TECHNICAL SUPPORT DOCUMENT  FOR  REGULATORY
           ACTION [TSCA: SECTION  6(a)]  AGAINST
FRIABLE ASBESTOS-CONTAINING MATERIALS  IN  SCHOOL BUILDINGS
                      Seotember 1980
             Office of Testing and Evaluation
        Office of  Pesticides  and  Toxic  Substances
           U.S.  Environmental Protection Agency
                   Washington/  DC   20460

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t '
     When promulgating a rule concerning  a chemical

     substance or mixture under the Toxic Substances

     Control Act (TSCA), the Administrator is  required

     to publish a statement on the effects of  that

     substance on health and the -magnitude of  exposure

     of human beings to that substance.  This  document
                                                *
     is a preliminary statement of these  findings in

     support of the rule "Friable Asbestos-Containing

     Materials in Schools Proposed Identification and

     Notification."  It is a draft and is released for

     comment on its technical merit and policy

     implication.

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                             CONTENTS



  I.   INTRODUCTION 	1



 II.   USE AND PRESENCE OF FRIABLE ASBESTOS-CONTAINING



      MATERIALS IN SCHOOLS  	2



       A.  Uses of Friable  Asbestos-Containing  Materials  in



           Building Construction  	3



       B.  Presence of Friable Asbestos-Containing



           Materials in Schools	6



       C.  Number of Persons Exposed  to  Asbestos  in



           Schools 	12



       D.  Remaining Years  of Use for School  Buildings



           	.14



III.   ASSESSMENT OF RISK FROM ASBESTOS IN  SCHOOLS 	15



       A.  Introduction	15



       B.  Hazard Assessment 	17



            1.  Introduction	17



            2.  Health Hazards of Asbestos  Exposure  	19



                 a.  Lung Cancer  	19



                 b.  Pleural and Peritoneal Mesothelioma  ...22



                 c.  Other  Cancers  	30



                 d.  Asbestosis	32



                 e.  Summary and Conclusions  	43



            3.  Factors that Modify the  Risk  of Asbestos-



                Induced Disease 	44



                 a.  Smoking	44



                 b.  Age 	51



                 c.  Fiber  Size and Type .	53
                               -i-

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                d.  Summary and Conclusions  	55



      C.   Exposure Assessment 	56



           1.   Asbestos Dispersion Mechanisms  	58



           2.   Estimate of Prevalent Exposures 	59



           3.   Description of Peak Exposures  	69



      D.   Risk Assessment	70



           1.   Procedure for Estimating Risks  of



               Premature Death	70



                a.  Outline of the Risk Estimation



                    Procedure		70



                b.  Selection of the Underlying Study	72



                c.  Asbestos Exposure Among  the Insulation



                    Workers 	74



                d.  Increased Risk Among the  Asbestos



                    Insulation Workers  	79



                e.  Asbestos Exposure in Schools  	82



                f.  Selection of the Extrapolation



                    Method	. . .	84



           2.   Risk Estimates for School Building



               Occupants 	89



IV.   IDENTIFICATION OF FRIABLE ASBESTOS-CONTAINING



     MATERIALS IN SCHOOLS 	94



      A.   Introduction 	94



      B.   Sampling 	95



      C.   Analysis 	96



 V.   CONTROL OF ASBESTOS IN SCHOOLS 	98



VI.   REFERENCES 	103
                              -11-

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I.  INTRODUCTION
    Exposure to asbestos  fibers  can  lead  to  numerous  serious  and
irreversible diseases.  Certain  building  materials  in common  use
can release asbestos  fibers  into the  atmosphere.   In  particular,
friable asbestos-containing  materials  have been  found to  release
fibers in concentrations  which,  if  inhaled,  are  sufficient to
increase the risk of  developing  such  diseases.   Some  3,000,000
students and 250,000  teachers and other staff  regularly use
public school buildings which contain  friable  asbestos-containing
materials and which may contain  such  levels  of contamination.
    The Agency has determined that exposure  to asbestos in school
buildings poses a significant hazard  to public health.   This
determination is based on the following considerations:

    (1)  the extent of use of friable  asbestos-containing
         materials in schools,
    (2)  the number of diseases  which  epidemiologic  studies have
         shown to be  caused  by exposure to asbestos,
    (3)  the evidence of  elevated airborne concentrations of
         asbestos in  schools and other buildings  where  friable
         asbestos-containing materials are present,  and
    (4)  an estimate  of the  degree of  risk posed  by  these
         elevated concentrations.

