENT

PUBLIC SCHOOLS
TYPF
OF
AGENCY



1 PRIVATE SCHOOLS
ESTIMATED SCHOOLS
ESTIMATE (PERCENT
I
1
394331
NO FRIABLE MATERIALS/UNKNOWN 1 451741
TOTAL 1 746071
39
60
100
.45
.55
.00
1 ESTIMATED SCHOOLS
1 ESTIMATE (PERCENT
1
1
1
1
1
1
1
53flfll
93171
147051
36
63
100
.64
.36
.00
1
1
1
TOTAL


1 ESTIMATED SCHOOLS
1 ESTIMATE (PERCENT
1
1
1
1
1
1
1
34B21 1
54491 1
893121
38
61
100
.99
.01
.00
                               *For  LEAs  with at least one school built before January 1, 1979

                                that have begun or completed inspections.
 I
to
                                Situation at LEA as of January, 1984

-------
                                  TARI.E 21.  NUMMtK OF SCHOOLS FOR WHICH SAMPLES WF!RF ANALYZED

SAMPLES ANALYZED
SCHOOLS WITH SAMPLES ANALYZED
TYPE OF
PURLIC SCHOOLS
ESTIMATED SCHOOLS
ESTIMATE (PERCENT
1
1
2*3791 82.83
NO SAMPLES ANALYZED/UNKNOWN 1 505*1 17.17
TOTAL 1 294331 100.00
AGENCY 1
1 PRIVATE SCHOOLS 1
1 ESTIMATED SCHOOLS 1
1 ESTIMATE (PERCENT 1
1 1 1
1 1 1
1 42591 79.051
1 11291 20.951
1 53881 100.001
TOTAL
ESTIMATED SCHOOLS


ESTIMATE (PERCENT
1
1
286381
61831
348211 1
P2.24
17.76
on. oo
                              *For inspected schools built before January  1,  1979  in which
                               friable materials were found.
I
KJ
Ci
Situation at LEA as of January,  1984

-------
                                TA9LE 22.  NUMBER OF LEAS WITH ONE OR MORE  SCHOOLS  HAVING  ASBESTOS

ASBESTOS FOUND
YES ASBESTOS
TYPE OF AGENCY
PUBLIC LEA
ESTIMATED LEAS
ESTIMATE 1
1
1
68421
NO ASBESTOS FOUND 1 3141
NOT ASCERTAINED 1 2621
TOTAL 1 74181
1
1
PERCENT 1
1
1
92.231
4.231
3.541
100.001
PRIVATE LEA
ESTIMATED LEAS
ESTIMATE 1
1
1
41891
4271
1961
48111
1
1
1
PEWCFNT 1
1
1
87.061
8.871
4.071
100.001

-------
                                   TABLE 21.  NUMBER OF INSPECTED SCHOOLS FINDING ASPESTOS *

HAS AS8ECTOS FOUND
ASBESTOS WAS FOUND


TYPE
OF
PUBLIC SCHOOLS
ESTIMATED SCHOOLS
ESTIMATE
26136
NO ASBESTOS/UNKNOWN 1 48471
TOTAL 1 74607
1
1
1
1
1
I
PERCENT
35
64
100
.03
.97
.00
AGENCY
1
1
1
1
1
1
1
1


PRIVATE SCHOOLS
ESTIMATED SCHOOLS
ESTIMATE
46^3
10012
14705
(PERCENT
1
1
1 31.92
1 66.08
1 100.00
1
1
1
1
1
1
1
1
1
1
TOTAL


ESTIMATED SCHOOLS
ESTIMATE
30830
58482
89312
1
1
1
1
1
1
PERCENT
34.52
*5.4«
100.00
 I
N}
en
                                 *For inspected schools built before January 1, 1979 in which
                                  friable materials were found.
                                  Situation at LEA as of January, 1984

-------
TABLE 24.  AVERAGE NUMBER  SQUARE  FEET  OF  ACFM PEW SCHOOL




AVERAGE SO FT ASBESTOS

< ItOOO
TYPE OF AGENCY |
PUBLIC SCHOOLS
1
SCHOOLS HAVING ACFM 1
ESTIMATE (PERCENT 1
1
1
40621
IfOOO - 4.999 1 43331
5*000 - 9,999 1 34101
10»000 OR MORE 1 48331
PIPE WRAP ONLY . 1 76831
UNKNOWN 1 18151
TOTAL 1 261361
1
1
15.541
16.581
13.051
18.491
29.401
6.941
100.001
PRIVATE SCHOOLS
1
SCHOOLS HAVING ACFM 1
ESTIMATE (PERCENT 1
1
1
4311
7351
3921
2671
22*71
5«2I
46931
1
1
9.191
15.661
8.351
5.681
48.721
12.411
100.001
TOTAL
SCHOOLS HAVING ACF^M


ESTIMATE (PERCENT
1
1
44931
50681
38021
51001
99701
23971
308301 1


14. 17
16.44
1P.33
16.54
32.34
7.7P
00.00
      *For  inspected schools built before January 1,  1979 in which
       asbestos-containing friable materials were found
       Situation at LEA as of January, 1984

-------
                            TABLE  25.  NUMBER OF EMPLOYEES IN LEAS WHERE ACFM FOUND *





NUMBER OF EMPLOYEES


< BO EMPLOYEES
TYPE OF AGFNCY 1
	
PUBLIC LEA 1
NATIONAL ESTIMATE 1
ESTIMATE (PERCENT 1
1 1
I 1
25721 37.601
50-99 1 15391 22.501
100 - 499 1 22471 32.841
500+ EMPLOYEES 1 4191 6.121
NOT ASCERTAINED 1 651 0.951
TOTAL 1 68421 100.001
	 1
PKIVATE LEA 1
NATIONAL ESTIMATE 1
ESTIMATE IPERCENT 1
1 1
1 1
33981 81.121
5951 14.201
1741 4.151
41 0.091
181 0.441
41891 100.001

TOTAL
NATIONAL ESTIMATE
ESTIMATE IPERCFNT
1
1
59701 54.13
21341 19.35
24211 21.94
4231 3.83
831 0.75
110311 100.00
I
U)
o
*For LEAs with at least one school built before January 1, 1979,
that inspected and found asbestos-containing friable materials
in one or more school.
                                     Situation at LEA as of January,  1984

-------
TABLE 26.   NUMBER  OF  TEACHERS/CUSTODIANS/OTHERS IN LEAS WHEHF  ACFM  WAS    FOUND

TEACHERS
< 50
50 - 99
100 - 499
bOO - 999
1.000 *
fjOT ASCERTAINED
TOTAL
CUSTODIANS
< 10
10 - 49
50 - 99
100 +
NOT ASCERTAINED
TOTAL
OTHER STAFF
< 10
in - 49
50 - 99
100 - 199
200 +
NOT ASCERTAINED
TOTAL
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
TYPE OF AGENCY 1
PUBLIC LEA I
NATIONAL 1
ESTIMATE 1
'1
1
32481
14571
1641 |
1721
771
2471
68421
1
1
27421
36081
1951
1131
1831
68421
1
1
27921
28261
5291
2601
1751
2611
68421
PRIVATE LEA 1
NATIONAL 1
ESTIMATF I
1
1
36261
3901
791
31
1 1
891
41891
1
1
35231
6301
31
151
181
41891
1
1
34931
5261
501
91
11
1101
41891
TOTAL
NATIONAL
ESTIMATE
6874
1847
1721
175
78
336
11031
6266
4238
198
128
201
11031
6285
3352
579
268
177
371
11031
          *For LEAs with at least one school built before January 1, 1979,
           that inspected and found asbestos-containing friable materials
           in one or more school.

                     Situation at LEA as of January, 1984
                                      A-31

-------
                       TABLE 27.  DISTRIBUTION OF LEAS RY NUMBER OF STUDENTS EXPOSED TO




AVERAGE NUMBER OF STUDENTS
< 600 STUDENTS
600 - 1*199
1,200 - 2,499
2,500 - 4,999
5.000 AND MORE
NOT ASCEKTAINF.D
TOTAL
TYPE OF AGENCY 1
PUBLIC LEA 1 PRIVATE LFA 1 TOTAL
NATIONAL ESTIMATE 1 NATIONAL ESTIMATE 1 NATIONAL ESTIMATE
ESTIMATE (PERCENT 1 ESTIMATE (PERCENT 1 ESTIMATE (PFRCENT
II II 1
II II 1
27841 40.691 36561 87.281 64
to
                               *For LEAs with at least one school built before January 1, 1979,
                               that inspected and found asbestos-containing friable materials
                               in one or more school.


                                            Situation at LEA as of January, 1984

-------
                                  TABLE 27A.  DJSTWTRUTION Of- INSPECTED LFAS BY RNPOLLMFNT *



NUMRER OF STUDENTS
< 600 STUDENTS
600 - 1,199
1,200 - 2,499
2,500 - 4,999 1
BtOOO OR MORE 1
NOT ASCERTAINED 1
TOTAL 1
TYPE OF AGENCY i
	 „. 	 1
PUBLIC LFA 1 PRIVATE LFA I TOTAL
NATIONAL ESTIMATE i NATIONAL ESTIMATE I NATIONAL ESTIMATE
ESTIMATE IOERCENT i ESTIMATE IPEHCENT i ESTIMATE IPERCENT
ii it i
ii ii i
46851 34.261 123851 90.081 170691 62.25
24951 18.241 11761 8.551 36711 13.39
29221 21.371 1631 1.191 30851 11.25
19621 14.351 121 0.091 19741 7.20
15981 11.681 141 0.101 16111 5.88
121 0.091 .1 .1 121 0.05
136731 100.001 137*91 100.001 274221 100.00
>
 I

CO
                            *For  LEAs with at least one school built before January' 1, 1979

                             that have begun or completed inspections.
                             Situation at LEA as of January,  1984

-------
TA"l.F
                                        AVfr'HAOE  SAMPLES PFR AUFA AlMALYZtn FOp FPTA-ll.h

AVERAGE SAMPLES PER AREA
1 - 2 SAMPLES

PUBLIC LFA


TYPF.

OF

NATIONAL ESTIMATE
ESTIMATE
2231
3 SAMPLES I 2147
4 OR MORE SAMPLES 1 1185
UNKNOWN 1 927
TOTAL 1 6490
1
1
1
1
1
1
1
1
PERCENT
34
33
18
14
100
.37
.OR
.26
.29
.00
AfiE
1
1
1
1
1
1
1
1
1
I
f"CY
PRIVATE LFA
NATIONAL F^TIM
ESTIMATE 1
1
1
13671
11891

73S|
37721


ATE
1
1
1
PERCENT 1
36
31
12
19
100
1
1
.251
.521
.761
.471
.001
TOTAL
NATIONAL FSTT
ESTIMATE
359ft
3336
1666
1662
10261

MATE


IPERCFNT
1
1
1 35
1 3?
1 16
1 16
1 100
.06
• ' 1
.?3
.19
.00
I
OJ
                            *For LEAs with at least one school built before January 1,  1979
                             that inspected,  found friable materials, and  sampled in one or
                             more school.
                             Situation at LEA as of January,  1984

-------
TABLE 29
                                 FIHST r>ATK SAMPLES TAKEN AT LEAS ANALYZING  FHIASLF

INITIAL SAMPLING DATF
SAMPLES TAKEN BEFORE 7/1/83
TYPE OF
PURLIC L«-'A 1
NATIONAL ESTIMATE I
ESTIMATE i PERCENT i
1 1
1 1
57631 88.811
SAMPLES TAKEN AFTER 7/1/83 1 4221 6.501
UNKNOWN 1 3041 4.691
TOTAL 1 64901 100.001
AGEMCY
PRIVATE LF.fl
NATIONAL ESTIMATE
ESTIMATE IPEKCENT
1
1
32451 H6.04
4H9I 12.96
381 1.00
37721 100.00
1
1
1
1
1
1
1
1
1
1
1
TOTAL
NATIONAL FSTIMME


ESTIMATE IPERCENT
1
1
90091 87
911 I ft
3421 3
102611 100
.79
.87
.34
.00
I
CO
U)
                         *For LEAs with  at  least one school built before January 1,  1979
                          that inspected, found friable materials, and sampled in one or
                          more school.
                           Situation at LEA as of January, 1984

-------
                         TAHLE  30.   LAST HATE SAMPLES TAKEN IN LEAS ANALYZING FKIAHLt  MATPHlAL

DATE LAST SAMPLES TAKEN
SAMPLING STILL IN PROGRESS
TYPE
PUBLIC LFA
NATIONAL ESTIMATE
OF AGENCY
1
1
ESTIMATE IPERCENT 1
1
1
1 151 1
BEFORE 7/1/83 1 52321 80
AFTER 7/1/83 1 8361 12
UNKNOWN 1 3061 4
TOTAL 1 64901 100
1
1
.781
.621
.881
.721
.001
PRIVATE If
1
A 1
NATIONAL FSTTMATF 1
ESTIMATE 1
1
1
301
31191
5591
f.41
37721
PERCENT 1
1
1
0.711
82.691
14.831
1.691
100.001
TOTAL

NATIONAL ESTIMATE
ESTIMATE (PERCENT
1
1
1451
83511
13951
3701
10261 1
1.41
81.38
13.60
3.61
100.00
I
U)
                                 *For LEAs with at least one school built before January 1, 1979
                                  that inspected, found friable materials, and sampled in one or
                                  more school.
                                   Situation at LEA as of January,  1984

-------
                           FAHLt 31.  KlHSf UAIt miAHLF MATERIAL SAMPLF3 SENl  FUR ANALYSIS *

FIRST I)AIF. SAMPLES SENT
Nil 3AMPLLS SLiMT

HUbUC LF
NAiiUNAL EST

36
BEFURH 7/1/83 1 5526
AFTER 7/1/H3 1 475
UNKNUWN 1 453
TOTAL 1 6490

A
TYHL

IMAIE
uj- AL.LNCY
i
1 NA

PRIVATE LEA




TTDNAL EST IMATE
IPERCFNT 1 ESTIMATE (PERCENT
1
1
1
1
1
1
1
0
85
7
6
100
1
1
.551
.161
.311
Q M 1
.001
1
1
261
31931
4891
641
37721
0.
84.
12.
1.
100.
69
66
96
69
00
1
1
1
1UTAL


1 NATIONAL ESTIMATE
1 ESTIMATE IPERCENF
1
1
1
1
1
1
1
1
1
621
87201
9631
5171
102611
0
84
9
5
100
.60
.9/
.39
.04
.00
I
CO
-J
                            *For LEAs with at least one school built before January  1,  1979
                             that inspected, found friable materials, and  sampled  in one  or

                             more school.
                             Situation  at LEA as of January,  1984

-------
lAHl.t 4^.




i ASI DAlt SAMPLES SEiU
SAMHl INb STILL IN PKuGKESS
HEHiHF 7/1/83
AFIEK 7/1/H3
UNKNOWN
Till AL
LA31 UAIt FKlAbLh
T
Put.LH. LhA
NAIJUIV.AL tSTiMA

1
HOI
1 50681
1 9071
1 4351
1 64901
MA II KIA
m UF
i
it- i

i
I

/tt.101
13.971
6.701
100.001
L SAMPLKS SENT H)
AGKlMCY
PRIVATE LE
NA1 ItlNAL ESTI
ESTIMATE 1
1
1
301
31521
5251
641
37721
K ANALYSIS
1
A I

PEKl'ENI 1
1
1
0./9I
83.581
13.931
1.691
100.001
*

IU1AL
NATIONAL EST
ESTIMAIE

110
8221
1432
498
10261



IMAFE
IPEKLENI
1
|
1 1.07
1 60.11
1 13.96
1 4.86
1 100.00
I
U)
00
                         *For LEAs with at least one school built before January 1, 1979
                          that inspected, found friable materials, and sampled in one or
                          more school.
                          Situation at LEA as of January,  1984

-------
                         UHLf  33.  HKS1  UAlt TEST  kFSULTS  KECHVEI)  FKUM FRIABLE SAMPLES *

FTWSI OATE ANALYSIS KtSULIS
RFCE1VFU
NO KESULTS RECEIVED
T tPt
HUhLTC LEA
NAIIUNAL EST I KA IE
FSI1MAIF. IPFRCF
1
1
1
701 1
HKFUKF 7/1/83 1 50671 /8
AFTER 7/1/H3 1 8021 12
UNKNOWN | 5511 8
TOTAL i 6«9oi 100
OF Att
1
1
NT I
1
1
.081
.0/1
.361
.491
.001
NCY
PRIVATE LEA
NATIONAL ESTIMA1
1
1
E 1
ESI IMATE (PERCENT 1
1
1
1
521
27621
7851
1731
37721 1
1
1
1
1.381
73.221
20.81 1
4.591
00.001
1U1AL
NATIONAL ESTIMATE
ESTIMATE IPEKCEN
1
1
1
1221 1.
78281 lt>.
15871 15.
7241 7.
102611 100.


1
19
29
47
06
00
I
u>
vo
*Por LEAs with at least one school built before January  1,  1979
 that inspected, found friable materials, and sampled in one or
 more school.
                       Situation at LEA as of January, 1984

-------
IA3I
                                                 1ESI  KFSUL1S l
-------
                               TflRLF 3S.  SCHOOLS rtHERE ACFM WERE FOUND* BY CONSTRUCTION OATF. *





PERIOD OF CONSTRUCTION


1969-1978
TYPE OF AGENCY
PUBLIC SCHOOLS
NATIONAL
ESTIMATE
ESTIMATE


1472
1959-1968 1 6073
1949-1958 1 7072
1939-1948 1 1627
1929-1938 1 2132
1919-1928 1 2453
1909-1918 1 1198
1899-190R 1 556
BEFORE 1899 1 348
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PERCENT OF
ALL
ESTIMATE


13.
34.
37.
32.
32.
36.
35.
39.
37.




5
3
8
2
6
1
2
4
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
PRIVATE SCHOOLS
NATIONAL 1
ESTIMATE 1
ESTIMATE 1
1
1
1261
13681
13371
4291
3021
3491
3311
1321
3111
PERCENT
ALL
1
OFI
1
ESTIMATE 1


3
28
30
33
31
20
34
19
31
1
1
.71
.31
.11
.11
.hi
.21
.31
.61
.21
ALL SCHOOLS
NATIONAL I
ESTIMATE 1
ESTIMATE 1
1
1
15981
74411
84091
20551
24341
28021
15291
6881
6591
PERCENT
ALL
OF

ESTIMATE


11
33
36
32
32
32
35
33
34


.1
.0
.3
.4
.5
.8
.0
.0
.1
 I
if*-
                                     *For inspected schools built before January 1,  1979 in which
                                      asbestos-containing friable materials were found.
                                      Some schools did not report date of construction and are not
                                      included in this table.
                                      Situation at LEA as of January,  1984

-------
                           TABLE 36.  NUMHEH OF SCHOOLS WHICH  P^OVlDtD  NOTICK  TO  EMPLOYEES *

NOTIFICATION OF EMPLOYEES
SCHOOLS NOT NOTIFIED

TYPE OF
PUMLIC SCHOOLS
NATIONAL ESTIMATE
ESTIMATE
5036
SCHOOLS NOTIFIED 1 20820
UNKNOWN 1 281
TOTAL 1 26136
(PERCENT
i
i
1 19.27
1 79.66
1 1.07
1 100.00

1
1
1
1
1
1
1
1
1
FNCY

PRIVATE SCHOOLS
NATIONAL FST
ESTIMATE
841
3574
278
4693
IMATE
IPEPCENT
1
1
1 17.92
1 76.16
1 5.9?
1 100.00
1
1
1
1
1
1
1
1
1
1
1
TOTAL
NATIONAL FST
ESTIMATE
5877
24394
559
30H30

IMATK


I PERCENT
i
i
1 19.
1 79.
1 1.
1 100.
Of,
12
HI
00
I
*»
ro
                           * For  inspected schools built before January 1, 1979 in which

                            asbestos-containing friable materials were found.
                                   Situation at LEA as of January,  1984

-------
                                    37.  METHOD USED BY LEA TO NOTIFY

METHOD OF NOTIFICATION
FORM 7730-3

PUHLIC LK

A
TYPE

NATIONAL ESTIMATE
ESTIMATE
2519
STAFF MEETING 1 933
NOTICE POSTED 1 793
OFFICIAL LFTTER 1 446
OTHER 1 836
TOTAL 1 5529
1
1
1
1
1
1
1
1
1
OF AGI-NCV
I
I
PERCENT 1
45.
16.
14.
8.
15.
100.
I
1
571
881
351
081
121
001
PHIVATF Lh!
NATIONAL FST
ESTIMATE
1275
1169
288
227
2*4
3242
A
IMATE
1
1
1
1
1
1
1
1
1
1
1
1
PERCENT i
39.
36.
P.
7.
8.
100.
1
1
321
041
871
001
761
001
TOTAL


NATIONAL ESTIMATE
fSTlKATE
3744
2102
10H1
674
1120
8771
1
1
1
1
1
1
1
1
1
PERCENT
43.26
23.96
12.32
7.68
12.77
100.00
00
                           *For LEAs with at least one school built before January 1, 1979
                           that inspected and found asbestos-containing  friable materials
                           in one or more school.

                                 Situation at LEA as of January,  1984

    Note:  To meet the employee notification requirement of the  Asbestos-In-Schools Rule

           1)  Notice to  school employees must be posted indefinitely  in primary administrative and
               custodial  offices  (using EPA Form 7730-3 or equivalent);

           2)  A copy of  the "Guide for Reducing Asbestos Exposure" (EPA Form 7730-2) must be
               distributed  to all  custodial or maintenance employees;  and

           3)  Written notice of  the location of all ACFM in the school  must be provided to building
               employees.

-------
                                                  TnF
1



.\OTIFlCATIurv, DME
NOTICE GIVtN BEFORE 7/1/43
NOTICE GIVFN AFTER 7/1/H3
UNKNOWN
TOTAL
TYFK OF aru -JCY |
•-IHLIC LKA i DHIVATF. LKA i TOTAL
NATIONAL ESTIMATE 1 NATIONAL FSTTMATE 1 NATIONAL FST1MATH
K'sTIMATF IPEPCENT 1 ESTIMATE IPF^CFNT 1 FSTI^ftTE |PF«CFKT
II II 1
II II 1
381BI b9.06l 19651 60.611 57B3I 65.44
13931 25.201 10BOI 33.311 24731 2R.19
31RI 5.741 197h 6.0fl| 5151 t>.87
1 5S29I 100.001 32421 100.001 -97711 100.00
*For LEAS with at least one school built before January 1,  1979,
 that inspected and found asbestos-containing friable materials
 in one or more school.
          Situation at LEA  as  of  January,  1984

-------
                                             OF SCHOOLS  PwOVIDING NQTICP TO




METHOD OF NOTIFYING PARENTS
DID NOT NOTIFY
NOTIFIED PTA
NOTIFIED PARENTS
UNKNOWN
TOTAL
TYPE OF
PU«LIC SCHOOLS 1
NATIONAL ESTIMATb 1
ESTIMATE (PERCENT 1
1 1
1 1
50011 19.131
145251 55.581
49571 18.971
16531 6.331
261361 100.001
AGtNCY 1
PPIVATE SCHOOLS 1
NATIONAL ESTIMATE i
ESTIMATE IPERCENT 1
1 1
i i
7661 16.321
21411 46.681
13Q5I 24.711
3421 7.291
46V3I 100.001

TOTAL
NATIONAL F.STI
ESTIMATE 1
1
1
57671
167161
63511
1^61
308301


MftTF
PERCENT

18.70
54.??
?0.60
6.47
100.00
*»
en
                                 *For inspected schools built before January 1, 1979 in which
                                  asbestos-containing friable materials were found.
                                           Situation at LEA as of January,  1984

-------
         TAIJLF. 40.  MF.THOD USED HY LtA TO NOTIFY

fETHOO OF NOTIFICATION
PTA MF.ETING


TYPE OF
PUBLIC LEA
NATIONAL FST
fcSTIMATF
643
PTA NEWSLETTER | b02
PTA IMFOHMRU I 1288
NEWSPAPER | 147
OTHER I 412
TOTAL I 2993
1
1
1
1
1
1
1
1
1
IMATE
PERCENT
21. 4«
16.79
43.05
4.92
13.77
100.00
AGENCY
1
1
1
1
1
1
1
1
1
1
PRIVATE L
NATIONAL EST
ESTIMATE 1
1
1
7741
3391
5791
181
1491
18591
KA
IMATF
1
1
1
PERCENT 1
41
18
31
0
8
100
1
1
.651
.231
.131
.981
.011
.001
TOTAL

NATIONAL EST
FSTI^ATF
1417
841
1867
165
561
4B51

IMATF


IPEUCFNT
1
1
1
1
1
1
1
1
29
17
3fl
1
11
100
.21
.34
.48
.41
.56
.00
*For LEAS with at least one school built before January 1, 1979,
 that inspected and found asbestos-containing friable materials
 in one or more school.
           Situation  at  LEA  as of January, 1984

-------
TABLE
             HATE  FIHST NOTICE MADE TO ANY PTA FROr* THE LtA

DATE PTA NOTIFItD
NOTICE GIVEN HfcFORE 7/1/R3


TYPE OF
PUBLIC LEA
NATIONAL EST
ESTIMATE
1662
NOTICE GIVEN AFTER 7/1/83 1 999
UNKNOWN 1 332
TOTAL 1 2993
I
1
1
1
1
1
1
1

PERCENT
55.53
33.39
11.08
100.00
AfitNCY
1
1
1
1
1
1
1
1
1
PRIVATE LEA
NATIONAL ESTIMATE
ESTIMATE 1
1
1
9141
7401
2041
18591
PERCENT
49.16
39.84
11.00
100.00
1
1
1
1
1
1
1
1
1
1
1
TOTAL



NATIONAL ESTIMATE
FSTIMflTE
2576
1740
536
4851
1
1
1
1
1
1
1
PERCENT
53.
35.
11 .
100.
09
86
05
00
*For LEAs with at lenst one school built before January 1,.
that inspected and found asbestos-containing friable materials
in one or more school.
          Situation at LEA as of January,  1984

-------
                               Tfit-Lt -4^.  '-1FTHUD USED BY LEA TO NOTIFY PTA FOUTVALENT  *

METHOD OF NOTIFYING PARt.MTb
NOTICE MAILED
TYPE OF A
PUHLIC LF.A 1
NATIONAL ESTIMATE 1
ESTIMATE (PERCENT 1
1 1
1 1
7381 40.051
NEWSLETTFR 1 4651 25.241
NEWSPAPER 1 4821 26.151
OTHER 1 1581 8.551
TOTAL 1 1H42I 100.001
liF.NCY
PRIVATE If-
1
A 1
NATIONAL ESTIMATE 1
ESTIMATE 1
1
1
6941
1381

5111
13951
PERCENT 1
1
1
49.771
9.H9I
3.701
36.641
100.001
TOTAL
NATIONAL FSTTMATF
ESTIMATE IPFRCFNT
I
I
14321 44.24
6031 lR.f-3
5331 16.48
6681 ?0.<>f,
32361 100.00
>

cr
                             *For LEAs with at least one school built before January 1, 1979
                             that inspected and found asbestos-containing friable materials
                             in one  or more school.

                                         Situation at LEA as of January, 1984

-------
   TAHU  43.  FIRST UATF LEA NOTIFIED ANY PTA EQUIVALENT  *

UATE PARENTS FIRST NOTIFIED
HEFORE 7/1/83


TYPE OF
PUBLIC LEA
NATIONAL ESTIMATE
ESTIMATE
1039
AFTEP 7/1/83 1 550
UNKNOWN 1 253
TOTAL 1 1842
1
1
1
1
1
1
1
PERCENT
56.44
29.84
13.72
100.00
AGFNCY
1
1
1
1
1
1
1
1
1
PKIVATF
LEA
NATIONAL EST
ESTIMATE
5

«1
695
1
13
19
05
IMATE
1 PERCENT
1
1
1 41.63
1 49.86
1 8.51
1 100.00
1
1
1
1
1
1
1
1
1
1
1
TOTAL
NATIONAL EST
ESTIMATE
1620
1245
371
3236

IMATF
IPFRCF
1
1
1 50
1 38
1 11
1 100


N'T
.06
.46
.48
.00
*For LEAs with at least one school built before January 1, 1979
that inspected and found asbestos-containing friable materials
in one or more school.

            Situation at LEA as of January, 1984

-------
«J'J.  i-iit".r;f->'  nh
                                                    H  v»llh MitA 1 1 f»tN I LL'^PLF FH>»  ONGUINL,, UK  PLANfvitU *
                                                                                                       14:4U FhlUAY,  APRIL 2U





Ar<;\ Tt'"F.-J 1 SlAl'jS
Ml AbAlFlM M
t

HUbLlL bChULl.S
'"«1 1UIMAI. F.STIMA
K-'JllNAU. IPF
1
19321
AU/UKMHJI UlMPLKfti) 1 114361
AilA 1 t ;«IF. IMF UN-UUTlMti | 61911
AHftJtMFMI PLAN'MfcU | 60141
IHFLNOFU - SIATUS UNKNIKJIM 1 b3|
UNKi\iUlr;lM I 501 1
""'u 1 261361
fHF LIF At,

1
It I
HLfMT I
1
7.391
43.751
23.691
23.01 1
0.241
1.921
100.001
tNCY |
	 . 	 _. — . — ,
PKIVAIF. SCHUULS 1
NA1 TONAL tSTIMAIt 1
FSTlMATt IPEHLFNT 1
1 1
1
5731 12.221
20501 43.671
9221 19.641
11201 23.871
.1 .1
281 0.601
46931 100.001


TUTAL
NAIIUNAL tSUMA



It
tSUMAlE IPEKLtNF
1
25051
134851
71131
71341
631
529|
308301

8.13
43.74
23.07
23.14
0.20
1.72
100.00
I
en
o
                             * For inspected  schools built before January 1,  1979  in which
                               asbestos-containing friable materials were found.
                               Situation  at LEA as of  January, 1984

-------
                             TAHLF 45.  STATUS OF KFMOVAL WORK IN SCHOOLS USINK THIS METHOD  »
                                                                                                  11:57 MONDAY* APPTL




REMOVAL STATUS
REMOVAL COMPLETED
REMOVAL ON-GOING
REMOVAL PLANNED
TOTAL
TYPE OK AdtNCY 1
PUBLIC SCHOOLS 1 PRIVATE SCHOOLS 1 TOTAL
NATIONAL ESTIMATE 1 NATIONAL ESTIMATE 1 NATIONAL ESTIMATE
ESTIMATE (PERCENT 1 ESTIMATE (PERCENT I ESTIMATE IPtRCENT
II II 1
ii ii i
II II 1
60641 58.751 10501 60.6RI 71141 59.03
4861 4.711 1161 6.691 6021 4.99
37721 36.541 5651 32.631 43371 35.9fl
103231 100.001 17301 100.001 120511 100.00
I
(SI
                                     *For inspecteu schools built before January 1, 1979 in which
                                      asbestos-containing friable materials were found and which
                                      use removal as a method of abatement.
                                            Situation at LEA as of January, 1984

-------
                          TABLE  46.   AVEHAGt SO FT OF ACFM IN SCHOOLS USING REMOVAL ABATEMENT  *



STATUS OF ABATEMENT
COMPLETED
ON-GOING
PLANNED
1
PUBLIC
SCHOOLS
AVERAGE
SQUARE FEET

6908
1 7151
1 9083
•YPE OF AGENCY
PRIVATE 1
SCHOOLS 1
AVERAGE 1
SQUARE FEET 1
1
1
24001
1 4352 1
1 51171

ALL SCHOOLS
AVERAGE
SQUARE FEET

6338
6450
8470
I
w
M
*For inspected schools built before January 1, 1979 in which
 asbestos-containing friable materials were found and which
 use removal as a method of abatement.
                                         Situation at LEA as of January, 1984

-------
47.
COST
                                      SiH'Af.'F FOOT TO
                                                                   ACFM *
1
1
1
1
1
1
STATUS OF A6ATFMFNT 1
COMPLFTFH 1


TYPF OF '.PPMPY
PLIRLTC i P^TVATF i
SCHOOLS | SPHOOLS IALI
AVFPAGF COc;T 1 AVF^ AGF CnST|A*'F
1 1
i i
^.371 3.0ft|
O A £. 1 A Q Q 1
3.471 0.671

SCHOOLS
PJAGF COST

3.14
P.?0
3.01
Ul
to
*For LEAs with at least one school  built  before  January 1,  1979,  that
 inspected and found asbestos-containing  friable materials  and that
 plan to use removal as a method of abatement.

 Situation at LEA as of January, 1984.

-------
TABLE 48.   INTF.NOED START  OF  HEMOVAL  IN LEAS PLANNING KFMOVAL *

PLANNED ONSET OF REMOVAL
< 3 MONTHS
TYPE OF AGENCY 1
MUHLIC LF.A 1
NATIONAL ESTIMATE 1
ESTIMATE IPERCENT I
1 1
1 1
871 9.411
3-6 MONTHS 1 371 1 40.371
7-12 MONTHS 1 2721 29.551
OVER 1 YEAR 1 1201 13.061
NOT ASCERTAINED 1 701 7.611
TOTAL 1 9201 100.001
PRIVATE LEA 1
NATIONAL ESTIMATE 1
ESTIMATE IPFRCENT 1
1 1
1 1
11 0.421
1581 53.651
75| 25.401
401 13.561
211 6.971
2951 100.001
TOTAL
NATIONAL ESTIMATE
ESTIMATE PERCENT
1
1
881 7.23
5301 43.59
3471 28.54
1601 13.18
911 7.46
12151 100.00
   *Por LEAs with at least one school built before January 1,  1979 that
    inspected and found asbestos-containing friable materials  and that
    plan to use removal as a method of abatement.
    Situation at LEA as of January, 1984

-------
                            TABLE  49.   SCHOOLS  USING ENCLOSURE ABATEMENT* BY STATUS OF WOKK
tn
ui

STATUS OF ENCLOSURE WORK
COMPLETED

TYPE OF AGtNCY

1
PUBLIC SCHOOLS 1 PRIVATE SCHOOLS I
SCHOOLS
1
SCHOOLS
1
TOTAL
SCHOOLS


ESTIMATE (PERCENT 1 ESTIMATE (PERCENT 1 ESTIMATE (PERCENT
1
22161
ON-GOING 1 5641
PLANNED 1 8181
TOTAL 1 35981
1
61.591
15.671
22.741
100.001
1
1
7741
491
1391
9621
1
1
80.411
5.101
14.481
100.001
1
1
?990I
6131
9571
45601
65.56
13.44
20.99
100.00
                       *For inspected schools built before January 1, 1979 in which

                        asbestos-containing friable materials were found and which use
                        enclosure as a method of abatement.
                               Situation at LEA as of January, 1984

-------
TABLE  50.   AVERAGE  SU  FT  UF  ACFM  IN SCHUULS U3TN6 ENCLOSURE ABATEMENT *



STATUS OF ABATEMENT
COMPLETED
ON-GOING
PLANNED
1
PUBLIC
SCHOOLS
AVERAGE
SQUARE FEET

4823
1 3523
1 4247
YPE OF AGENCY
PRIVATE 1
SCHOOLS 1
AVERAGE 1
SQUARE FEET 1
1
1
15151
1 1241
1 11441

ALL SCHOOLS
AVERAGE
SQUARE FEET

3958
3036
3711
     *For inspected schools built before January 1, 1979 in which
      asbestos-containing friable materials were found and which use
      enclosure as a method of abatement.
               Situation at LEA  as  of January,  1984

-------
              51.   AVFRAGF COST PFR SQUARF FOOT TO FNCLCSF ACFM



STATUS OF ARATFMFNT
COMPLETED
ON-GOING
PLANNED

PUBLIC
SCHOOLS
AVERAGE COST

2.84
3.29
3.51
TYPF OF AGFNCY
1 PRIVATE 1
1 SCHOOLS 1
| AVERAGE COSTI
1 I
1 |
1 6.121
1 0.001
1 2.001

ALL SCHOOLS
AVFRAGF COST

3.99
3.?9
3.3?
>
01
*For LEAs with at least one school built before January 1, 1979 that
 inspected and found asbestos-containing friable materials and that
 plan to use enclosure as a method of abatement.

 Situation at LEA as of January, 1984

-------
TABLE
                                      INTENDED START OF ENCLOSURE IN LEAS  PLANNING  ENCLOSURE *





PLANNED ONSET OF ENCLOSURE

< 3 MONTHS
TYPE OF AGENCY
	
PUBLIC LEA 1
NATIONAL ESTIMATE 1
ESTIMATE IPERCENT 1
1 1
1 |
861 29.041
3-6 MONTHS 1 1*1 1 47.761
7-12 MONTHS 1 401 13.571
OVER 1 YEAR 1 61 1.971
NOT ASCERTAINED 1 231 7.661
TOTAL 1 2951 100.001

PRIVATE LEA
NATIONAL ESTIMATE
ESTIMATE IPERCENT
1
1
211 14.76
821 59.11
131 9.57
.1
231 16.57
1391 100.00
1
1
1
1
1
1
I
1
1
1
1
1
1


TOTAL
NATIONAL ESTIMATE
ESTIMATE IPERCENT
1
I
1061 24.45
2231 51.40
531 12.29
61 1.34
46| 10.5?
434) 100.00
Ul
on
                      *Por LEAs with at least one school built before January 1, 1979 that

                      iSTE*1 and *?"* asb^tos-containing friable materSls'and
                      plan to use enclosure as a method of abatement.
                                   Situation at LEA as of January,  1984

-------
                           TABLE 53.   SCHOOLS  USING  ENCAPSULATION ABATEMENT* RY STATUS OF WORK *
in
vo




STATUS OF ENCAPSULATION WORK
COMPLETED
ON-GOING.
PLANNED 1
TOTAL 1
TYPE OF AG
PUHLIC SCHOOLS 1
SCHOOLS 1
ESTIMATE (PERCENT I
1 1
1 I
63351 78.361
6181 5.811
16981 15.941
106511 100.001
ENCY 1
PRIVATE SCHOOLS 1
SCHOOLS 1
ESTIMATE (PERCENT I
1 1
1 1
13431 76.451
1071 6.111
3061 17.441
17571 100.001

TOTAL
SCHOOLS
ESTIMATE 1
1
1
96791
7261
20041
124091



PERCENT

78.00
5.B5
16.15
100.00
                                *For  inspected  schools  built before January 1,  1979  in which
                                 asbestos-containing  friable materials  were found and which
                                 use  encapsulation as a method of abatement.
                                      Situation  at  LEA  as  of  January,  1984

-------
                  TABLE 5U.  AVERAGE S(J FT  ACFM IN SCHOOLS  hITH  FNC APSULAT ION ABATEMENT



STATUS OF ABATEMENT
COMPLETED
ON-GOING
PLANNED

PUBLIC
SCHOOLS
AVERAGE
SQUARE FEET
,«
7341
1 4080
1 5710
VPE OF AGENCY
PRIVATE 1
SCHOOLS 1
AVERAGE 1
SQUARE FEET 1
1
1
32911
1 55701
1 92781

ALL SCHOOLS
AVERAGE
SQUARE FEET

6853
4316
6154
I
a\
o
*For inspected schools built before January 1, 1979 in which

 asbestos-containing friable materials were found and which

 use encapsulation as a method of abatement.