    In addition, information on  the  identification of friable
asbestos-containing materials and control measures that can be
taken to reduce the release  of and consequent  exposure  to
asbestos fibers are presented.
                               -1-

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    A.   Uses of Friable Asbestos-Containing  Materials  in
         Building Construction
    Asbestos is used  in buildings  as  a  spray- or  trowel-applied
coating to building surfaces to retard  fire,  deaden  sound,  or
decorate; it is also  used  in lagging  on boilers and  pipes,  and  in
cement products, plasters, vinyl tile,  and miscellaneous  products
such as lab table tops and ventilation  hoods.  Asbestos-
containing sprayed- or trowelled-on materials were first  used in
the U.S. in 1935, when the material was found to  be  suitable  for
acoustical purposes and for decorative  finishes in public
buildings.  In the 1950's, one of  the most significant  advances
in the construction industry was the  replacement  of  concrete  with
asbestos to protect structural steel  against  fire.   Structural
steel must be insulated to ensure  that  it does not become soft,
bend, and collaspe during  a fire.  The  replacement of concrete by
asbestos greatly reduced the weight and bulk  of large buildings
(Sawyer 1979).
    The amount of asbestos in the  mixtures used in these
applications varies widely.  From  1%  to 80% or more  of  asbestos,
usually chrysotile or amosite or a mixture of the two,  were
combined with other fibers (including cellulose,  mineral  wool, or
fiberglass), and cement or resinous binders.   Table  1 shows the
results of analyses of a variety of sprayed-'  or trowelled-on
asbestos samples from schools in the  U.S.  (Battelle  1980).
Nicholson et al. (1978a) reported  similar concentrations  for
schools in New Jersey.  (Paint present  in  these samples may have
been applied at the time of spraying  or during subsequent
maintenance operations.)
                               -3-

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Table 1. Site Sample Results from Bane Me Bulk Sample
                  (Continued)
Sample No.
15-01A

01B

QIC

01D

03A

038

16-01B

02A

02B

02C

020

03A


B

04A

048

17-01A


018


02A


028



Location
Hall
water damage
Hall
water damage
Hall

Hall





Hall

Hall
wet damage
Hall
wet damage
Hail

Hall

Music room


Music room

Caf Blot la

Cafeteria

Classroom


Classroom


Art room


Art room



Chrysolite Amosite
(%) (%)
90

80

50

40

20

5 40

5

0

5

10

10

10


10

5

5

0


0


0


0



Anthophyllite Other fibers
(%)
2% min.
wool


30% min.
wool
30% min.
wool
20% min.
wool
30% min.
wool


20% min.
wool




50% fiber-
glass
10% fiber-
glass

10% fiber-
glass
10% fiber-
glass
10% fiber-
glass













Nonfiber materials
5% calcite
3% opaque
10% gypsum, 5% glass.
5% opaque
10% gypsum, 5% glass.
5% opaque
20% gypsum
5% glass, 5% opaque
40% gypsum.
10% glass, 10% opaque
20% calcite
5% glass, opaque
50% opaque, 50% calcite.
40% opaque, 5% cotton
20% calcite
60% opaque
45% calcite,
50% opaque
50% calcite.
40% opaque
30% calcite.
50% opaque
25% calcite.
5% opaque,
5% cotton
40%calcrtB,
40% opaque
35% calcite,
10% opaque
35% calcite.
60% opaque
60% wood.
20% gypsum
10% opaque
60% wood.
20% gypsum
20% opaque
70% wood
20% gypsum,
10% opaque
60% wood.
20% gypsum.
20% opaque.
50% wood
Sample appearance
Fibrous