          Situation at LEA as of January, 1984

-------
       TABLF  SS.   AVFR6GF  COST PFR SQUARF FOOT TO F^CAPSULATF ACF* «
1


STATUS OF AHATFMFNT
COMPLFTFO
ON-GOING
PLANNFD
TYPF OF AGENCY
PURLTC | PPTVATF 1
SCHOOLS | SCHOOLS 1
AVFRAGF TOSTIAVFRAGF COSTI
1 1
?.A?I A.RAI
1.041 2.P7I
1.1*1 ?.noi

AIJ SCHOOLS
/\VFRARF COST

?.«
1.17
1.??
*For inspected schools built before January 1, 1979 in which
 asbestos-containing friable materials were found and which
 use encapsulation as a method of abatement.
 Situation at LEA as of January 1984

-------
TABLE 56. INTF.NHED START OF ENCAPSULATION 1

PLANNED ONSET OF ENCAPSULATION
< 3 MONTHS


TYPE
PUBLIC LEA
NATIONAL ESTIMATE
ESTIMATE
57
3-6 MONTHS 1 213
7-12 MONTHS 1 177
OVER 1 YEAR 1 32
NOT ASCERTAINED 1 83
TOTAL 1 562
1
1
1
1
1
1
1
1
1
OF AO.F
1
1
PERCENT I
10
37
31
*
14
100
1
1
.101
.971
.491
.701
.731
.001
N LFAS PLANNING ENCAPSULATION *
NCY

PRIVATE LEA
NATIONAL EST
ESTIMATE
81
166
21
15
23
306
IMATE
(PERCENT
t
1
1 26.57
1 54.2fl
1 6.71
1 4.90
I 7.53
1 100.00
1
1
1
1
1
1
1
1
1
1
1
1
1
TOTAL
NATIONAL EST
ESTIMATE
13*
380
198
47
106
869

T

MATE
IPFRCF.NT
1
1
1
1
1
1
1
1
15.92
43.73
22.75
5.42
12.19
100.00
0\
M
                              *For LEAs with at least one school built before January 1, 1979 that
                               inspected and found asbestos-containing friable materials and that
                               plan to use encapsulation as a method of abatement.
                                            Situation at LEA as of January, 1984

-------
                               TABLE  57.   SCHOOLS USING 0/M/rt AHATEN'ENT, BY STATUS OF WORK «




STATUS OF OTHER OPERATIONS WORK
COMPLETED
ON-GOING
PLANNED
TOTAL
TYPE OF
PUHLIC SCHOOLS
SCHOOLS
ESTIMATE IDERCENT
1
1
25451 22.37
64611 56.79
23701 20.84
113771 100.00
AG
1
1
1
1
I
1
1
1
1
EMCY
PRIVATE SCHOOLS
SCHOOLS
ESTIMATE IPERCENT
1
1
2551 18.82
8191 60.39
2821 20.79
13561 100.00
1
1
1
1
1
1
1
I
1
1
1
1

TOTAL
SCHOOLS
ESTIMATE

2801
7280
2652
12734



IPERCENT
1
1
1 21.99
1 57.18
1 20.83
1 100.00
01
CJ
                                *For inspected schools built before January 1, 1979 in which
                                 asbestos-containing friable materials were found and which use
                                 operations/maintenance/reassessment as a method of abatement.
                                 Situation  at  LEA as of January,  1984

-------
                              TABLE 58.  AVERAGE SO FT OF  ACFM IN SCHOOLS  USING 0/M/R ABATEMENT *



STATUS OF' ABATEMENT
COMPLETED
ON-GOING
PLANNED
TYPE OF AGENCY
PUHLIC PRIVATE 1
SCHOOLS SCHOOLS 1
AVERAGE AVERAGE 1
SQUARE FEET SQUARE FRET 1
1
9780 38691
1 103991 37991
1 76541 33051

ALL SCHOOLS
AVERAGE
SQUARE FEET

9293
9819
6937
I
CT-
*For inspected schools built before January 1, 1979 in which
 asbestos-containing friable materials were found and which use
 operations/maintenance/reassessment as a method of abatement.


              Situation at LEA as of January, 1984

-------
                           TABLE  59.   INTFNDtl) STAKJ OF 0/M/K IN LF AS PLANNING 0/^/H


PLANNED ONSET OF 0/M/R
< 3
3 -
7 -
OVER
NOT
MONTHS
TYPE OF AGENCY
PUBLIC LFA
NATIONAL EST
ESTIMATE
96
6 MONTHS 1 183
12 MONTHS 1 143
1 YEAR 1 64
ASCERTAINED 1 17R
TOTAL 1 663
IMATE
1
1
1
1
1
1
1
1
1
PERCENT
14.44
27.54
21.53
9.67
26.82
100.00
1
1
1
1
1
1
1
1
1
1
1
PRIVATE LFA
NATIONAL ESTIMATE
ESTIMATE 1
1
1
1561
561
561
131
.1
2821
PERCENT
55.46
19.80
20.02
4.73
•
100.00
1
1
1
1
1
1
1
1
1
1
1
1
1
TOTAL


NATIONAL ESTIMATE
ESTIMATE
252
238
199
77
178
945
1
1
1
1
1
1
1
1
I
PERCENT
26.67
25.23
21.08
8,20
18.82
100.00
I
o\
in
                              *Por LEAs with at least one school built before January 1, 1979 that

                               inspected and found asbestos-containing friable materials and that

                               plan to us operations/maintenance/reassessment as a method of

                               abatement.
                                            Situation at  LEA as of January,  1984

-------
TAHLt MJ,
THAT Cl.alHFp FXK'
-------
TABLE 61. PERCENT OF ASBESTOS-CONTAINING  MATERIALS  FOUND  IN PIPE WHAP AT LEAS





PFRCENT PIPE WRAP


0

	
PUBLIC
NATIONAL
ESTIMATE


1939
1-34 1 1373
P5-49 1 218
50-74 1 251
75-99 1 274
100 1 2710
NOT SPECIFIED I 78
TOTAL 1 6842



TYPE

LEA
OF AGENCY

1
ESTIMATE 1
1
1
1
1
1
1
1
1
1
1
1
PERCENT I


28
20
3
3
4
39
1
100
1
1
.351
.071
.191
.661
.001
.611
.131
.001


PRIVATE
NATIONAL
ESTIMATE


1222
433
21
41
161
2261
50
4189

LEA
1
	 1
1
ESTIMATE 1
1
1
1
1
1
1
1
1
1
1
1
PERCENT 1


29
10
0
0
3
53
1
100
1
1
.191
.331
.491
.981
.851
.971
.191
.001






TOTAL
NATIONAL
ESTIMATE


3162
1806
238
292
435
4971
127
11031
EST
IMATE
(PERCENT
1
1
1
1
1
1
1
1
1
1


28.66
16.37
2.16
2.64
3.94
45.06
1.15
100.00
       *Por LEAs with at least one school built before January 1, 1979,
        that inspected and found asbestos-containing friable materials
        in one or more school.
                  Situation at LEA as of January,, 1984

-------
       TABLE 62.  LEAS COMPLYING WITH ALL ASPECTS OF RULE RY 6/30/83  *

COMPLIANCE STATUS
COMPLIED
TYPE OF AGENCY I
PUBLIC LEA 1
NATIONAL ESTIMATE I
ESTIMATE (PERCENT I
1 1
1 1
15291 11.441
DID NOT COMPLY 1 118361 88.561
TOTAL 1 133641 100.001
PRIVATE LEA 1
NATIONAL ESTIMATE 1
ESTIMATE IPERCENT 1
1 1
1 1
13701 10.091
122021 R9.91I
135721 100.001
* *For LEAs with at least one school built before January
that have completed inspections.
D
TOTAL
NATIONAL ESTIMATE
ESTIMATE (PERCENT
1
. 1
28991 10.76
240371 89.24
269361 100.00
1, 1979
*1.  All schools in LEA built before January 1, 1979 were inspected by the end of June, 1983.
 2.  LEAs have Form 7730-1 on file and completed it before the end of June, 1983.
 3.  For LEAs that sampled, at least three samples per homogeneous sampling area were taken
     with the last results having been received before the end of June, 1983.
 4.  Employees were notified in schools with asbestos-containing friable materials using
     Form 7730-3 with the first notification occurring before the end of June, 1983.
 5.  Parents were notified in schools with asbestos-containing friable materials with the
     first notification occurring before the end of June, 1983.

-------
  TABLE 62A.  LEAS WITH ASBESTOS THAT COMPLIED WITH
            MOST ASPECTS OF THE MULE BY JANUARY,1984 *

COMPLIANCE STATUS
COMPLIED
TYPE OF AGENCY 1
PUBLIC LEA 1
NATIONAL ESTIMATE 1
ESTIMATE IPERCENT 1
1 1
1 1
13931 20.351
DID NOT COMPLY 1 54491 79.651
TOTAL 1 68421 100.001
PRIVATE LEA 1 TOTAL
NATIONAL ESTIMATE 1 NATIONAL
ESTIMATE IPERCENT 1 ESTIMATE
1 1
1 1
9551 22.791
32341 77.211
41R9I 100.001 1
ESTIMATE
IPERCENT
1
1
23471 21.28
86831 78.72
10311 100.00
*For LEAs with at least one school built before January 1, 1979
that inspected and found asbestos-containing friable materials
I in one or more school.

-------
                                  TABLE 626.  LEAS WITH ASBESTOS THAT COMPLIED WITH
                                            MOST ASPECTS OF THE MULE BY JANUARY*19B4

COMPLIANCE STATUS
COMPLIED


TYPE
PUBLIC LEA
NATIONAL EST
ESTIMATE
3662
DID NOT COMPLY 1 3180
TOTAL 1 6842
IMATE
1
1
1
1
1
1
OF
1
1
PERCENT |
53
46
100
1
1
.521
• 4R|
.001
AGENCY

PHIVATE LEA
NATIONAL ESTIMATE
ESTIMATE 1
1
1
21901
199RI
41«9I
PERCENT
52.29
47.71
100.00
1
1
1
1
1
1
1
1
1
1
TOTAL



NATIONAL ESTIMATE
ESTIMATE
5852
5179
11031
1
1
1
1
1
1
PERCENT
53.
46.
100.
05
95
00
 I
o
rl.  All  schools  in  LEA  built  before January 1,  1979  were  inspected.
 2.  LEAs have  some  documentation  on file describing  inspection  results,
 3.  LEA  took some samples  of  friable materials  for analysis.

            Situation at LEA  as of January, 1984
                          *Por LEAs with at least one school built before January 1, 1979
                           that have completed inspections.

-------
TABLE 63.  LEAS COMPLYING WITH MOST ASPECTS  OF  THE  RULE  BY JANUARY.1984 «




COMPLIANCE STATUS
COMPLIED
DID NOT COMPLY
TOTAL
TYPE OF
PUBLIC LEA 1
NATIONAL ESTIMATE I
FSTIMATE (PERCENT |
1 1
1 1
51791 38.751
R186I 61.251
133641 100.001
AGENCY 1
PRIVATE LEA 1
NATIONAL ESTIMATE 1
ESTIMATE (PERCENT 1
1 1
i i
1 1
58721 43.261
77001 56.741
135721 100.001

TOTAL
NATIONAL ESTIMATE
ESTIMATE (PERCENT
1
11050! 41.02
158861 58.98
269361 100.00
           *For LEAs with at least one school built before January 1, 1979
            that have completed inspections.
                  Situation at LEA as of January, 1984
  *1.   All  schools in LEA built before January 1,  1979  were inspected.
   2.   LEAs have some documentation on file describing  inspection  results.
   3.   LEA  took some samples of friable materials  for analysis.
   4.   LEA  notified employees and parents at schools where asbestos-containing
       friable materials were found.

-------
                        TABLE 63A.  LEAS COMPLYING WITH MOST ASPECTS OF THE RULE RY JANUARY.1984  *




COMPLIANCE STATUS
COMPLIED
DID NOT COMPLY
TOTAL
TYPE OF
PUBLIC LEA 1
NATIONAL ESTIMATE 1
ESTIMATE i PERCENT i
1 1
1 1
73771 55.201
59881 44.801
133641 100.001
AGENCY 1
PRIVATE LFA 1
NATIONAL ESTIMATE i
ESTIMATE IPERCENT 1
1 1
t i
1 1
71071 52.371
64641 47.631
135721 100.001

TOTAL
NATIONAL ESTIMATE
ESTIMATE IPRRCEMT
i
144841 53.77
124521 46.23
269361 100.00
 I
^1
NJ
*For LEAs with at least one school built before January 1, 1979
 that have completed inspections.


       Situation at LEA as  of  January,  1984
                            *1.  All schools  in LEA built before January  1,  1979 were  inspected.

                             2.  LEAs have  some documentation  on file describing inspection results.

                             3.  LEA took some samples  of friable materials  for analysis.

-------
        TAbLE hf.
                                                         ; FOOTAGE OF ACFM FOUND IN SCHOOLS *

ASBESTOS

FOUND
SQUARE FOOTAGE OF ASBESTOS
LEAS WITH
LEAS NOT
TYPF. OF
Di.J^LIC LF.A 1
NATIONAL F.STIMATt 1
ESTIMATE 1
1
1
15956297HI
PIPE WRAP ONLY 1 2B11 1
ASCERTAINED 1 2b8 1
AGENCY 1
PRIVATE LFA 1
NATIONAL ESTIMATE i
ESTIMATE 1
1
1
157380861
2261 1
4361
TOTAL
NATIONAL ESTIMATE
ESTIMATE
175301065
5072
694
I
^J
u>
*For LEAs with at least one school built before January 1, 1979,

 that inspected and found asbestos-containing friable materials

 in one or more school.
                                             Situation at LEA as of January, 1984

-------
 APPENDIX B






QUESTIONNAIRE

-------
     INTRO;  Hello, my name is
                         and I'm calling from
     the Washington, D.C. area for the Environmental Protection
     Agency.  We recently sent you a questionnaire for a study
     we are" doing on the asbestos inspection and notification
     rule.  Are you the person who can best provide me with
     your (schools'/agency's) answers to the questionnaire?
OMB #:  2070-0019
Expires:  Aug. 31,  1984
               U.S.  Environmental Protection  Agency
Asbestos-ln-Schools  Identification and  Notification  Rule
                                Questionnaire
                                        (label)
          PLEASE RECORD THE FOLLOWING INFORMATION, ONLY IF DIFFERENT FROM THE LABEL ABOVE.
Name of School or School District:
Mailing Address:
Street or PO Box
City State
Zip Code
                                                                                      16-17
    1.
                          I.  AGENCY INFORMATION

What type of education agency is this?  [CIRCLE ONLY ONE CODE]
                                                                        01
        a. Public school district	
        b. Private school system (made up of two or
           more schools, administered by this agency)	02
        c. Private school	03

        d. Other [SPECIFY]: 	 04
                                                                                      18-19
    2.  If this is a school district or system, how many schools are administered or governed by
        this system?

                NUMBER OF SCHOOLS:
                                                                               20-22
                                          B-l

-------
What is the total number of students currently enrolled in your school(s)?

          NUMBER OF STUDENTS:
                                                                                               23-32
Were any of your school buildings built before January 1, 1979?  [INCLUDE BUILDINGS THAT
ARE LEASED, RENTED OR USED, AS WELL AS BUILDINGS THAT ARE OWNED.  CIRCLE ONLY ONE CODE]

          Yes [GO ON TO QUESTION 5]	1
          No [SKIP QUESTIONS 5 THROUGH 56 OF THIS QUESTIONNAIRE.
             WHEN THE INTERVIEWER CALLS, YOU WILL ONLY NEED TO GIVE
             GIVE ANSWERS FOR QUESTIONS 1 THROUGH 4]	  2
33
How many of your schools were built during the following decades?  [IF A SCHOOL USES
BUILDINGS OR PARTS OF BUILDINGS THAT WERE BUILT IN DIFFERENT DECADES, PLEASE CLASSIFY THE
SCHOOL ACCORDING TO THE OLDEST STRUCTURE, RATHER THAN THE NEWEST STRUCTURE.  IF THERE IS
ONLY ONE SCHOOL WRITE "1" NEXT TO THE DECADE OF CONSTRUCTION.]
DECADE
a.
b.
c.
d.
e.
f.
g-
h.
i.
j-
k.
1979 -
1969 -
1959
1949 -
1939 -
1929 -
1919 -
1909 -
1899 -
Before
1983
1978
1968
1958
1948
1938
1928
1918
1908
1899
Total number of schools (SHOULD EQUAL QUESTION 2):
NUMBER OF SCHOOLS











                                                                                               34-36

                                                                                               37-39

                                                                                               40-42

                                                                                               43-45

                                                                                               46-48

                                                                                               49-51

                                                                                               52-54

                                                                                               55-57

                                                                                               58-60

                                                                                               61-63

                                                                                               64-66
                                         B-2

-------
                               II.   INSPECTION  PROGRAM  INFORMATION
 6.   All  education  agencies  have been required by the  EPA  to  inspect  all school  buildings built
     before  January 1,  1979,  to look for  friable  materials* that may  contain  asbestos.   Has
     there been or  is  there  scheduled to  begin an inspection  program  for friable materials in
     your school buildings?   (Program may be  conducted by  school,  district, or outside  source.)
       *THE DEFINITION  OF FRIABLE MATERIALS IS "ANY  MATERIAL  APPLIED  ONTO CEILINGS,
       WALLS,  STRUCTURAL  MEMBERS, PIPING,  DUCTWORK,  ETC.,  WHICH WHEN  DRY MAY  BE  CRUMBLED,
       PULVERIZED OR REDUCED TO POWDER BY  HAND PRESSURE."
               Yes [GO ON TO QUESTION 7]	1
               No [SKIP TO QUESTION 55]	2


 7.   Is the friable material inspection program being conducted  by this school (or school
     district)  or is it being conducted by an outside agency?  [CIRCLE  ONLY  ONE CODE]

               u.  This school (district)	01
               b.  Outside agency [SPECIFY]:  	02
 8.   When was the friable materials inspection program started?

               DATE PROGRAM STARTED: 	/	                                             70-73
                                       MONTH     YEAR

 9.   Which of the following statements best describes the status of friable materials inspection
     in your school(s)?  [CIRCLE ONLY ONE CODE]

               a.  The inspection of the school(s) has been
                   completed [SKIP TO QUESTION 11] 	  01
               b.  The inspection of the school(s) has begun, but
                   has not been completed [SKIP TO QUESTION 12]	02
               c.  The inspection of the school(s) is scheduled
                   to begin in the future [GO ON TO QUESTION 10]	03

10.   On what date is the friable materials inspection of your  (schools/school) scheduled to  begin?

               EXPECTED DATE INSPECTIONS WILL START:  	/	                             76-79
                                                        MONTH     YEAR
                       SKIP QUESTIONS 11 THROUGH 56.
11.  When was the friable materials inspection  of  the  school(s)  completed?

               DATE INSPECTION COMPLETED:  	/	                                       80-83
                                              MONTH     YEAR


                                              B-3

-------
12.  When did the friable materials inspection of the school(s) begin?

               DATE INSPECTION BEGAN:           /
                                         MONTH
                                                                                                    84-87
                                              YEAR
13.
EPA has an on-going technical assistance program for friable materials inspections that
includes a toll-free telephone number, regional technical advisors to assist schools, and
written guidelines for schools.  Has your agency used any of these resources of the tech-
nical assistance program?

          Yes [GO ON TO QUESTION 14]	1
          No [SKIP TO QUESTION 15]	2
                                                                                                    88
14.  Did the technical assistance program meet your needs?
               Yes
               No.
                                                                                               89
15.  EPA has provided written guidelines to assist schools in complying with the asbestos rule.
     These guidelines provide information such as where and how to sample friable materials, where
     to send samples, notification rules and so on.  Please indicate which of the following documents
     you have,  and which of those documents were used as guidelines for your inspections.
Document
a. "Compliance Assistance Guidelines: Friable Asbestos-
Containing Materials in Schools; Identification and
Notification Rule." (This is a ten-page, typed, loose-
leaf handout. The text begins "I. WHO MUST COMPLY"). . .
b. "Asbestos-Containing Material in School Buildings:
A Guidance Document, Part I." (This is an orange
c. "Asbestos-Containing Material in School Buildings:
A Guidance Document, Part II." (This is an orange
covered booklet published in 1979.). ...........
d. "Asbestos-Containing Materials in School Buildings:
Guidance for Asbestos Analytical Programs." (This
is a black covered booklet published in 1980.) ......
e. "Guidance for Controlling Friable Asbestos-
Containing Materials in Buildings." (This is a
blue covered booklet published in 1982.) .........
f. Other [SPECIFY]:


Does you
have copy?
Yes No
1 2
1 2
1 2
1 2
1 2
1 2


Did you
use for
inspection
guideline?
Yes No
1 2
1 2
1 2
1 2
1 2
1 2


                                               B-4
                                                                                                    90-91



                                                                                                    92-93



                                                                                                    94-95



                                                                                                    96-97



                                                                                                    98-99

                                                                                                    100-101


                                                                                                    102-103

-------
16.  DOBS this school or district have a completed Form 7730-1,  "Inspections for Friable Asbestos-
     Containing Materials" on file?  [CIRCLE ONLY ONE CODE]

               Yes [GO ON TO QUESTION 17]	1
               No [SKIP TO QUESTION 18]	2
17.  On what date was this Form 7730-1 completed?

               DATE FORM 7730-1 COMPLETED:  	/
                                              MONTH     YEAR
                                                                                                    105-108
                                    III.  INSPECTION RESULTS


The following questions are about the results of the inspections of your school(s).   For each
question please specify the source of information that you used for your answer.  These questions
are taken directly for the Form 7730-1.  If you have a completed Form 7730-1  on file, please use
the form as the source for your information.


18.  Please review questions 19 through 24, and indicate which source of information you will use
     to answer these questions.  [CIRCLE ONLY ONE CODE]

                                        Form 7730-1	01
                                        Other [SPECIFY] 	  02                109-110
19.  [FORM ITEM 2]:  How many schools have been inspected for friable materials?  [DO NOT
     INCLUDE SCHOOLS THAT WERE BUILT AFTER DECEMBER 31, 1978]

               NUMBER OF SCHOOLS INSPECTED:                                                          111-113
20.  [FORM ITEM 3]:  How many of the  inspected schools had  friable materials present?   [IF  NO
     SCHOOLS HAD FRIABLE MATERIALS PRESENT, CIRCLE "000" AND SKIP QUESTIONS 21 THROUGH  56]

               NUMBER OF SCHOOLS
               WITH FRIABLE MATERIALS:  	        114-116

                                        None  [SKIP QUESTIONS 21  THROUGH  56],  .  .  000
                                               B-5

-------
 21.   [FORM  ITEM 4]:   How  many  schools  with  friable  materials  have  had  samples  analyzed  for
      asbestos content?  [IF NO SCHOOLS HAVE  HAD  SAMPLES  ANALYZED FOR ASBESTOS, CIRCLE "000" AND
      SKIP QUESTIONS 22  THROUGH 55]

               NUMBER OF  SCHOOLS WITH
               SAMPLES  ANALYZED FOR  ASBESTOS:  	         117-119

                                         None [SKIP  QUESTIONS  22 THROUGH  56].  . . 000


 22.   [FORM  ITEM 5]:   How  many  of the schools had asbestos-containing friable material?   [IF NO
      SCHOOLS HAD ASBESTOS-CONTAINING FRIABLE MATERIAL, CIRCLE "000" AND  SKIP TO QUESTION 24]

               NUMBER OF  SCHOOLS WITH  ASBESTOS-
               CONTAINING FRIABLE MATERIAL:  	         120-122

                                         None [SKIP  TO QUESTION 27]	000

                                                                                                    I02I
 23.   [FORM  ITEM 6]:   What was  the total  area in  square feet of all friable asbestos-
      containing materials found in these schools?

               NUMBER OF  SQUARE FEET OF  ASBESTOS-
               CONTAINING FRIABLE MATERIAL FOUND:  	 sq. ft.         16-25


 24.   [FORM  ITEM 7]:   What is the total number  of school  employees who  regularly work in  the
      schools where asbestos containing materials were found?

               TOTAL  NUMBER OF EMPLOYEES IN
               SCHOOLS  WHERE ASBESTOS  WAS FOUND:                                                     26-35
25.  Of the total number of school employees who  regularly work in schools where asbestos-
     containing friable materials were found, how many are professional staff, how many are
     custodians, and how many  are other nonprofessional staff?

                                                                        Number
                                                                     of employees

         a.  Number of teachers, administrators and other
             professional staff		                36-45
         b.  Number of custodians		                46-55

         c.  Number of other nonprofessional and  support staff .  . 	                56-65
         d.  Total  (SHOULD EQUAL ANSWER  TO QUESTION 24)	 	                66-75


26.  What is the total number of students enrolled in the school(s) where asbestos-containing
     friable materials were found?

               NUMBER OF STUDENTS ENROLLED:                 	                                 76-85
                                              B-6

-------
                             IV.   SAMPLING & ANALYSIS INFORMATION


27.  On the average, how many samples of a friable material were taken from each sampling area?

               NUMBER OF SAMPLES PER SAMPLING AREA:  	                             88-90


28.  What was the first date that samples were taken?

               STARTING DATE OF SAMPLING:  	/	                                       91-94
                                             MONTH     YEAR
29.  What was the last date that samples were taken?  [IF SAMPLING IS STILL IN PROCESS, CIRCLE
     "0000"]

               LAST DATE SAMPLES WERE TAKEN:  	/	                                    95-98
                                                MONTH     YEAR
                                              Still in process	 0000


30.  What was the first date that samples were sent to be analyzed?  [IF NO SAMPLES HAVE BEEN
     SENT FOR ANALYSIS, CIRCLE "0000" AND SKIP TO QUESTION 34]

               DATE FIRST SAMPLES SENT: 	/	
                                          MONTH     YEAR                                            99-102
                                        No samples sent [SKIP TO QUESTION 34]  . 0000


31.  What was the last date that samples were sent to be analyzed?  [IF ALL SAMPLES HAVE NOT
     BEEN SENT, CIRCLE "0000"]

               DATE LAST SAMPLES SENT:  	/	
                                          MONTH     YEAR                                             103-106
                                        Still in process	0000


32.  What was the first date that you received results  from any sample  analysis?   [IF  RESULTS
     HAVE NOT BEEN RECEIVED, CIRCLE "0000" AND SKIP QUESTIONS 34  THROUGH  56]

               DATE FIRST RESULTS RECEIVED:           /
                                                MONTH      YEAR
                                              No results  received  [SKIP                               107-110
                                              QUESTIONS 34 THROUGH 56]	0000
33.  What was the last date  that  you  received results from any sample analysis?  [IF ALL RESULTS
     HAVE NOT BEEN RECEIVED, CIRCLE "0000"]

               DATE LAST RESULTS  RECEIVED:            /
                                               MONTH     YEAR                                         111-114
                                             Still in process	0000
                                                B-7

-------
             V.   INFORMATION  ON  SCHOOLS WITH ASBESTOS-CONTAINING FRIABLE MATERIALS
I03|
34.   Were asbestos-containing  friable materials found in any of your school(s)?

               Yes [GO  ON  TO QUESTION 35]	1
               No [SKIP QUESTIONS  35 THROUGH 56]  	   2
16
35.   How many of the schools  that  were  found to have asbestos-containing friable material were
     built during the following  decades?   [IF A SCHOOL USES BUILDINGS OR PARTS OF BUILDINGS THAT
     WERE BUILT  IN DIFFERENT  DECADES, PLEASE CLASSIFY THE SCHOOL ACCORDING  TO THE OLDEST STRUCTURE
     RATHER THAN THE NEWEST STRUCTURE]
DECADE
a.
b.
c.
d.
e.
f.
g-
h.
i.
j-
k.
1979
1969
1959 -
1949
1939 -
1929
1919
1909
1899
Before
Total
1983
1978
1968
1958
1948
1938
1928
1918
1908
1899
number of schools (SHOULD EQUAL ANSWER TO QUESTION 22):
NUMBER OF SCHOOLS











                                                                                                  17-19

                                                                                                  20-22

                                                                                                  23-25

                                                                                                  26-28

                                                                                                  29-31

                                                                                                  32-34

                                                                                                  35-37

                                                                                                  38-40

                                                                                                  41-43

                                                                                                  44-46

                                                                                                  47-49
           What  percentage of  the total amount  of asbestos-containing
           friable material found in (all) your school(s) was from  other
           than  pipe or duct insulation?   (for  instance, from ceilings aad
           walls)
                          	 percent
                                            B-8

-------
36.  In how many of the schools where asbestos was found was notice concerning the presence of
     asbestos provided to the school employees?  [IF THERE ARE NO SCHOOLS WHERE EMPLOYEES HAVE
     BEEN NOTIFIED, CIRCLE "000" AND SKIP TO QUESTION 39]

               NUMBER OF SCHOOLS WHERE
               EMPLOYEES HAVE BEEN NOTIFIED:  	                50-52

                                              None [SKIP TO QUESTION 39]. ...  000


37.  Was notice to these employees provided using EPA Form 7730-3 or by some other method?
     [CIRCLE ONLY ONE CODE]

               a.  EPA Form 7730-3	01
               b.  Other [SPECIFY]: 	  02
                                                                                                    53-54
38.  What was the first date that notice was provided to any school employees?

               DATE OF FIRST
               EMPLOYEE NOTIFICATION:  	/	                                           55-58
                                         MONTH     YEAR
39.  In how many of the schools where asbestos was found was notice concerning the presence of
     asbestos provided to the Parent/Teacher's Association?  [IF THERE ARE NO SCHOOLS WHERE THE
     PARENT/TEACHER'S ASSOCIATION HAS BEEN NOTIFIED, CIRCLE "000" AND SKIP TO QUESTION 42]

               NUMBER OF SCHOOLS WHERE
               P.T.A. HAS BEEN NOTIFIED:  	                       59-61
                                           None  [SKIP TO QUESTION 42] .  .  000


40.  How was notice provided to the Parent/Teacher's Association(s)?
                                                                                                     62-63
41.  What was the first date that  notice  was  provided  to the  Parent/Teacher's Association?

               DATE OF FIRST P.T.A.  NOTIFICATION:  	/	                               64-67
                                                      MONTH     YEAR
                                           SKIP TO Q45
                                               B-9

-------
42.  In how many of the schools where asbestos was found was notice of the presence of asbestos
     sent to the parents of the students attending the school?  [IF THERE ARE NO SCHOOLS WHERE
     NOTICE HAS BEEN SENT TO PARENTS, CIRCLE "000" AND SKIP TO QUESTION 45]

               NUMBER OF SCHOOLS WHERE
               PARENTS WERE NOTIFIED: 	                 68-70

                                      None [SKIP TO QUESTION 45]	000


43.  How was notice provided to the parents of the students attending the school(s)?

                                                                                                    71-72
44.  What was the first date that notice was provided to the parents of the students attending
     the school(s)?

               DATE OF FIRST PARENT NOTIFICATION:  	/	                               73-76
                                                     MONTH     YEAR
                                              B-10

-------
The following questions are about abatement work in the school(s) where asbestos was found.
There are four basic types of abatement.  First is removal of all friable material containing
asbestos.  Second is enclosure of the material with an air-tight, impact resistant barrier.
Third is encapsulation of the friable material by the use of a sealant.  And fourth is special
operations and maintenance procedures and periodic reassessment which can be used to monitor the
building for the need for other abatement activities.
45.  Is any abatement work planned, on-going, or completed in the school(s) where asbestos was
     found?  [CIRCLE ONLY ONE CODE]

               Yes [GO ON TO QUESTION 46]	1
               No [SKIP QUESTIONS 46 THROUGH 56] 	  2
77
46.  In the table below, please indicate the number of schools where all asbestos abatement
     work has been completed, the number of schools where abatement work is currently being
     done, and the number of schools where abatement work is scheduled for the future.
      a.  Number of schools in which all asbestos
          abatement work has been completed	

      b.  Number of schools in which abatement work
          is currently being done	,

      c.  Number of schools in which abatement work
          is scheduled to begin in the future	,


      d.  Total number of schools where abatement
          work has been or will be done (should
          equal the sum of a, b, and <-, above)	



47.  Does your school or district use  removal  as  a method of asbestos abatement?
     [CIRCLE ONLY ONE CODE]

               Yes [GO ON TO QUESTION  48]	1
               No [SKIP TO QUESTION 49]	2
                                                                        Number of schools
78-80
81-83
 84-86
 88-90
 I04|
 16
                                               B-ll

-------
48.  In Column A of the table below, please indicate the number of schools in which the removal
     of asbestos-containing friable materials has been completed, the number of schools in which
     removal is currently being done, and the number in which removal work is planned to begin
     in the future.  In Column B, enter the total number of square feet of friable material
     involved, and in Column C, enter the cost per square foot for the removal of the material.
     In Column D, for future work only, indicate when the work will begin.
          Removal work that
          has been completed
      b.  Removal work that is
          currently being done
      c.  Removal work that is
          planned for the future
                                        A.

                                     Number of
                                      schools
(schools)
(schools)
(schools)
                 B.
            Total number
             of square
                feet
(sq.  ft.)
(sq.  ft.)
(sq.  ft.)
                  C.

                Cost  per
              square  foot
                      D.
                 When will
                 work begin?
                 [CIRCLE  ONE]
                           $
(per sq.  ft.)
(per sq.  ft.)
(per sq.  ft.)
Less than
  3 mos	 1
3-6 mos	 2
7-12 mos	 3
More than
  12 mos	4
                                                  17-39
                                                               40-62
                                                               63-86
                                                                                                     I05I
49.  Does your school or district use enclosure as a method of asbestos abatement?
     [CIRCLE ONLY ONE CODE]

               Yes [GO ON TO QUESTION 50]	1
               No [SKIP TO QUESTION 51]	2
                                                               16
                                              B-12

-------
50.  In Column A of the table below, please indicate the number of schools in which the enclosure
     of asbestos-containing friable materials has been completed,  the number of schools in which
     enclosure is currently being done, and the number in which enclosure work is planned to begin
     in the future.  In Column B, enter the total number of square feet of friable material
     involved, and in Column C, enter the cost per square foot for the enclosure of the material.
     In Column D, for future work only, indicate when the work will begin.
      a.  Enclosure work that
          has been completed
      b.  Enclosure work that is
          currently being done
      c.  Enclosure work that is
          planned for the future
                                        A.


                                     Number of
                                      schools
(schools)
(schools)
(schools)
                 B.

            Total number
             of square
                feet
(sq.  ft.)
(sq.  ft.)
(sq. ft.)
                  C.


                Cost  per
              square  foot
                      D.
                 When will
                 work begin?
                 [CIRCLE  ONE]
(per sq.  ft.)
                           $
(per sq. ft.)
Less than
  3 mos	 1
3-6 mos	 2
7-12 mos	 3
More than
  12 mos	4
                                                               17-39
                                                               40-62
                                                               63-86
                                                                                                     I06I
51.  Does your school or district use encapsulation as  a method of  asbestos  abatement?
     [CIRCLE ONLY ONE CODE]

               Yes [GO ON TO QUESTION 52]	1
               No [SKIP TO QUESTION  53]	2
                                                                16
                                               B-13

-------
52.  In Column A of the table below, please  indicate the number of schools  in which  the encapsu-
     lation of asbestos-containing friable materials has been completed, the number  of schools
     in which encapsulation is currently being done, and the number in which encapsulation work
     is planned to begin in the future.  In  Column B, enter the total number of square feet of
     friable material involved, and in Column C, enter the cost per square  foot for  the encapsu-
     lation of the material.  In Column D, for future work only, indicate when the work will
     begin.
      a.  Encapsulation work that
          has been completed
      b.  Encapsulation work that
          is currently being done
      c.  Encapsulation work that
          is planned for the future
                                         A.


                                      Number  of
                                       schools
(schools)
(schools)
(schools)
                 B.
            Total number
             of square
                feet
(sq.  ft.)
(sq.  ft.)
(sq.  ft.)
                  C.


                Cost  per
              square  foot
                      D.
                 When will
                 work begin?
                 [CIRCLE ONE]
(per sq.  ft.)
(per sq.  ft.)
Less than
  3 mos	 1
3-6 mos	 2
7-12 mos...... 3
More than
  12 mos	4
                                                              17-39
                                                              40-62
                                                              63-86
                                                                                                     I07|
53.  Does your school or district use special operations  and maintenance procedures  and
     periodic reassessment (operations/maintenance/reassessment) as  a method of  asbestos  abatement?
     [CIRCLE ONLY ONE CODE]

               Yes [GO ON TO QUESTION 54]	1
               No [SKIP QUESTIONS 54 THROUGH 56]  	   2
                                                              16
                                              B-14

-------
54.  In Column A of the table below, please indicate the number of schools in which the opera-
     tions/maintenance/reassessment of asbestos-containing friable materials has been completed,
     the number of schools in which operations/maintenance/reassessment is currently being done,
     and the number in which operations/maintenance/reassessment work is planned to begin in the
     future.  In Column B, enter the total number of square feet of friable material involved.
     In Column C, for future work only, indicate when the work will begin.

a. Operations/maintenance/
reassessment work that
has been completed
b. Operations/maintenance/
reassessment work that
is currently being done


c. Operations/maintenance/
reassessment work that
is planned for the future

A.
Number of
schools

(schools)

(schools)




(schools)

B.
Total number
of square
feet

(sq. ft.)

(sq. ft.)




(aq. ft.)

C.
When will work begin?
[CIRCLE ONE]






3-6 mos 	 2
7-12 mos 	 3
More than 1 2 mos 	 4

                                                                                                     17-29
                                                                                                     40-52
                                                                                                     63-75
                                                                                                     86
                                    SKIP  QUESTIONS  55  AND  56.
                                               B-15

-------
55.  Some schools or districts are exempted  from parts of the Asbestos-in-Schools Rule.   Do any
     of the following exemptions  apply to  these  school(s).   [CIRCLE  ONE CODE FOR EACH ITEM]
a.
b.
c.
d.



These school (s) were inspected, sampled, and analyzed prior
to the effective date of the Asbestoa-in- Schools Rule 	
These school (s) can document that no friable asbestos-
containing building materials were used in construction,
Abatement programs in these school (s) have resulted in the
elimination of all friable asbestos materials from the
Other [SPECIFY]:



Yes No
. . . 1 2
. . . 1 2
. . . 1 2
1 2



                                                                                                     87



                                                                                                     88



                                                                                                     89

                                                                                                     90
                                                                                                     91-92
56.  Are there any other reasons that  these  school(s)  have not  been inspected for asbestos-
     containing friable materials?
                                                                                                     93-94
                                              B-16

-------
         APPENDIX C





INTERVIEWER PROCEDURES MANUAL

-------
     ASBESTOS-IN-SCHOOLS

INTERVIEWER PROCEDURES MANUAL
         Prepared by:

         Westat,  Inc.
      December 12, 1983
              C-l

-------
Appendix
                       TABLE OF CONTENTS
Chapter


   1
INTRODUCTION TO EPA ASBESTOS-IN-SCHOOLS
STUDY 	
                                           Page
                                                           1-1
   2


   3


   4
CONTACT/NONCONTACT PROCEDURES
SPECIAL PROCEDURES
QUESTION-BY-QUESTION SPECIFICATIONS FOR
QUESTIONNAIRE 	,
3-1
                                                           4-1
               EPA ASBESTOS-IN-SCHOOLS OFFICIAL FORMS
                                            A-l
                                C-3

-------
       1.  INTRODUCTION TO EPA ASBESTOS-IN-SCHOOLS STUDY
1.1       Overview of Study

          The Environmental Protection Agency,  in an effort to
protect school children from the risks associated with exposure
to airborne asbestos particles, put into operation the Asbestos-
in-Schools Identification and Notification Rule in 1982.   This
rule required all schools, public and private,  to inspect for
friable asbestos.  (These are materials which when dry can be
crumbled and pulverized by hand and contain particles of  asbes-
tos.)  The schools and/or school districts were then required to
post results of the inspection for employees and parents  if
asbestos was found.