Fibrous



Fibrous



Granular



Granular

Chunky-
granular
Granular




Granular



Fibrous





Fibrous


Fibrous



                          -4-

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    In the U.S., two principal methods  have  been used to apply
formulations of mineral  fibers,  including  asbestos,  for building
construction applications.   In one  method, dry fibrous material
was pumped through a 2-  to 4-in.  hose.   The  hose conveyed the dry
material to a nozzle at  the  actual  site of application.  As the
dry material left the nozzle, it  passed through the  focus of a
ring of fine water jets.  The mixing  took  place at the focal
point, approximately 4 to 8  in.  from  the end of the  nozzle (Reitz
1972).  The mixture was  directed  against the building surface
from a distance of about 2 ft, and  depths  of application ranged
up to 3 in.  The material applied by  this  method often was
fibrous in nature, rather than compact  and granular.   A coat of
resin or paint frequently was incorporated to increase the
cohesiveness of the final coating.
    In the second process, the material was  premixed  with water
in a hopper, and the resulting slurry was  pumped to  a nozzle and
sprayed on the surface (Reitze et al. 1972).   This usually
resulted in a less fibrous,  more  compact material being
applied.  The depth of application  generally did not  exceed 1 in.
(Barnes 1976).
    Material that was trowelled-on  had  essentially the same
composition as the sprayed-on materials, and  it too was premixed
with water.  This material probably formed the densest, hardest
coating of the three types.  The  depth'of  application usually did
not exceed a fraction of an  inch.
    Asbestos also was applied to  pipes  and boilers in several
ways.  In some instances, a  wet  slurry  similar to the above
                               -5-

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material was sprayed or  trowelled  on.   In  others,  a  blanket



consisting principally of woven asbestos  fibers  was  wrapped



around the pipe and secured with plaster,  tape,  or a sprayed-on



binder.



    In 1973, EPA banned  the use of spray-applied asbestos-



containing material as insulation  in buildings  to  prevent



widespread contamination of the environment  during spraying (EPA



1973).  EPA amended this regulation in  1975  to  include  asbestos-



containing pipe lagging, regardless of  the method  of application



(EPA 1975).  EPA extended this ban in 1978,  ban  to all  uses of



sprayed-on asbestos (EPA 1978).  EPA also  regulated  the methods



of removing asbestos from a building and disposing of the wastes



generated by removal (EPA 1973).   These regulations  apply  to



"friable asbestos material," which is defined as material  "that



contains more than 1 percent asbestos by weight  and  that can be



crumbled, pulverized, or reduced to powder,  when dry, by hand



pressure." For the purposes of regulating  the spraying  process,



EPA defined "asbestos-containing"  as containing  >1%  asbestos in



bulk.  Thus, the regulation does not preclude the  use of



materials contaminated by small amounts of asbestos  (_<_!% in bulk)



in spray formulations.



    B.   Presence of Friable Asbestos-Containing Materials  in



         Schools



    EPA has gathered information on the presence of  friable



asbestos-containing materials in public schools  by surveying



school districts and reviewing State, municipal  and  other



programs to identify and control asbestos  hazards.
                               -6-

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    Table 2 shows the results, as of  April  1980,  of  an  EPA survey



of school districts regarding friable asbestos-containing



materials.  EPA mailed a guidance manual which  included  a  survey



form to school districts across the Nation  in May, 1979.   A copy



of the survey form follows Table 2.



    768 school districts containing 7,378 public  schools  (about



8% of the nation's total) responded to  the  survey.   Of  the 6,422



schools in these districts which were built or  renovated between



1945 and 1973, 5,797 were inspected.  1,916, or 33%  of  the



inspected schools that responded were identified  as  having



friable asbestos-containing materials.



    Although school districts across  the country  returned  forms,



districts in 7 States responded and less than 2%  of  the  districts



in 22 of the remaining States responded  (Table  3).