          Regardless of the findings of the inspection, an
inspection report on EPA form 7730-1 (Appendix  A) was required to
be kept on file at the district or school office.

          Westat is conducting a survey for EPA to determine
(1) the extent of compliance with the inspection and notifica-
tion rule, (2) results of the inspections, and  (3) numbers of
school employees and pupils exposed to asbestos.
1.2       Sample

          The sample of local education agencies to be called  in
this survey has been selected from listings of all public school
systems, archdioscesan Catholic school systems and non-Catholic
private schools.  You will be calling administrative offices of
public and Catholic school systems and the principals' offices
of private schools.
                                C-5

-------
1.3       Overview of Interviewers' Tasks


          For the questionnaire phase of the study the inter-
viewers will:


          •    Receive assignments consisting of:

                    A Call Record with a Westat ID;

                    A Respondent Information Sheet with the name
                    of the local educational agency  (LEA), the
                    name of the school superintendent or prin-
                    cipal, the address and telephone number of
                    the LEA and, in some cases, the name and
                    number of the individual responsible for the
                    asbestos inspection; and

               -    A Main Questionnaire.

          •    Call the number of the LEA and locate the person
               responsible for the asbestos inspection.

          .    Administer the questionnaire when the person is
               located.

          .    Call back if respondent needs time to locate the
               questionnaire.

          .    Record results of all telephone calls.

          •    Edit all completed survey materials.
1.4       Overview of Survey Materials


          All materials used in the study will be briefly de-

scribed here.  They will be analyzed fully in the procedures

sections and copies can be found in the appendices.


          Letter and Questionnaire.  Approximately two weeks

before the questionnaiare is administered by telephone, a letter

and questionnaire will be sent to the superintendent or school

principal.  The questionnaire is identical to the telephone
                              C-6

-------
questionnaire, except for the handwritten checks and introduc-
tion.  The respondent should fill out the questionnaire in order
to be prepared for the telephone interview.  We are enclosing in
the package a card to be returned to Westat with the name and
number of the person responsible for the asbestos inspection.
If this card is returned, the computer will print the name on
the Respondent Information Sheet.

          Respondent Information Sheet.  This is a computer
generated sheet listing the respondent's Westat ID, name of LEA
(school or school district), address, the telephone number of
LEA, and the superindent or principal's name.  If the informa-
tion has been returned from the respondent, the name of the
person responsible for asbestos inspections will be listed on
the first line of referrals.

          Call Record.  This form is used to record each attempt
you make to contact the respondent as well as the results of
that attempt.  .If you receive a reassignment, the Record also
will show information about previous efforts to call the re-
pondent.  There are only two preprinted  items on the Call Record
of concern to the interviewer:   (1)  the  Westat  ID, which must
match the ID on the Respondent  Information Sheet; and  (2) the
File Name, which will include the time zone of  the respondent.

          Main Questionnaire.   This  booklet contains the ques-
tions to be asked of each  respondent.

          Non-Interview  Report  Form.   This form is  filled  out
when the superindent, principal, or  contact person  refused  to
answer any questions on  the  interview  or when  you  feel you  have
exhausted the possibilities  in  locating  a respondent.

          ID  Labels.  These  labels will  list  the name  of the LEA
and Westat  ID.  These labels will be affixed to the quetionnaire
                              C-7

-------
               2.  CONTACT/NONCONTACT PROCEDURES
2.1       Introduction

          Keeping a record of the result of every phone call you
make for each case is an important part of the research process.
By doing so, we will know how to treat each case according to
its needs, and maintain a record of the productivity of the
survey.  The record-keeping for the EPA Asbestos-in-Schools
Study will be done by the use of a computer management system.
The computer will provide the initial work assignments, and once
acceptable status codes have been acquired, we will code these
status codes into the computer.  This enables us to keep a rec-
ord of all finalized cases.  The receipt control staff will
monitor the needs of the active cases (those that require addi-
tional calls or special handling).

          The procedures you will follow and the codes you will
use for this survey are discussed in this chapter.
2.2       Respondent Information Sheet (RIS)

          There will be one RIS for each school.  This RIS will
provide you with basic information about the school  (see Exhibit
2-1).  The RIS will have the following information:

          •    Westat ID number;
          •    School name, address, city and state;
          •    School telephone number;
          •    Respondent name; and
          •    Place to record new respondent name  and  telephone
               number.
                               C-9

-------
                                  EXHIBIT 2-1
                                  EPA TASK15
WE5TAT ID:   1CCDC1-7
SCHCCL:      ALLEN SC-SCL

ADDRESS:     22CC CEM?AL AVENUE

C:TY:        ALLEM:«\                          STSTE: FA        ZIP:  1?1C5

TELEPHONE:   2139S7551Z

CCMAC7:     JACK JCNEi


NEW CONTACTS:                        NF« PlC\£ NJVEE^S:     _ _
CC^ENTS:
                                      C-10

-------
          The RIS will be stapled to the inside cover of the
folder.
2.3       The Call Record

          The Call Record (see Exhibit 2-2)  is a computer-
generated form that has a two-fold purpose:   (1) it serves as
your work assignment by providing information you will need
regarding the school that you are to call;  and (2) it is the
only means by which you communicate the status of each school
you call and finalize.  One call record will be generated for
each school that you are to contact.  You should use this call
record to keep an account of the calls that have been made.

          After you contact or attempt to contact a school, you
must record the result on the call record.   Since the call rec-
ord is produced in duplicate in computer readable type style,
you should fill out the necessary information on the top sheet,
being careful not to make extraneous marks on the paper.  The
attached call record copy is pressure sensitive, and anything
written or pressed onto the top sheet will be reflected on the
copies.

          Below is an explanation of each item on the call
record:
               File. Key - The file key is a unique number that
               is given to each case
               Previous Disposition - This will be blank unless
               a code  "2" or "9" has been previously  assigned
               (codes  are discussed in Section 2.4.
               Total Calls - This space will be blank until
               computer updating has occurred.
                                C-ll

-------
                                                                      CALL    RECORD
to
KtY: FILE NAME-
IOUS DISPOSITION: TELEPHONE:
kL CALLS: APP DATE/TIME:
INTERVIEWER TIME TIME CALL BACK INFO. D/E/W
INITIALS DATE BEGUN ENDED RESULTS COMMENTS DATE TIME
+0001-6
+0002. b
+0003. M
+OOOM-2
+0005-1
+000b.7
+0007.5
+0006-3
+0001-1
+0010-1






























+ M1320 (1) RING NO ANSWER
+ 50326 (2) FIRST REFUSAL/BREAKOFF
+ 5132b (3) BUSY
+ S232M (4) CALLBACK - NO APPT.
+ 53322 (S) CALLBACK - APPT.
+ 5M320 (6) INITIAL LANG. PROB.
+ 55327 (7) PROJECT SPECIFIC CODE
+ 5b325 (8) PROBLEM (Specify^
+ 57323 (9) MAILOUT NEEDED
+ MlM6b (10) TRACING NEEDED











































+ b7322 (C) COMPLETE CASE ID
+ 60b71 (PC) PARTIAL COMPLETE
+ 73320 (1) INELIGIBLE
+ 71b57 (OA) OUT OF AREA
+ 82bb1 (RB) FINAL REFUSAL/BREAKOFF 'NT. CODE
+ 7b6Q2 (LP) FINAL LANGUAGE PROBLEM
+ 71327 (O) OTHER
*7682M (NR) NON RESIDENTIAL
+ 76bS1 (NA) NO ANSWER
+ 76673 (NW) NON WORKING
+ 787bb (NL) NOT LOCATABLE
+ 63M13 (SI) SPECIFIC 1
+ 63501 (52) SPECIFIC 2
»77L77 (MC) MAXIMUM CONTACT

-------
File Name - This will tell you the name of the
file in the computer for this study.

Telephone Number - This space will be blank for
this study.

Appointment Date/Time - This space will be blank
for this study.

Interviewer Name - You should record your first
initial and last name in this space for every
contact or attempt to contact that you make.

Date - Record the month and date of every contact
or attempt to contact, e.g., 12/15.

Time Began - Record the time you called or at-
tempted to call, and indicate a.m. or p.m., e.g.,
2:45 p.m.

Time Ended - Record the'time you ended the call,
and indicate a.m. or p.m.  If the call does not
result in a contact, put a dash (-) in this
space.

Result - Record the result code of the call/in-
terview by using one of the codes listed  in the
result codes section of the call record.  Result
codes will be further discussed in Section 2.4.

Comments - Record any pertinent comments  or notes
regarding the case  in this space.  These  should
include any relevant  information  about the re-
spondent, the telephone number, or the interview,
etc.  Limit your comments to  one  line, if possi-
ble.  However,  if you feel additional  explanation
is necessary, attach  a  note  to  the call  record.
The note should have  the  ID  number of  the case,
the date, and your  initials.

Callback Information  -  If a  specific appointment
is made with a  respondent to complete the inter-
view, record that  information in  this space.
Record  the month and  date  (12/15) and the time
 (6:30 p.m.).  Always  record  the time first in the
respondent's time  and convert it  to  Westat time
outside the box.   Please  designate the conversion
by indicating E.S.T.,  C.S.T., M.S.T.,  or P.S.T.

D.E.W.  - This space should  not be used on this
study.
                C-13

-------
               Case ID Number - An ID number for the case will
               be preprinted in this space.

               Interview Code - You will be  given a set of com-
               puterized labels that contain your initials and
               your code.  Whenever you finalize a case, you
               should affix one label in this space.  Codes C,
               PC, RB, O, SI and 2 receive your interviewer
               label.
2.4       Result Codes


          Only project specific codes are discussed in this

section.
2.4.1     Interim Codes


          All interim codes are to be recorded as numbers.  They

are used only when the outcome of the contacts do not result in

a final disposition. Interim codes are defined below:


          (1)  No Answer - Code "1" on the call record when no
               one answers the telephone when you call.  It is
               important that you let the telephone ring no more
               than six times.  This should allow sufficient
               time for someone to answer.

          (2)  First Refusal/Breakoff - Code "2" if the respon-
               dent refuses to participate or begins the inter-
               view but stops or breaks off before completing
               it.  If you receive a particularly strong first
               refusal and feel that the number should not be
               called again, note this in the Comments section
               column but do not assign the final refusal code.
               Only the supervisor may assign the final refusal
               code.

          (3)  Busy Signal - Code "3" on the call record when
               the number you call is busy.  If you get a busy
               signal, someone is usually at the number, so try
               again in 10 minutes.  All busy signals should be
               attempted twice during your shift.
                               C-14

-------
(4)   Callback -  No Appointment  - Code  "4" on the call
     record when you call  a  number but cannot complete
     the interview and the person you  talk to does not
     give you a  specific time or day to call back.
     You may use this code when you have completed
     part of the interview but  must call back to com-
     plete the remainder.  If the respondent prefers
     to be called back at an unspecific time of day
     (e.g., early a.m.), note this in  the comments.
     Note:  A code "5" (discussed next) is always
     preferable  to a Code "4"-
(5)  Callback - Appointment - Code "5"  on  the  call
     record when you call a number and  receive a spe-
     cific day and time to call back to talk to a
     respondent (e.g., Monday at 10:30  a.m., Wednesday
     at 5:00 p.m., etc.).  Remember to  convert the
     appointment to Westat time in the  right hand
     margin and designate E.D.T./E.S.T.

     Whenever a "5" is recorded, information must be
     written in the comment and callback information
     space of the call record.  You will use this code
     when the questionnaire is not complete and you
     obtain a specific time to call back to complete
     the remainder.

(6)  Initial Language Problem - This code will not  be
     used.

(7)  New Respondent Identified - Code  "7" when the
     original respondent on the RIS has been contacted
     and has referred you to a more knowledgeable
     person.  Code "7" is also used when original
     respondent is unavailable but person answering
     the telephone makes a referral to asbestos person.
     When this code is used, the name  of the new re-
     spondent must be added to the referral list on
     the RIS.  Code "7"  is used when the new respond-
     ent has been identified but the interview has not
     been completed.  This code can be used with Codes
     "4" and "5".

(8)  Problem - Code "8"  if you encounter any  situation
     that would require  the attention  of a  supervisor
     before a callback is made  and  no  other code is
     appropriate.  When  you use  this code,  provide  a
     description  of the  problem in  the comments col-
     umn.  Use this code if you  suspect a  school is
     closed but you cannot  find  confirmation.   Always
     have a supervisor initial  a  Code  "8"  before turn-
     ing in your  work.
                      C-15

-------
          (9)  Mailout Requested - Code "9" for schools who want
               another copy of the original letter or additional
               information on the study.  Put details in com-
               ments column.

         (10)  Tracing - This code will not be used.
2.4.2     Final Codes


          Final result codes are all represented by letters.  Do
not assign any final result codes, except completions, without

first discussing the file with your supervisor.  Final codes are

defined as follows:
          (C)   Complete - Code "C" on the call record when you
                have completed the entire interview for the
                school.  A complete means all pertinent ques-
                tions have been answered by an appropriate re-
                spondent .

          (PC)  Partial Response - "PC's" will only be assigned
                by supervisors unless otherwise specified.

          (RB)  Final Refusal - Code "RB" if the attempt made to
                convert an original refusal is met with a re-
                fusal.  Only a superintendent or principal can
                issue a final refusal.  A supervisor will assign
                this code.

          (I)   Ineligible - This code will not be used.

          (OA)  Out of Area - This code will not be used.

          (LP)  Language Problem - This code will not be used.

          (0)   Other - This code will be assigned by a super-
                visor.  This code is used only when none of the
                other final codes apply.  If you feel this is
                the appropriate code, specify reasons in Com-
                ments column and discuss the case with your
                supervisor.
                                 C-16

-------
          (NR)   Non-residential - This code will not be used.

          (NA)   No Answer - This code will not be used.

          (NW)   Non Working - This code will not be used.

          (NL)   Not Locatable - This code will not be used.

          (SI)   School  Closed - If it is determined that the
                school  is no longer in operation, Code Si.  If
                the telephone number is no longer a working
                number  or there is no answer at that number, use
                interim code "8" and refer to your supervisor.

          (S2)   This  code will not be used.

          (MC)   Code  "MC" will be assigned by a supervisor after
                the school has been contacted and you have not
                been  able to complete the interview after nine
                attempts.
2.5       Receiving Assignments


          All assignments will be available in files designated

by Time Zone and type of assignment.


          •     New Work - Folders containing Call Records,
                Respondent Information Sheets (RIS), and quest-
                ionnaires for respondents never called.

          •     Appointments - Folders containing Call Records,
                RIS and questionnaires for previously called
                respondents with an appointment set up.

          .     Repeat Calls - Folders for respondents called
                before, but without a specified time for calling
                again.


          The folders containing the Call Record, RIS and  the

questionnaire will each bear an ID number.  Always  check to make

sure that the identification numbers are identical.  Notify your

supervisor if there are any discrepancies.
                               C-17

-------
          A supply of Non-Interview Report Forms (NIRF's) will
be located in the receipt area; be sure to take a sufficient
supply with you before you begin interviewing.  Each time you
use a NIRF be careful to record the ID number from the Call
Record and RIS.
2.5.1     Specific Appointments

          These are schools requiring callbacks on specific days
at specific times.  You will call back at the designated time
and conduct the interview.

          When setting up appointments to call back, either:

          (1)   Set up an appointment during your shift; or
          (2)   Set up an appointment during the hours of opera-
                tion for this study, which will be Monday
                through Friday, 9:00 a.m. to 6:00 p.m.  Make
                every effort to set up an appointment within the
                following week.

          If a respondent sets a time that is not within the
hours of operation, you should explain to him/her that because
of our hours, it will not be possible to call back at that time.
If the respondent insists on a time not within our hours of
operation, you must bring the case to the attention of your
supervisor immediately.

          Since you will be calling in other time zones, use the
table below to decide when you can make appointments.  Always
record the appointment time in Westat time.
                                 C-18

-------
                        No Appointments     No Appointments
                             Before              After
Eastern
Central
Mountain
Pacific
9
8
7
6
:00
:00
:00
:00
a
a
a
a
.m.
.m.
.m.
.m.
6
5
4
3
:00
:00
:00
:00
P
P
P
P
.m.
.m .
.m.
.m.
          Below is  a  list  of  circumstances where an appointment

is the appropriate  response:
                The knowledgeable  respondent  has been  identified
                but is not available;

                The "asbestos person"  is  not  identified and  the
                superintendent/principal  is not available; or

                The "asbestos person"  is  contacted  but is not
                prepared or not available for interview at that
                moment.
2.5.2     Special Assignments


          Special assignments consist of schools that require

specialized treatment.  These assignments are:


          •     Code 2 - If the contact person is not the school
                superintendent or principal,  he or she cannot
                provide the final refusal.  If the contact per-
                son refused to complete the questionnaire, a
                callback to the principal/superintendent will be
                made.  These calls as well as recalls to the
                principal/superintendent to convert his/her
                original refusal to comply will be handled by
                specially trained interviewers.
                                 C-19

-------
                 Code  8  -  When this  code  is  used  it  indicates
                 some  question about a school's continued  exist-
                 ence. With Code "8's" directory  assistance must
                 be called to ascertain if  the telephone number
                 is still  listed.   If this  does not  clarify a
                 school's  status,  specially trained  personnel
                 will  do some tracing.
 2.6        Preparing for Interview

           Before calling a respondent for whom you  (or  another
 interviewer)  have already made a previous attempt,  review the
 Call  Record and the RIS for any notes made on  previous  tries.
 They  will  give you clues on when and how to make  your next
 attempt.
 2.7        Quality  Control

           Before you return  your work,  you shoulld  review every-
 thing  you  have  recorded.   This  editing  process  is critical to
 every  research  project.  Editing should be done in  blue  pencil.
 When you finish editing, put your initials in the top right hand
 corner of  the questionnaire. If these  initials are missing, the
 call record  and questionnaire will be returned  to you for
 editing.

           In addition to your editing process,  the  receipt con-
 trol staff will scan your  work  to make  sure everything is coded
 properly.
.2.9       Data  Retrieval

          In addition  to your editing process  the receipt con-
trol staff will scan your work.   If an error or  inconsistency is
                                 C-20

-------
found, the questionnaire will be returned to your for data
retrieval.  A Data Retrieval Form will designate the problem and
where it occurs.  You will call to resolve the problem.  Record
the resolution, make the necessary changes in the questionnaire
and record the result of the data retrieval call at the bottom
of the form.  Do not record the result of the data retrieval
call(s) on the call record.
2.9       Receiving and Returning Work

          A location within the Telephone Center will be desig-
nated as the receipt area for this study.  When you begin your
shift you will take work in the following order:

           (1)   Appointments
           (2)   Old Work
           (3)   New Work

          All assignments should be  sorted appropriately  into
the following results:

           (1)   Interim
           (2)   Finalized
           (3)   Problems
                                  C-21

-------
                     3.  SPECIAL PROCEDURES
3.1       Answering Respondents' Questions

          Although a letter has been sent to the LEA explaining
the study and outlining the information required on the-question-
naire, some respondents will have questions.  The questions may
not be phrased the same way they are written in this manual.   It
is important that you listen carefully to the respondent's question,
understand the point of the question and respond briefly  and
directly to that point.  Should you be asked a question you
cannot answer, admit that you don't know the answer.   If  the
respondent wishes, arrange for the respondent to speak with your
supervisor.  Similarly, if you are asked a question that,  if
answered, would likely lead to a refusal, refer the person  to
your supervisor rather than attempting to answer the question
yourself.

           •    Whom do you work for?   I work for Westat, a
               survey research firm,  which is under con-
               tract to the Environmental Protection Agen-
               cy.
           •    Why is the study being done?   The  Environ-
               mental Protection Agency is trying  to find
               out the effects of the Asbestos Inspection
               and Notification Rule and the extent of  the
               asbestos problem.
           •    Are all schools being contacted?  No, a
               sample of all schools will be contacted.
           •    Do I have to answer these questions?  This
               is a voluntary study, but your answers will
               provide needed information for the EPA.
           •    How long will this interview take?  If you
               have the EPA Form 7730-1 with the results of
               your inspection, it should take no more than
               15 minutes.
                                C-23

-------
               Is  this  information  confidential?  Yes.  This
               information will  be  used  for  research purposes
               only.   It is not  part  of  EPA's monitoring and
               enforcement effort.
3.2       Study Verification
          If a respondent wants to verify the  legitimacy  of  the
study she or he may use Westat's toll-free 800 number.  Whenever
the respondent expresses a wish to call,  give  him/her:

          •    Your name
          .    Your supervisor's name
          •    Westat's name
          •    The name of the survey:  EPA Asbestos in Schools
               Study.
               The toll-free number:  (800)638-8985.

          When a respondent wants to call for verification of
the study, suggest to the respondent that he/she call Westat
during your shift.  There will be a supervisor available to
answer questions during every shift.  Please remember to inform
the supervisor that someone may be calling.

           If  a respondent wishes to verify the legitimacy  of the
survey before answering,  attempt to set up an appointment  to
complete  the  questionnaire after the verification.  In  most
instances  two days  should be enough time to verify the  study-
                                C-24

-------
3.3       Potential Problems

3.3.1     Telephone Number Problems

          If the telephone number on the call record turns out
to be a non-working number, a wrong number,  or a ring-no-answer,
consult the information operator to obtain the correct number of
the LEA.  If there is no number available for the LEA, note that
in the comments column of the call record and refer the file to
your supervisor.
3.3.2     Problem Identifying the Person Responsible for Asbestos
          Inspections
          If the person answering the phone does not know who is
responsible, ask to speak to the principal or the superintendent.
The principal/superintendent is ultimately responsible for the
asbestos inspection.  If no one else is identified as more know-
ledgeable, administer the questionnaire tc him/her.
3.3.3     School Problems

          In the section on interim final results, we discussed
the situation of a school closing.  If you can determine  definitely
from the telephone call that the  school  is no longer  in operation,
note that in the comments section and Code SI in  the  final  result
column.  If you suspect that the  school  is closed, but you
cannot confirm it, Code 08 interim result and refer  it to your
supervisor.
                               C-25

-------
3.3.4     Refusal

          The principal/superintendent is the only person who
can refuse.  You may be told that the LEA did not conduct the
inspection and so has no asbestos information about the asbestos
situation.  You should explain that EPA wants to know that, too.
Every LEA is qualified to participate in the survey regardless
of what is known about asbestos in the school(s).
3.3.5     Information Not Available

          If the respondent cannot provide the information required,
ask if he or she can locate the information for a callback
appointment.  If not, take what is available.  Lack of information
is not grounds for a refusal.
3.3.6     Information Not Complete

          If the respondent can provide only part of the information
at this time, complete the interview and ask the respondent to
make note of the items still needed.  If this information can be
made available later make an appointment to callback.  Note this
in comments column.
                                C-26

-------
                            GLOSSARY
Asbestos -
Encapsulation -
Exposure (human) -
Exposure (material) -
Enclosure -
Friable -
Operations maintenance
or deferred action  -
LEA -
Removal  -
A group of naturally occurring minerals
that separate into fibers, used
commercially as fire-proof insulation.

Abatement measure in which the asbestos
material is coated with a bonding agent
called a sealant.  The sealant prevents
fiber release from the asbestos material.

The presence of people in an area where
levels of an airborne contaminant are
elevated.

The amount or fraction of material
visible.

Abatement measure in which a barrier
such as a suspended ceiling is constructed
between the asbestos material and the
building environment.

Capable of being crumbled, pulverized
or reduced to powder by hand pressure.

No abatement action is taken; the
area is  inspected periodically for
changes  in exposure potential.

Local educational agency.  This  is  an
educational unit consisting of all  the
schools  in a school district  in  the
case of  public  and parochial  schools,
and of a  single school in the  case  of
independent  schools.

This is  an abatement  measure  in  which
the friable  asbestos  containing  material
it  removed from the  building  and buried.
                               C-27

-------
3.4       Conducting the Interview


          As described earlier, the data collection you will be
performing for this study is actually not "interviewing."

Rather than reading question and recording responses, you will

record the answers the respondent has already prepared.  It is
important that you observe the following techniques for this

special form of data collection:

          1.   Question Referencing;  For the most part, it will
               not be necessary to read questions to the respon-
               dent, but refer to them by question number and
               letter.  The questionnaire copies you will be
               using are annotated and highlighted to help you
               collect information in this manner.  It will be
               your responsiblity to convey to the respondent
               the pace and order in which you will receive and
               record this information.

          2.   Verify Responses;  As necessary, verify the re-
               sponse you receive, especially numerical data and
               technical descriptions.

          3.   Interviewer Consistency Checks;  During the re-
               cording process, perform the "checks" which have
               been added to the question margins.  In the event
               that the information the respondent provides
               "fails" one of those checks, you will need to
               probe for clarification.

          4.   Answering Respondent Questions;  The respondent
               may have questions about certain questionnaire
               items, or his/her responses may indicate to you
               that he/she does not understand the intent of the
               question.  In such instances, you should take one
               of the following actions, as appropriate:

                    If the respondent's question involves a
                    definition in your Glossary or a matter of
                    questionnaire usage, you should attempt to
                    answer this question and proceed with data
                    recording.

                    If the respondent's question is of a more
                    technical nature which could affect the way
                    the remainder of the questionnaire is com-
                    pleted,  you should ask your supervisor for
                    assistance.
                                C-28

-------
   4.  QUESTION-BY-QUESTION SPECIFICATIONS FOR QUESTIONNAIRE
QUESTION 1
QUESTION 2

QUESTION 3
In this question we want to know if  this  is  an
independent school, i.e.,  only one school in the
district or a school which is part of  a school
system, either public or Catholic.   If it is part
of a school district, we want to know  the size  of
the district in number of schools.   If you are
speaking with one school in a district, get the
telephone number of the district office and END.

This question refers to schools, not buildings.

In this item, record the number of students in
the school if it is an independent school, or the
number of students  in the school system  if it is
a district office.  This number includes only the
number of regularly enrolled  students  in the
school.  It  should not  include  the students en-
rolled in night classes o-  after hours continuing
education classes.
 QUESTION 4
 Asbestos  was  not  used  in  any  school construction
 after  January 1,  1979.  If  any part of  the
 school(s) in  question  was built before  that  date,
 answer YES and continue the interview.
 QUESTION 5,
 QUESTION 6
 We are interested in schools here,  not school
 buildings.   Use oldest construction date.

 If the school/district has not done an inspection
 we are interested in any plans for a future in-
 spection.  Try to get a clear yes or no answer.
 If the answer is no, END.
                               C-29

-------
QUESTION 7
An outside agency such as the state may be re-
sponsible or the inspection program.  Obtain all
information necessary in case we want to call
that agency.
QUESTION 8
This question is looking for the date of the
first inspection of the first school in the dis-
trict.  The EPA rule was issued in 1981, but
there was a voluntary regulation before that.  We
want to know the date, to place the inspection in
the voluntary or mandatory period.
QUESTION 13
This item will identify those LEA's which actu-
ally called EPA for assistance.  If the respond-
ent doesn't know if any calls were made, record
DK.
QUESTION 14
The response to this item will be used to measure
consumer satisfaction with the technical assis-
tance program.
QUESTION 15
This item is asking which of the documents they
actually have.  It is different from the question
asking which they used.
QUESTION 16
The second question is asking which document or
documents were actually used.  If the LEA used
something other than the documents listed be sure
to record a description of the document in the
space provided.

Form 7730-1 is the document that the EPA rule
requires on file at the school or district of-
fice.  There are two reasons for asking this
question.  We want to know first if they filled
                              C-30

-------
    4.  QUESTION-BY-QUESTION SPECIFICATIONS FOR QUESTIONNAIRE
QUESTION 1
QUESTION 2

QUESTION 3
In this question we want to know if  this  is  an
independent school, i.e., only one school in the
district or a school which is part of a school
system, either public or Catholic.  If it is part
of a school district, we want to know the size  of
the district in number of schools.  If you are
speaking with one school in a district, get the
telephone number of the district office and END.

This question refers to schools, not buildings.

In this item, record the number of students in
the school if it is an independent school, or the
number of students in the school system if it is
a district office.  This number includes  only the
number of regularly enrolled students in the
school.  It should not include the students en-
rolled in night classes o~ after hours continuing
education classes.
QUESTION 4
Asbestos was not used in any school construction
after January 1, 1979.  If any part of the
school(s) in question was built before that date,
answer YES and continue the interview.
QUESTION 5
QUESTION  6
We are  interested  in schools here, not school
buildings.  Use oldest construction date.

If the  school/district has  not  done an inspection
we are  interested  in any  plans  for a  future  in-
spection.   Try to  get a clear yes or  no  answer.
If the  answer is no, END.
                               C-29

-------
QUESTION  7
An outside agency  such a;  the state may be re-
sponsible or  the inspection program.  Obtain all
information necessary in case we want to call
that  agency.
 QUESTION 8
 QUESTION  13
 This  question  is  looking  for  the date of the
 first inspection  of  the first school in the dis-
 trict.  The  EPA rule was  issued in 1981, but
 there was a  voluntary regulation before that.  We
 want  to know the  date, to place the inspection in
 the voluntary  or  mandatory period.

 This  item will identify those LEA's which actu-
 ally  called  EPA for assistance.  If the respond-
 ent doesn't  know  if any calls were made, record
 DK.
QUESTION  14
QUESTION  15
QUESTION 16
The response to this  item will be used to measure
consumer satisfaction with the technical assis-
tance program.

This item is asking which of the documents they
actually have.  It is different from the question
asking which they used.

The second question is asking which document or
documents were actually used.  If the LEA used
something other than the documents listed be sure
to record a description of the document in the
space provided.

Form 7730-1 is the document that the EPA rule
requires on file at the school or district of-
fice.  There are two reasons for asking this
question.  We want to know first if they filled
                              C-30

-------
   4.  QUESTION-BY-QUESTION SPECIFICATIONS FOI
QUESTION 1
QUESTION 2

QUESTION 3
In this question we want to know if  this  is  an
independent school, i.e.,  only one  school  in the
district or a school which is part  of  a school
system, either public or Catholic.   If it is part
of a school district, we want to know  the size  of
the district in number of schools.   If you are
speaking with one school in a district, get  the
telephone number of the district office and  END.

This question refers to schools, not buildings.

In this item, record the number of students in
the school  if it is an  independent school, or the
number of students  in the school system if it is
a district  office.  This number includes  only the
number of regularly enrolled  students in the
school.  It should  not  include  the students en-
rolled  in night  classes o^ after hours continuing
education classes.
QUESTION  4.
Asbestos was  not used  in any school construction
after  January 1, 1979.   If any part of  the
school(s)  in  question  was built before  that date,
answer YES and continue  the  interview.
 QUESTION  5.
 QUESTION 6.
 We  are interested  in schools  here,  not  school
 buildings.   Use oldest  construction date.

 If  the school/district  has not done an  inspection
 we  are interested  in any plans for a future in-
 spection.   Try to  get a clear yes or no answer.
 If  the answer is no, END.
                               C-29

-------
QUESTION 7
QUESTION  8
An outside agency such as the state may be re-
sponsible or the inspection program.  Obtain all
information necessary in case we want to call
that agency.

This question is looking for the date of the
first inspection of the first school in the dis-
trict.  The EPA rule was issued in 1981, but
there was a voluntary regulation before that.  We
want to know the date, to place the inspection in
the voluntary or mandatory period.
QUESTION 13
This item will identify those LEA's which actu-
ally called EPA for assistance.  If the respond-
ent doesn't know if any calls were made, record
DK.
QUESTION 14
The response to this item will be used to measure
consumer satisfaction with the technical assis-
tance program.
QUESTION 15
This item is asking which of the documents they
actually have.  It is different from the question
asking which they used.
QUESTION 16
The second question is asking which document or
documents were actually used.  If the LEA used
something other than the documents listed be sure
to record a description of the document in the
space provided.

Form 7730-1 is the document that the EPA rule
requires on file at the school or district of-
fice.  There are two reasons for asking this
question.  We want to know first if they filled
                              C-30

-------
               out this form and second,  we want to know if they
               had it on hand for providing detailed answers to
               the questionnaire.  If the LEA conducted its
               asbestos inspection during the voluntary period
               (from 1979 to 1982) they can used EPA form 7710-
               29 for answering this questionnaire.
QUESTION 17,
There is no spot on the 7730-1 form for date.   If
the respondent has to give an approximate date,
write APP beside the date.  If the respondent  has
no idea, write DK on line.  If the respondent  is
using 7710-29, note that with the date.
QUESTION 18
If the respondent does not have a copy of form
7730-1 or 7710-29, we want to know if he has any
documentation for his answers.  Some possible
sources might be annual reports, invoices for
abatement services, internal memos, etc.  If the
respondent is going to estimate all answers, note
that also.  All written sources should have a
date.
                In all subsequent questions, the unit of interest
                is the school.   If a school has one or more
                buildings  it  is  still counted as one school.  If
                a school has  building(s) or part of a building
                built before  1/1/79 that was in use as a school
                building any  time during the 12-month period  from
                6/82 through  5/83,  it is counted  in this question
                as one school.
                                C-31

-------
QUESTIONS 19-24.
               These questions are taken verbatim from form
               7730-1.  If the form is available the answers to
               form item 2-7 should be inserted in these items.
               If the form is not available, ask the respondent
               to use whatever materials he has available or to
               estimate.
QUESTION 25
This is the total from Q.24, broken down into the
various types of staff.  Custodians should work
inside, not outside, the building.
QUESTION  26
This question refers to the total enrollment of
an independent school containing asbestos-con-
taining materials.  In a district it is the sum
of the enrollments of each asbestos-containing
material school.
QUESTION 27
This question is not found on form 7730-1.  We
want to know how they sampled the friable mater-
ials when they found them.  The orange books and
compliance guidelines give different guidelines
for sampling.
QUESTION 28
This question is not on the form but might be
found on a report of the inspection if the re-
spondent is using other documentation.  We are
looking for the date of the first sampling of the
first building inspected.  If the date is esti-
mated, please note it on the same line as the
date.
QUESTION 29.   See above.
                                C-32

-------
QUESTION 30
The date on this item might be found on a labora-
tory invoice.  If an exact date is not available
and the respondent gives an approximate date note
it on the line of the date.
QUESTION 31,
In this item, if the inspection process is not
yet complete record the last date a sample was
sent and not on the line provided that the in-
spection is on-going.
QUESTION 32,
Record the date on the first report sent from the
laboratory.
QUESTION 33,
In this item, record the date of the last report
received.  If further reports are expected, note
that the inspection is on-going.
QUESTION 34
This  item  is  taken from form 7730-1.  If the
respondent is using another source, remind him
that  we are asking about schools not school
buildings.  If  several buildings of one school
have  asbestos containing materials, they are
counted as one.
QUESTION  35,
 Record  number  of  schools  next  to  the  time  period
 of  first  or oldest  construction.   Refers to
 schools not buildings.
QUESTION  36
 "Notice"  in this item means  that a form stating
 asbestos-containing materials were found in a
 named school is posted in the primary administra-
 tive and  custodial offices and in the faculty
 common rooms of all schools  found to have asbes-
 tos-containing materials.
                                C-33

-------
QUESTION  37.   This  is a  standard form provided by EPA.  A copy
               is included  in the appendices.

QUESTION  38.   If this date  is estimated, please note mat.

QUESTION  39.   This  item  refers to a written notice sent to the
               association  not necessarily to individual mem-
               bers.
QUESTION 40.
EPA did not provide any form for this notice.
Ask for a description of notice materials:
letter, memo, copy of inspection form, etc.
QUESTION 41.
The date in this item refers to the date of the
first notice to the first PTA if more than one
was notified.
QUESTION 42.
This item refers to some type of notice sent to
individual parents.  This was not required by the
EPA rule.
QUESTIONS 43,44.
               If a notice was sent, ask for a description and
               the date of the first notice.
The remainder of the questions in the interview deal with abate-
ment measures.  The EPA is interested in knowing what the action
the schools took if they found an asbestos problem.  The schools/
districts were not required to do anything beyond posting notice
of the problem.  However, if they chose to do something about
the problem, there are four methods of abatement from which to
choose:  (1) removal of the friable asbestos; (2) enclosure of
the material with an airtight, impact resistent barrier such as
                                C-34

-------
suspended ceiling; (3) encapsulation of the friable material  by
means by a sealant; and (4) special operations and maintenance
procedures with periodic reassessment of the buuilding.
QUESTION 48
This is a general question to separate those who
have implemented or who will implement abatement
procedures and those who will not.   If the re-
spondent indicates no abatement done or planned,
END.
QUESTION 46
Abatement is completed when all abatement mea-
sures are finished in the school.  If some mea-
sures are complete but others are on-going, count
the school in b.  If some measures are completed
but more work is scheduled, count the school in
b.  (currently being done)
QUESTION 47
In schools where more than one method is being
used, work is not counted as complete until all
methods are complete.

If removal is not used, skip the grid (Q.48 which
asks about removal).
QUESTION 48
See Q.46.   If there  is a number in Column A, ask
B and C.
QUESTION 49
Enclosure means with  an  airtight  impact  resistant
barrier.
QUESTION  50

QUESTION  51
Complete  grid  as  in Q.48.
Encapsulation  means with a sealant,
                               C-35

-------
QUl.STION 52.   Complete as in Q.50.

QUESTION 53.   Special operations and maintenance procedures
               includes steps for sealing material which is
               damaged in construction, for example.

QUESTION 55.   There are various reasons why a school or dis-
               trict may be exempted from the rule.  Find out
               why the school or district considers itself ex-
               empted .

QUESTION 56.   Include in this question any reasons not men-
               tioned above.
                              C-36

-------
     APPENDIX D
QA VISIT FIELD MANUAL

-------
                                     March 8, 1984
         QA VISIT FIELD MANUAL
  EVALUATION  OF THE ASBESTOS-IN-SCHOOLS
  IDENTIFICATION AND NOTIFICATION RULE
            Janet Greenblatt
               Task  Leader
              Westat, Inc.
         1650  Research Boulevard
       Rockville, Maryland  20850
    Subcontract No. A-3043(8149)-270
     BATTELLE COLUMBUS LABORATORIES
          Washington Operations
           2030 M Street, N. W.
        Washington,  D. C.   20036
         Contract No. 68-01-6721
        Cindy Stroup,  Task Manager
    Joseph  A.  Carra,  Project Officer
       Exposure Evaluation Division
Office of Pesticides and  Toxic Substances
  U. S. Environmental Protection Agency
         Washington,  D.  C.  20460
                   D-l

-------
        1.   INTRODUCTION TO EPA ASBESTOS-IN-SCHOOLS STUDY
1.1.       Overview of Study

          The Environmental Protection Agency,  in an effort to
protect school children from the risks associated with exposure
to airborne asbestos particles, put into operation the Asbestos-
in-Schools Identification and Notification Rule in 1982.  This
rule required all schools, public and private,  to inspect for
friable materials.   (These are materials which when dry can be
crumbled and pulverized by hand.)  The schools and/or school dis-
tricts were then  required to take samples of the friable mater-
ial, have them analyzed and if asbestos is found, post results of
the analyses for  employees and parents.

          Regardless of the findings of the inspection, an
inspection report on EPA  form  7730-1  (Appendix A) was required  to
be kept on file at  the district  or school office.

          Westat  is conducting a survey for EPA  to determine  (1)
the extent of compliance  with  the inspection and notification
rule,  (2) results of the  inspections,  and  (3)  numbers of  school
employees and pupils exposed  to  asbestos.