    EPA has preliminarily estimated that 8,545  public schools



have friable asbestos-containing materials.  These estimates are



based on the survey responses and follow-up contacts with  the



reporting school districts, contacts  with school  districts that



did not respond to the survey, and data  supplied  by  New  York



City's program on asbestos in schools.
                               -7-

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                                    Tuble 2. U.S. Environmental Protection Agoncy, Office of Pesticides and Toxic Substances Asbestos Survey Report by School District
Region


1
\/
/
it
'II
'III
X
<
ttiuiiul
>tuls
#SCH.
IN DIST.
45
69
3.307
184
540
828
187
261
755
1.202
7.378
#SCH.
BLT/REN
45-78
32
62
3.180
64
466
675
94
199
670
980
6.422
#SCH.
INSP.
42
72
2.666
89
418
688
147
195
612
968
6.797
#SCII.
USING
PLM
10
10
357
14
106
70
22
13
63
94
749
#SCH.
W/ ASB/
DATE
10
4
1,574
11
63
33
33
14
79
105
1,916
#SCH.
EXPOSED
PROB.
7
a
267
9
20
15
21
10
36
43
436
SO. FT.
EXPOSED
ASBESTOS
9.50Q
7,073
2,414,320
125,290
327,911
366,662
844.697
1,399,991
286.677
628.970
6.295,991
j^CIIILD
EXPOS.
601
660
102,113
1,434
9,279
8,402
8,624
2,690
6,721
68,923
198,147
#SCLFT
REMOVE/COST


671,953
12,612,089
41,480
6,940,000
128,370
887,885
61,190
1,876,600

1.405
1,982,250
112,920
643.666
143.157
676,666
1,150.475
26.318,956
j^SO. FT.
ENCAP/COST
1.200
2.250
1,000
721,527
6.508,988
63.840
1.009.200
269.317
25,353,650
281,500
65.000
123.800
610.000
15.200
1,400.400
142,248
866.400
1.619,632
35.815.888
/SO. FT.
ENCLS/COST
5.000
19.000

100.435
7.155.785
10
100
125,000
125.000
13.000
116,640
6,317.000

5,244
2,875
365.329
12.619,760
//SQ. FT.
DEHtH/INSP.
4.500
6.073
1.172,854
87,720
362.100
106,291
13,500
30,347
27,300
386.968
2,197.663
u:  See the following "Asbestos Survey Report", EPA Form 7710-29 (3-79). for full text of questipns 4  through 12.
                                                                                        -8-

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                                          ASBESTOS SURVEY  REPORT
                                           .'Survey c;  Ac:ivit:es to Control
                                  A soesros—Containing Materials in School  Buildings)
                                                                                                     ForTT. Approved
                                                                                                    OMB No. 158-R-0165
                                                           GENERAL
Th
on
to
   is information is collected under the authority of the Toxic  Substances  Control Act, Sections 6 and 8.  EPA is compiling information
   the  progress of State and local programs to control exposure to asbestos— containing materials in schools. This form should be used
   periodically report information concerning the asbestos control activities in your school district.  To obtain more forms, call this
   — free number:  800 — i24— 9065 or in the Washington, D.C. area, call 354—1404.  Data collected in this survey will be subject to the
          of the Freedom of Information Act f 5 U.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 asbestos program
                            contact (for name and address, call  this toll—free number: 800—
                            424—9065 or i( in the  Washington, D.C. area, call 554—1404),
                                                       IDENTIFICATION
1. SCHOOL DISTRICT INFORMATION
                                            2.  PERSON TO CONTACT REGARDING THIS REPORT
NAME OF SCHOOL. DISTRICT
                                            N AME {last, nrst, as miqcTc initial)
   "f OH COUNTY
                                                      J O H T I T j_ g
                                                     SPECIFIC QUESTIONS
3. Has the school district submitted an EPA Asbestos Survey
   Reoort before?
           i YSS
                            NO
                                           UNKNOWN
                                                                 4.  How many schools in the district were built or renovated
                                                                     between 1945 and 1978? .