          As part of that study  a survey of 2,700  schools was
conducted by telephone.   A quality assurance check  in  the field
on the  responses  received by  telephone and  the basis  for  those
responses is being  conducted  on  a limited  number of  LEA's.
                             D-3

-------
             EPA ASBESTOS-IN-SCHOOLS RULE REQUIREMENTS


                              SUMMARY



Respondents:  Local Education Agency   (LEA)

Date of Rule:  May 27. 1982

Date Requirements to be Met;  June  28, 1983


1)        INSPECT all school buildings for friable materials.

2)        SAMPLE all friable materials (at least three samples
          per homogeneous sampling  area).

3)        ANALYZE bulk samples by polarized light microscopy
          (PLM)  (done by  a laboratory).

4)        NOTIFY employees and parents if asbestos is found.

          a.  Employees  (EPA 7730-3  posted in all teacher's
              lounges and custodial  areas)

          b.  Custodians  (EPA 7730-2  "Guidelines for Reducing
              Exposures...")

          c.  PTA and Parents  (no specific guidance).

5)        RECORDKEEPING must be  kept  at  LEA on EPA Form 7730-1,
          Schools also must have records on where asbestos is
          located.  If no asbestos  is found, that must be
          documented in the LEA's records.
                                 D-4

-------
1.2       Sample

          The sample of local education agencies which was called
in this survey was selected from listings of all public school
systems, archdiocesan Catholic school systems and non-Catholic
private schools.  The Westat telephone center called administra-
tive offices of public and Catholic school systems and the prin-
cipals' offices of private schools.
1.3       Overview of the QA Monitors' Tasks

          The purpose of the site visits is to verify that the
information collected during the telephone interviews corresponds
to that of the local education agency  (LEA) and, in the case of
public school districts, of the schools.  You will also be vali-
dating that the  information reported by the LEA about the schools
matches the situation at the schools.

          When making appointments for the site visits, you may
state that you are  an employee of the  EPA  if it works better to
obtain access to the schools.  You are visiting the LEA and
school only to verify the questionnaire, and the visit has no
connection to the Compliance Monitoring Inspections conducted by
the EPA.  Further,  all  information collected during the visit
will be strictly confidential.  Their  school will  not be men-
tioned in the final  report as  all information will be aggregated
and presented as national figures and  estimates.

          The QA visits are being conducted  in  10  sites.
                               D-5

-------
In each site  there will be one visit  to each of three types of
LEAs:

           1.    Public  school districts;
           2.    Private Catholic  schools;  and
           3.    Private non-Catholic schools.

Within the public  school district, a  subsample of  schools will be
visited.   (See  section on  selecting schools.)

           Summary  of Tasks to be Performed  to Complete  a Site
           Visit

           Task  1.  Advance Phone Call and Visit to LEA:

           Before visiting  a  site,  the QA  monitor will call  the
person who answered  the questionnaire for an appointment.   At
that  time  QA  monitors  should make it  clear  that this  is a Quality
Assurance  visit to verify  the information on the questionnaire
and not part  of EPA's  Compliance Monitoring Inspections.  You
should request  the contact person prepare for you  the following:

           1.    A list  of all schools  in the LEA, marking the ones
                with  asbestos-containing friable materials;
           2.    A xerox of  Form 7730-1 or  the equivalent used by
                the school; and
           3.    The information that was used to respond to  the
                questionnaire should be made available to you when
                you visit the LEA.

           At  this  time, you should tell them that  you will  want
to walk through approximately 10  percent, but no more than  10, of
their schools to verify the inspection results.  You could  focus
on the fact that this  is part of  a survey they've  already done
all the work  for and it won't take much of  their time.
                              D-6

-------
          Task 2:   Selecting Schools for  Inspection:

          The contact person at the LEA should  provide you  with a
list of the schools in their school district built before Janu-
ary 1, 1979.  You should request that they mark the schools in
which asbestos-containing friable materials were found.  Ask them
to check the schools which have boilers with a  different mark or .
color pen.  You should start at the top of the  list and select
one school which meets each of the following criteria, listed in
order of their importance.*

           1.   Choose one school with no asbestos-containing
               friable material but with a boiler.
           2.   Choose one school with asbestos-containing friable
               material with a boiler.
           3.   Choose one school with asbestos-containing friable
               material without a  boiler.

           When choosing  the schools,  try  to  pick  at least one
 high  school.  Once you  have a  high school,  select an  elementary
 school.  Next, try to include  one  middle  school.   Selecting the
 grade span is less important than  selecting  schools that meet the
 criteria listed  above.

           If you should have several schools to choose from in
 each  of  the categories shown above, ask the contact person to
 identify schools which represent a variety of  socio-economic
 areas or which  represent special  ethnic communities.   If it is
 possible,  choose a variety of schools from each type.
 *It is possible that a school district will not have schools
  which fall into each category.
                               D-7

-------
          Forms 1,  2  and 3 should  be  filled out when you visit
the LEA using  the  records from  their  files.   If they tell you
about an  inspection,  etc., but  have no  forms  that document  it,
write down  the"information but  note that  it was told to you, by
whom, and that there  was no written documentation.

          Task 3;   Walk-through of the  Schools;

          When visiting a school,  first go to the principal's
office.   Introduce yourself and describe  the  purpose of the •
visit.  Again, it  is  important  to  stress  that you are  there to
verify the  results of the survey questionnaire and  that you are
not a part  of  the  EPA's Compliance Monitoring Inspections.  The
information you collect will  be strictly  confidential  and will
not be turned  over to the EPA.  Ask the principal to let you see
the records they have on file regarding asbestos inspections.
You may have to return to the records after the building
inspection  to  verify  sampling results.  Use Form 5  as  a checklist
to verify that all proper records  are on  file.

          The  purpose of the  site  visit is to verify the data
collected during the  telephone  interview  regarding  Inspections,
Sampling  Analysis,  Notifications and  Recordkeeping.  You should
try to include the person who inspected or supervised  the inspec-
tion during your walk-through.

          Inspections

          Using the Compliance  Assistance Guidelines as a key,
you should  inspect all areas within all school buildings.   The
inspection  will include looking for and touching all suspect
friable materials.  You should  also look  behind suspended ceil-
ings and  non-permanent concealed areas.   Form 6 contains a  list
of all areas which should be included in  the  inspection.
                             D-8

-------
                    EVALUATION OF THE ASBESTOS-IN-SCHOOLS
                     IDENTIFICATION AND NOTIFICATION RULE

                              LEA SUMMARY SHEET

LEA ID: 	        INSPECTION DATE: 	
LEA NAME: 	        QA MONITOR: ____
LEA ADDRESS:  	
CONTACT NAME:
TITLE:
TELEPHONE:
SUMMARY DATA:
# Schools  in LEA                 	
f Schools  built before 1/1/79    	
# Schools  inspected              	
# Schools  with friable materials 	
# Schools  with asbestos-containing friable materials    _
Does  LEA have FORM 7710-1 on file         Yes 	     No
                                     D-9
                                                                          FORM  1

-------
                    EVALUATION OF THE ASBESTOS-IN-SCHOOLS

                     IDENTIFICATION AND NOTIFICATION  RULE
Records Required at Each LEA
                                      Records
                                      on File
Comments
1.
2.
3.
A list of all schools under
its authority indicating:
(a) which were inspprtPri _.,
(b) which contain friable
material s_
(c) which friable materials
contain asbestos
For each school in which
asbestos-containing friable
materials were found:
(a) the total area of materials
in <;quarp fppt_
(b) total number of employees
who work in the school—.
Copy of EPA Form 7730-1
(Inspections for Friable
Asbestos-Containinq Materials)

Yes







No















                                  D-10
                                                                      FORM  2

-------
ID*	Phone No.  J	J_
Name- cf Lir.	    Contact Name/Title

Address	    Interviewer 	

        	          Date
                     U.S.  ENVIRONMENTAL PROTECTION AGENCY
           ASBESTOS-IN-SCHOOLS IDENTIFICATION AND NOTIFICATION  RULE
                          SITE VISIT INTERVIEW GUIDE

               (USE SPACE AFTER QUESTIONS FOR EXPLANATORY NOTES]
 1.  What type of education agency is this?  [CIRCLE ONLY ONE CODE]

              a.  Public school district 	 01
              b.  Private school system (made up of two or           • •
                  more schools, administered by this agency	02
              c.  Private school	03
              d.  Other [SPECIFY]: 	                	04
 2. If this  is a school district or system, how many schools are administered
    or governed by this system?

              NUMBER OF SCHOOLS:	
 3. What  is  the  total  number  of  students currently enrolled in your school(s)?

               NUMBER OF  STUDENTS:              	
                                      D-ll                           Form  3

-------
 4. Has there been an  inspection program  for  friable materials  in your school
    building?   (Program may  be  conducted  by school, district, or outside
    source.)
     *THE DEFINITION OF  FRIABLE MATERIALS  IS  "ANY MATERIAL APPLIED ONTO
     CEILINGS, WALLS, STRUCTURAL MEMBERS,  PIPING, DUCTWORK, ETC., WHICH
     WHEN  DRY MAY BE CRUMBLED,  PULVERIZED OR REDUCED TO POWDER BY HAND
     PRESSURE."
               Yes  [GO ON TO QUESTION 5]	   1
               No  [SKIP  TO  QUESTION 22]	   2
 5.  When was  the  friable  material inspection program started?
                  MONTH      YEAR

    When  did  it  end  (or  is  it  expected to end?)
                  MONTH     YEAR
 6.  How many  schools  have  been  inspected  for  friable materials?   [DO NOT
     INCLUDE SCHOOLS THAT WERE BUILT AFTER DECEMBER  31,  1978]
              NUMBER OF SCHOOLS  INSPECTED:
6A. Did you include boiler insulation and pipe wrapping in your inspection?

              Yes                        	1
              No	2

6B. How many schools had this type of friable materials present? 	
                                                              Form 3
                                    D-12

-------
7. How many of the  inspected schools had friable materials present?  (IF NO
   SCHOOLS HAD FRIABLE MATERIALS PRESENT, CIRCLE "000" AND SKIP TO  Q19]

             NUMBER OF SCHOOLS
             WITH FRIABLE MATERIALS:
                                     None	000
 8.  How many schools with friable materials  have had samples analyzed for
    asbestos content?  [IF NO SCHOOLS HAVE HAD  SAMPLES ANALYZED FOR ASBESTOS,
    CIRCLE "000" AND SKIP TO  Q19]

              NUMBER OF SCHOOLS WITH
              SAMPLES ANALYZED FOR ASBESTOS:
                                       None	000
 9.  How many of the schools had asbestos-containing friable material?  [IF NO
    SCHOOLS HAD ASBESTOS-CONTAINING FRIABLE MATERIAL, CIRCLE "000"  AND SKIP TO Q19]

              NUMBER OF SCHOOLS WITH ASBESTOS-
              CONTAINING FRIABLE MATERIAL: 	
                                       None	000
                                                             Form 3
                                     D-13

-------
10.  What was the total area  in  square  feet of all  friable asbestos-containing
    materials  found  in these  schools excluding pipe wrap and boiler insulation?

               NUMBER OF  SQUARE  FEET OF ASBESTOS-
               CONTAINING FRIABLE MATERIAL FOUND: 	 sq. ft.
11. Were  these  asbestos-containing materials restricted  to pipe, wrap, boiler
    insulation  and similar materials?

              Yes	    1
              No	    2
12. Were  any  of  the  asbestos-containing materials found  on  ceilings or walls?

               Yes	1
               No	2
                                                             Form  3
                                     EHL4

-------
13. For the total amount of asbestos containing  materials  in all  schools
    in the LEA, what percentage was

              a.  on pipe wrap and boiler insulation  	%

              b.  on walls and ceilings               	%
                                                           100  %
14.  In how many of the schools where  asbestos was found was notice concerning
     the presence of asbestos provided to  the school employees?   [IF THERE ARE
     NO SCHOOLS WHERE EMPLOYEES HAVE BEEN  NOTIFIED, CIRCLE  "000" AND SKIP TO
     QUESTION 15]

               NUMBER OF SCHOOLS WHERE
               EMPLOYEES HAVE BEEN NOTIFIED:
                                        None	000

     Was notice to these employees provided using  EPA Form 7730-3 or  by some
     other method?  [CIRCLE ONLY ONE CODE]

               a.   EPA Form 7730-3	01
               b.   Other [SPECIFY]: 	
     [IF NOTICE WAS POSTED, ASK WHERE IN EACH SCHOOL]
                                                        Form 3
                                    D-15

-------
15. In how many of the  schools where  asbestos was found did you give custodians
    a copy of A Guide For Reducing Asbestos Exposure?

              NUMBER OF SCHOOLS:
                                       None	000
16.  In how many of  the  schools  where  asbestos was found was notice of the
     presence of asbestos  sent to the  parents of  the students attending the
     school  (or to the parent/teacher  organization)?   [IF THERE ARE NO SCHOOLS
     WHERE NOTICE HAS BEEN PROVIDED TO PARENTS, CIRCLE "000" AND SKIP TO QUES-
     TION 19]

              NUMBER OF SCHOOLS WHERE
              PARENTS WERE NOTIFIED:
                                       None	000
              NUMBER OF  SCHOOLS WHERE
              PTA'S WERE NOTIFIED:
                                       None	000
17.  How was notice provided  to  the parents of the students attending the
    schools?
                                                         Form  3
                                  D-16

-------
18.  What was the first date that notice was provided to the parents of the
    students attending the school(s)?

              DATE OF FIRST PARENT NOTIFICATION:           /
                                                  MONTH     YEAR
19.  What records are  retained  at  the LEA to document the findings or absence of
     asbestos-containing materials?  [LIST]
                                                         Form 3

                                    D-17

-------
 20. Do you have a copy of the 7730-1
              Yes.
              No  .
1 [OBTAIN COPY]
2
21.  For the schools  in your LEA which have asbestos, please indicate the
    abatement  activities which have been completed, are on going, or are
    planned.   [USE ADDITIONAL PAGES, IF NECESSARY]
Type of Abatement
Encapsulat ion
Enclosure
Removal
Monitoring
# Schools




Completed




ongoing




Planned




                                                        Form 3
                                  D-18

-------
22. If the LEA has not inspected for asbestos,  please discuss the reasons why
   not.
23. If  the LEA has completed all requirements but notification please indicate
    why not.
                                                            Form  3

                                   D-19

-------
LEA ID:
LEA NAME:
                    EVALUATION OF THE ASBESTOS-IN-SCHOOLS
                     IDENTIFICATION AND  NOTIFICATION  RULE

                             SCHOOL SUMMARY  SHEET
INSPECTION DATE:
QA MONITOR:
SCHOOL NAME:
SCHOOL ADDRESS:
CONTACT NAME:
TITLE:
TELEPHONE:
Was the school inspected?
Did they find friable materials?
Were samples taken?
Are lab reports on file?
Did they find asbestos-
containing friable materials?
Were teachers/custodians
notified?
Was PTA notified?
Yes







No







                                    D-20
                                                                 FORM 4

-------
                    EVALUATION OF  THE  ASr:.^TOS-IN-SCHOOL5-

                     IDENTIFICATION AND  rr-']F HATjur;  RULT
Records Required at Each School
                                      Records
                                      on File
Comments

l.Name and address of school.
2. List of all buildings associated
with the school indicating:
a. whether each building has
been inspected
b. which buildings contain
friable materials.
3. Copies of the Notice to School
Employees (7730-3).
4. For each building that contains
friable materials
a. a blueprint diagram or written
description that identifies:
- total area in square
feet of sampling area
- locations in which
samples collected
- sample ID number
- indication of whether
asbestos was present,
and an estimate of the
percent.
b. copies of all laboratory
'reports and correspondence
with labs.
5. For each school that contains
friable asbestos-containing
materials:
a. copy of the "Guide for
Reducing Asbestos Exposure"
b. copy of Guidance Documents
Part 1 and 2.
6. A statement that all role
requirements have been satisfied
signed by person responsible
for compliance.
Yes














No


























•


                                      D-21
           FORM 5

-------
          Sampling Analysis

          No samples will be taken during this inspection.  If,
however, you find friable materials, you should determine if
samples were taken and what kind of sample was taken  (scrap vs.
core).   At least three samples from locations distributed
throughout the sampling area should have been taken for each
distinct type of friable material found.  The location of each
sample was to be documented and included in the school's records.
Form 6 provides a checklist which should be marked if samples
were taken.

          The LEAs were to have analyzed all samples  using Polar-
ized Light Microscopy  (PLM).  The schools should have records of
all written correpondence with laboratories for each  sample
taken.

          Note that  if the school signed a statement  saying that
they will treat all  pipe wrap or all friable materials as
asbestos-containing, they didn't have  to sample.  If  this is the
case, indicate such  under the comments section of Form 6.

          Notification

          Form 7 provides a check list relating to notifications
to all School Employees and parent-teacher associations.  A copy
of all notifications should be on file at the school.  You should
examine all custodial areas and all administrative and faculty
common rooms to see  if notices have been posted and are readable.
Indicate how many had notices posted (3 of 5, 2 of 2, etc.).
Note any unusual circumstances in the  comments section.
                              D-22

-------
LEA:
SCHOOL:
BUILDING:
                        EVALUATION OF  ASBESTOS-IN-SCHOOL IDENTIFICATION AND NOTIFICATION RJIE
                                        CHECKLIST FOR WALK-THROUGH OF SCHOOLS


1. Boiler Room
2. Machinery/Storage
Room
3. Other Pipe
Wrapping (i.e.,
in classrooms)
4. Sprayed/Troweled
material above
dropped ceilings
5. Music/Band rooms
6. Woodshop/Metal shop
7. Auditorium
8. Gymnasium
9. Swimming pool
10. Classrooms
11. Bathrooms
12. Administrative areas
13. Cafeteria/Kitchen
14. Hallways
15. Encapsulated
materials
16. Removed Materials
SCHOOL RECORDS

Inspected
















Friable
Materials
Yes No
















Samples
Taken
es
















No
















#
















Lab
Reports
on File
Yes
















0
















WALK-THROUGH

nspected
















Friable
aterials
Yes

No
















Observed
here Samples
Taken
Yes
















No


































Comments*
















    Use  additional sheets for comments as needed.
                                                            D-23
                                                                                                         Form 6

-------
 EVALUATION OF ASBESTOS-IN-SCHOOLS
IDENTIFICATION AND  NOTIFICATION RULE
         NOTIFICATION  TABLE
1.
2.
3.
4.
Custodians
a. Were they informed?
b. How were they informed?

c. Did they receive a copy of EPA Form 7730-2
"A Guide For Reducing Asbestos Exposures"?
d. Were notices posted in custodial areas?
Faculty/Administration
a. Were they informed?
b. How were they informed?

d. Are notices posted in faculty lounges?
Administrative areas?
Faculty common rooms?
e. Did they use Form 7730-3?
PTA
a. Were they informed?
b. How were they informed?

Does the school have copies of all notification
letters, forms, etc. on file?
Yes










No










                                               Form 7
             D-24

-------
          A copy of the "Guide for Reducing Asbestos Exposure"
(EPA Form 7730-2) was to be distributed to all custodial  or main-
tenance employees.  You should ask the custodian if such  notice
was received.

          Recordkeeping

          Form 5 provides a list of all forms you should  expect
to find at the school.  You should check to see that all-EPA
forms, or an equivalent form, are on file.

          The Compliance Assistance Guideline provides a detailed
list of all  information required  to be on  file.

          Task 3;  Comments;

          Extra  sheets of paper will  be provided for comments.
Please  include in  the comments section your  impressions  of  the
LEA and schools  regarding compliance  to the  Rule.   For each
school/building  that  you walk-through, provide  a written report
including as much information as  possible.  Take notes as you  go.
Do not  be distracted  by LEA officials who may attempt  to let you
see only what  they want you to see.   Included with this  package
are examples of  two  inspection reports prepared by Wolfgang
Bradner showing  the  type of comments  we would like from  you.
                             D-25

-------
1.4       Request for Final Report

          Tell each superintendent and principal that you will be
happy to arrange for their LEA to receive a copy of the final.
report.   Mention that the name of their school will not be
mentioned in the report as all data is presented as aggregated
national figures.  If they wish, they may fill out Form 8 to
receive a copy of the final report.
                              D-26

-------
                    EVALUATION OF THE ASBESTOS-IN-SCHOOLS

                     IDENTIFICATION AND  NOTIFICATION RULE



                           REQUEST FOR FINAL REPORT
LEA SCHOOL NAME:
LEA SCHOOL ADDRESS:
REQUESTOR'S NAME:
REQUESTOR'S TELEPHONE:
                                                                     Form 8
                                     D-27

-------
 QA VISIT FIELD MANUAL
      APPENDIX A
EPA ASBESTOS-IN-SCHOOLS
    OFFICIAL  FORMS
           D-29

-------
                          "7730-1
                     INSPECTIONS fOR FRIABLE ASSESTOfr-OONTAJNINQ MATERIALS
                                                        agency:
                                                         cou*mr
                                                         z*coot
        fill in the Ufa
                    l«n*a
Miatn&the schools
  under the authority of this too* adoption agency:
2 The number of schools which hrw been impacted for f riabtt
  Tirte 40 of the'Code of Federal Regulations.
                                                                     with {763.105 of
3 The number of schools where friable materials ere preMnt.
If the •ntwer to question 3 it none, diireojrd questions 4-7 and go on to tnt ten
M m the I odowing information atxxrt the tchoolt •numarattd in numlmi 3:
                                                                            . OthtrwriM. '
4  The number of schools in which all friable materials have been mnjAmi and unrtyMd in
   with (§783.107 and 763.108 of Title4Oof the Cod* of fwJtrri ftafolatiom.
S. The number of schools with friable mattrial(t) that oontain(i) 4
   If the answer to question 5 is none, disregard questions 6-7 aodjoon «o the eartifkation. Othan*ba.fM in
   the «oHowin| frnWnal'mi about the schoots enumerated in question C.
6. The «Malaraa« square faat Of aN frii
                                  stettc
                        rMs found IN 1
7. The tool number of school aipployeeiwrio regularly worit in artioob wtiara IriaMa
CERTIFICATION: Plaas* read and sign below the following statement:
I  hereby eartify  that this local education agency has
                            rth the EPA
                                                                             40 CFR 7*3.100
                                                                                                      '7C3.117,
   "Asfaattoc-Containing Materials in Schools Identification and Notftatton.- and feat the knfonMtion on this form k. to the best of
   my knowledge, true and complete.  .                                                                             v
8ICNATWMC
                                                                  PfUPfTCD
TVP
   Additional forms can be obtained by calling 800-4244066 (664-1404 in the Washington.DC araa).
    PC** ma-1 m-nt
                                                   D-31

-------
                           ..'. Vol. <7. No. 103 / Thursday. May 27,1962 /  Rules and Regulations	23371
773O-3  NCmcL 10 SCHOOL EMPLOYEES


 In accordance with EPA regulation*, thb school hM Own Iropected for friable (eerily crumbled) nwurtali which
 contain HtMttoi. Friabto Mbtnot^ontalnlng mrarM may oauw hMhh probtomc.
                      Frwbl« Mbmot-contiining nutartel is present in
                    INm* of School)
A record of the inspection, a diagram of the lootion(t) of friabla asbntoxontaining mattrialt. and a copy of
relevant EPA regulations are available in
                    BuUdlne
For further information, interested person* should call 800-4244005 (664-1404 in the Washington. DC are*).
                   Signed:
                                                D-32

-------
                                     .s. EsviRCKMi'.-i^ EOC-EC-.C-. «.:• E -.,. •
                                         ASBESTOS SURVEY REPORT
                                          (Survt\ c: Activtiei  .': Cor.:rc
                                     stos—Conn mine Vticrie/'s ir. Sr/ioc. £•_•. ::.-n;
                                                                                                   .'.-r: .-1,-pr-vrc'
                                                                                                      Ac. J5S-R-Olt-
                                                        GENERAL
 Thii information it collected under the ourherity of the 1o»ic Subttonc*i Centre* Act, i.ciioni 6 ond 8. EPA is compiling infonnsuon
on the progress of State and local programs to'control exposure to ssbestos-conuimnK mstensls in »choo4i. Thi« (onn should be used
 o periodically report Information concern!n« tbe asbestos control activities m your school di»trict. To obtain more form*, call thi>
 oil-free number  800-424-9065 or la the Wfahington, D.C. area, call 554-1404.  Data collected in this *urvey will be aubject to tbe
proviaiona of the Freedom of Information Act f 5 l/.S.C. 552).
                                                  MAILING INSTRUCTIONS
MAIL ONE COPY TO: The EPA Regional Asbestos Coordinator
                     for your Region. (For names and addresses
                     see reverse side.)
                                                              ALSO, please mail a copy to your official State aabeatoa program
                                                              contact (lor name ana* iddnti, ca/1 thit toll—free number: 400—
                                                              424-9065 or if In the Wuhington, D.C. area, CMII 554-1404).
                                                     IDENTIFICATION
1. SCHOOL DISTRICT INFORMATION
                                           2. PERSON TO CONTACT REGARDING THIS REPORT
                                           Br.rlt
                                                    -iQi
                                                        TI7Lg.
                                                        *imt n r wj.r.r» ••,11 ..i.ra
                                                    H
                                                                                         PATEfmo.. tmr.
                                                                                         ': »•
                                                   SPECIFIC QUESTIONS
3. Haa the school diatrict submitted an EPA Asbestoa Survey
   Report before?
           ) YES
                         n NO
                                          UNKNOWN
                                                               4. How many achools in the diatrict were built or renovated
                                                                  between 1945 and 1978?

                                                               NUMBER OVTCMOOUS                     ~
 5.  As of      fmo./VT.). how many schools in the diatrict
    have been mi
    containing
inspected for the presence of friable asbestos—
                        I
                                                                6. Howmany schools had bulk samples analysed for aabeatoa with
                                                                   the EPA recommended technique of Polarized Light Microscopy?!
                                                               NUMBER 6~FTcBoots        ""                               I
 7.  Aa of.
                  .fmo./yr. ot
    unmlymim) for how many schools
    in the diatrict waa friable ma-
    terial analysed aa containing
    aabeatoa?
                      8. (•) In how many achoola waa friable asbestos—containing material determined to present
                            an espoaure problem?
                         (b) Approximately how many aquare feet of thia material were found?
                         (c) Estimate the number of children per school year expoaed to thia material.  (Multiply
                            (he percent of children expoaed by (he total number of enroHff »Indents, e.g.. An
                            expoaure proafera in fire claaarootna may intro/re 157* of the tola/ population of 700
                            student*; 15%. x 700 equaJa 705 a(uden(a expoaed.)
                         (d) Have the names of the children been recorded and retained for future reference?
                                   a. NO. OF SCHOOLS
                                                         b. SQUARE FEET
                                                                              1
                                                                               C. NO. OF CHILDREN
                                                                                      1
        d. NAMES RECORDED

              YES
                                                                                                                         .
 Questions 9 throuth 11 refer to the friable asbestos—containing material that presents an exposure proh/em in Question ff.
 9. (a) Approximately how many aquare feet of this material have
       been or will be removed?
    (b) What ia the estimated total coat of removal?
 a. SQUARE FEET
                              T
                                 COST:  S
                                                                10.  (a) Approximately how many aquare feet of this material have
                                                                       been or will be encapsulated?
                                                                    (b) What is the estimated total cost of encapsulation?
                                                               a. SQUARE FEET
                                                                                               COST:  S
11.  (a) Approximately how many aquare feet of thia material have
        been or will be enclosed?
     (o) What ia the estimated total coat of enclosure'
                                                                12. (a) For approximately how many aqnare feet of asbestos-
                                                                       containing material waa action deterred?
                                                                    (b) Will this material be inspected periodically to de-
                                                                       termine if an expoaure problem exists?
  a. SQUARE FEET
                              T
                                                               a.SQUARE FEET
                                 COST:  S
                                                                               T
b. PERIODIC INSPECTION

        n YES  D NO
 13.  What ia the aource of funding for the asbestos control
     activities in your diatrict?
                                                                14.  When did for will) the aabeatos control activiua
                                                                    diatrict begin and end?
 FUNDING SOURCE
                                                               BEGINNING YEAR
                                                                                            T
                                                                                              ENDING YEAR
                                                          COMMENTS
 EPA Form 7710-Jf (3-79)
                                                                                                                         31
                                                         D-33

-------
                        INSPECTIONS FOR FRIABLE ASBESTOS-CONTAINING MATERIALS
 1  Please provide the following information about the local education agency:

   VME OF AGENCY
 cn
                                                               COUNTY
 STATE
                                                               :IP CODE
    Please fill in the following information about the schools
    under the authority of this local education agency:	
 2.  The number of schools which have been inspected for friable materials in accordance with §763.105 of
    Title 40 of the Code of Federal Regulations.
 3.  The number of schools where friable materials are present.
    If the answer to question 3 is none, disregard questions 4 — 7 and go on to the certification. Otherwise,
    fill in the following information about the schools enumerated in question 3:
 4. The number of schools in which all friable materials have been sampled and analyzed in accordance
    with § §763.107 and 763.109 of Title 40 of the Code of Federal Regulations.
 5.  The number of schools with friable material(s) that contain(s) asbestos.
    If the answer to question 5 is none, disregard questions 6-7 and go on to the certification. Otherwise, fill in
    the following information about the schools enumerated in question 5.
 6.  The total area in square feet of all friable asbestos-containing materials found in these schools.
 7. The total number of school employees who regularly work in schools where friable asbestos-
   containing materials are present.
 CERTIFICATION: Please read and sign below the following statement:

    I hereby  certify that this  local education  agency has complied with the EPA regulation 40 CFR 763.100 through 763.117.
    "Asbestos-Containing Materials in Schools Identification and Notification." and that the information on this form is, to the best of
    my knowledge, true and complete.
 SIGNATURE
                                                               TYPED OR PRINTED NAME
TYPED OR PRINTED TITLE
                                                               DATE
   Additional forms can be obtained by calling 800-424-9065 (554-1404 in the Washington. DC area).
EPA Form 7730 1 (&-82)
D-34

-------
                                A GUIDE FOR REDUCING ASBESTOS EXPOSURE
                                                        PURPOSE
Your school building  contains  materials which contain as-
bestos and may release fibers into the air. Breathing asbestos
         fibers is dangerous. This fact sheet tells how to reduce expo-
         sure   to   asbestos   fibers.   Please   read   it   carefully.
                                       PROTECTING YOURSELF FROM ASBESTOS
Some of the friable building materials in your school contain
asbestos. Friable asbestos-containing materials crumble easily
and release fibers into the air. Breathing these fibers may cause
cancer and other diseases. The more asbestos you breathe, the
greater your chances are of getting disease. You can take pre-
cautions that will reduce or eliminate the risk of being exposed
to asbestos.

Find  out from your supervisor where these friable asbestos-
containing materials are in  your building. Do not touch or
disturb them  unless  you have  to. If  you must handle an
asbestos-containing material,  first lightly spray it with water.
(EPA recommends using water which  contains wetting agents,
if  they are available.) Wet asbestos-containing materials will
not release as many fibers.

Even  if friable asbestos-containing materials are not disturbed,
they may release asbestos fibers, which will fall slowly to the
floor.  If you are cleaning in areas which contain these mate-
rials, do not use a broom: it will stir the fibers into the air. Do
not use a  vacuum cleaner unless it is equipped with a High
Efficiency Paniculate Absolute filter. The fibers are so small
         they can pass through an ordinary vacuum cleaner and out
         into the room.

         When cleaning  in  areas which contain friable asbestos-con-
         taining materials, use dampened mops and dustcloths. Damp-
         ened mops and  dustcloths will hold the fibers much better
         than dry mops and dustcloths, and will reduce the number of
         fibers put back into the air.  It is best to use mops with dis-
         posable heads and to  throw away the mop head after use.
         Otherwise fibers will be released as the mop dries. Use either
         lightly dampened mops or cloths or a vacuum with a  High
         Efficiency Paniculate Absolute filter to clean areas where wet
         mopping cannot be used  (such  as carpeting  or  hardwood
         floors).

         Clean tables and chairs in the area with damp cloths. Do not
         dust them with brushes or with dry cloths, and do not vacuum
         them.

         After you use the  mop heads and cloths, put them in a plastic
         bag while they are still wet. Dislodged materials should also be
         placed in plastic bags for disposal.
                                      A LIST OF IMPORTANT POINTS TO REMEMBER
 1. Do not handle or disturb friable asbestos containing mate-
   rials unless necessary.

 2. If you must handle asbestos-containing materials, wet them
   first

 3. If you must disturb asbestos (for example, to repair a light),
   see your supervisor before starting work. Then;

   a. Place a plastic dropcloth below the work area.

   b. Spray  asbestos-containing  material with  water before
      you disturb it.

   c. Make sure that only those persons who are necessary for
      the job are  in the area.

   d/Put all the  asbestos you remove into a heavy plastic bag.
      Seal the bag and  discard  it.

   e. After the job, clean all  the ladders and tools you used
      with a wet cloth.
            f. Roll up the dropcloth carefully and put it  in a plastic
               bag. Discard the bag.

            g. Clean the floor below the worK area with a wet mop.

            h. Put the mop head and the cloth used to clean the ladders
               in a plastic bag while they are still wet, seal the bag, and
               discard it.

          4. If you must disturb or remove large sections of asbestos-
            containing material, see your supervisor before you begin.
            The National Institute for Occupational Safety and Health
            recommends that a  respirator approved for toxic dusts be
            worn during such work.

          You should make arrangements to turn off the school's venti-
          lation system if you are disturbing or removing large sections
          of asbestos-containing material. The ventilation system should
          remain off  until the work is completed and the area has been
          cleaned.
EPA Form 7730-2 (6-82)
D-35

-------
                   NOTICE  TO  SCHOOL EMPLOYEES
In accordance with EPA regulations, this school has been inspected for friable (easily crumbled) materials which
contain asbestos. Friable asbestos-containing material may cause health problems.
                          Friable asbestos-containing material is present in
                       (Name of School)
 A record of the inspection, a diagram of the location(s) of friable asbestos-containing materials, and a copy of
 relevant EPA regulations are available in
                       Building
                                                 Room
 For further information, interested persons should call 800-424-9065 (554-1404 in the Washington, DC area).
                       Signed:
                       (Name)
                       (Title)
                       Date
EPA Form 7730-3 (6-82)
                                                D-36
                                                                   U.S. GOVERNMENT PRINTING OFFICE :  1982 0 - 376-899

-------
                 REGIONAL ASBESTOS COORDINATORS
Mr. Paul Heffernan
EPA Region I
Asbestos Coordinator
Air & Hazardous Materials Div,
JFK Federal Building
Boston, MA  02203
(617) 223-0585
Mr. Arnold Freiberger
EPA Region II
Asbestos Coordinator
Woodbridge Avenue
Edison, NJ  08837
(201) 321-6668
Ms. Pauline Levin
EPA Region III (3SA-00)
Asbestos Coordinator
Curtis Building
Sixth & Walnut Street
Philadelphia, PA  19106
(215) 597-9859
      597-8683
Mr. Jim Littel
EPA, Region IV
Asbestos Coordinator
345 Courtland Street
Atlanta, GA  30365
(404) 881-3864
FTS   257-3864
Dr. Tony Restaino
EPA Region V  (5HT-16)
Asbestos Coordinator
230 S. Dearborn Street
16th Floor
Chicago, IL   60604
(312) 886-6003
Mr. John West
EPA, Region VI
Asbestos Coordinator
Interfirst Two Building
1219 Elm Street
Dallas, TX  75270
(214) 767-2734
FTS   729-2734

Mr. Wolfgang Brandner
EPA, Region VII
Asbestos Coordinator
324 East 11 Street
Room 1411
Kansas City, MO  64106
(816) 374-3036
FTS   758-3036

Mr. Steve Farrow
EPA, Region VIII (8AW-TS)
Asbestos Coordinator
Toxic Substances Branch
1860 Lincoln Street
Denver, CO  80295
(303)  844-3926
FTS    327-3926

Ms.  JoAnn  Semones
EPA, Region  IX
Asbestos Coordinator
215  Fremont  Street
San  Francisco,  CA   94105
 (415)  974-8123
FTS    556-4606

Mr.  Walt  Jaspers
EPA, Region  X
Asbestos  Coordinator
 1200 Sixth Avenue
 Seattle,  WA   98101
 (206)  442-2632
FOR COPIES OF GUIDANCE DOCUMENTS AND RULE:   800-424-9065
FOR A VARIETY OF ASBESTOS-RELATED
TECHNICAL ASSISTANCE AND INFORMATION:

TO RESPOND TO QUESTIONS ON  THE
ASBESTOS-IN-SCHOOLS IDENTIFICATION
AND NOTIFICATION RULE  CALL  DAVE MAYER
      800-334-8571  X6738
      202-382-3949
                               D-37

-------
50272 -101
 REPORT DOCUMENTATION  i._REPORT NO.
       PAGE
                                                2.
                                                              3. Recipient's Accession No
4. Title end Subtitle
      Evaluation  of the Asbestos-ln-Schools
      Identification and Notification  Rule
 7. Author(s)
      Janet Greenblatt
                                                              5. Report Date
                                                               June 15, 1984

                                                             fe	
                                                              8. Performing Organization Rept. No.
                                                                G8149-1501
 9. Performing Organization Name and Address
      Battelle  Laboratories,  505 King  Avenue, Columbus
                                              Ohio 43201
      Westat  Inc., 1650 Research Boulevard, Rockville,
                                            Maryland  20850
                                                             [ 10. Project/Task/Work Unit No.

                                                                  Task 15
                                                             | 11. Contrjct(C) or Graot(G) No.

                                                              (c>A-3043(8149)-270

                                                              (G)
12. Sponsoring Organization Name and Address

     Exposure Evaluation Division
     Office  of Toxic  Substances
     Environmental  Protection Agency
                  n. C.	2QAZQ	
                                                               13. Type of Report & Period Covered
                                                                 Peer Review
                                                                 March  '83-May '84
                                                               14.
 15. Supplementary Notes
 16. Abstract (Limit: 200 words)
   The Asbestos-in-Schools  Identification and Notification Rule effective
   June 28, 1982, required all public  and  private local education agencies
   (LEAs) to (1) inspect for friable materials;  (2) sample and analyze these
   materials when found;  (3)  post notice  of  inspection results and notify
   employees and parents  in schools with asbestos-containing  friable  ma-
   terials  (ACFM) ;  and (4) maintain records of the findings at  the LEAs  and
   schools.  A stratified systematic sample of 1,800 public and 800 private
   LEAs was randomly selected proportionate to the square  root of enroll-
   ment.  A telephone survey  found  that 83 percent of  the  LEAs have begun
   or  completed  inspections  and  94 percent  of all  schools  have been
   inspected.  Of the  schools inspected, 35 percent found ACFM. Almost  all
   LEAs with ACFM have abatement programs (93%) , about one-third of which
   (31%) are operations/maintenance only.  Only 9 percent  of the LEAs were
   in compliance with  the  rule by June 28,  1983, the rule's compliance date;
   and 11 percent were  by January 1984,  the date of the  survey.  Record-
   keeping and  notification were the major problem areas  of noncompliance.
   QA site visits were made to 38 LEAs and 94 schools within these LEAs were
   inspected.    The  LEA  data  collected   during  the  site visits  agreed
   substantially with the telephone survey  data.
 17. Document Analysis  a. Descriptors
   b. Identifiers/Open-ended Terms
       Asbestos
       Compliance Monitoring
   c. COSATI Field/Group
 IB. Availability Statement
                                                  19. Security Class (This Report)
                                                                        21. No. of Pages

                                                                           235
                                                  20. Security Class (This Page)
                                                                         22. Price
(See ANSI-Z39.18)
                                    See instructions on Reverse
                                                                       OPTIONAL FORM 272 (4-77)
                                                                       '.Formerly NTIS-35)
                                                                       r>«r>artment of Commerce

-------