                                                                 NUMBER OF "SCHOOLS      — —  — — —  ——       ___
    As of _ (mo./yr.), how many schools in the district
    have been inspected for the presence of friable asbestos—
    containing materials?
                                     SCHOOLS
                                                                  6.  Howmany schools had bulk samples analyzed for asbestos with
                                                                     the EPA recommended technique of P olarized Light Micro scopy i
                                                                 "UMBER o>TcSbo~Ls~            "~          —  — —       —
                        I
 7.  As of.
                  .(mo./yr. of
    analysis) for how many schools
    in the district was  friable ma-
    terial analyzed as containing
    asbestos?
NUMBER OF SCHOOLS
8. (a) In how many schools was friable asbestos—containing material determined to present
       an exposure problem?
   (b) Approximately how many square feet of this material were found?
   (c) Estimate the number of children per school year exposed to this material.  (Multiply
       the percent of children exposed by the total number of enrolled students, e.g., An
       exposure problem in five classrooms may involve 157c. of the total population of 700
       students; 15%. x 700 equals 105 students exposed.)
   (d) Have the names of the children been recorded and retained for future reference?
                                   a. NO. OF SCHOOLS
                                                          b. SQUARE FEET
                                                                                 IC-
                                                                                   NO. OF CHIDREN
                                                                                                      "Id. NAM
                                                                                                       I     3
                                                                      NAMES RECORDED

                                                                          YES    ~~| NO
                                                         I                                                   I_J YE5    _J N0
Questions 9 through 11  refer to the friable asbestos—containing material that presents an exposure prohlem in Question
 9.  (a) Aonroximatelv how many square feet of this material have    10.  (a) Approximately how many square feet of this material h
 9.  (a) Approximately how many square feet of this material
       been or will be removed?
    (b) What is the estimated total cost of removal?
 a. SQUARE FEET
                              T
                                 COST:
                            10. (a) Approximately how many square feet of this material have
                                    been or will be encapsulated?
                                (b) What is the estimated total cost of encapsulation?
                                                                a. SQUARE  FEET
                                                                                                 COST: $
11. (a) Approximately how many square feet of this material
        been or will be enclosed?
    (b) What is the estimated total cost of enclosure?
                                                         have
                                                                 12. (a) For approximately how many square feet of asbestos-
                                                                         containing material was action deferred?
                                                                     (b) Will this material be inspected periodically to de-
                                                                         termine if an exposure problem exists?
 a. SQUARE FEET
                                                                a. SQUARE FEET
                                 COST:  $
                                                                                               b. PERIODIC INSPECTION

                                                                                                       (H YES   (H NO
13. What is the source of funding for the asbestos control
    activities in your district?
                                                                 14.  When did (or will) the asbestos control activities tn the
                                                                     district begin and end?
 FUNDING SOURCE
                                                                BEGINNING YEAR
                                                                                             1
                                                                                               ENDING YEAR
                                                          COMMENTS
 EPA Form 7710-29 (3-79)
                                                               -9-

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REGIONAL OFFICES
Region 1
Mr. Paul Heffernan
Asbestos Coordinator
Air &. Hazardous Materials Div.
Pest. & Toxic Substances Br.
EPA Region I
JFK Federal Bldg.
Boston. MA 02203
(617) 223-0585

Region 2
Mr. Marcus Kantz
Asbestos Coordinator
EPA Region II
Room 802
26 Federal Plaza
New York. NY  10007
(212) 264-9538

Region 3
Mr. Fran Dougherty
Asbestos Coordinator
EPA Region III
Curtis Building
Sixth & Walnut  Streets
Philadelphia, PA 19106
(215) 597-8683

Region 4
Mr. Dwight Brown
Asbestos Coordinator
EPA Region IV
345 Courtland Street
Atlanta, GA 30308
(404) 881-3864

Region 5
Dr. Lyman Condie
Asbestos Coordinator
EPA Region V
230 S. Dearborn St.
Chicago, IL 60604
(312) 353-2291
Region 6
Dr. Norman Dyer
Asbestos Coordinator
EPA Region VI
First Internarl Bide.
1201 Elm Street
Dallas. TX 75270
(214) 767-2734

Region 7
Mr. Wolfgang Brandner
Asbestos Coordinator
EPA Region VII
324 East 11 Street
Room 1500
Kansas City, MO 64106
(816) 374-3036

Region 8
Mr. Ralph Larsen
Asbestos Coordinator
EPA Region VIII
1860 Lincoln Street
Denver. CO 80295
(303) 837-3926

Region 9
Mr. John Yim
Asbestos Coordinator
EPA Region IX
215 Fremont Street
San Francisco, CA 94105
(415) 556-3352

Region 10
Ms. Margo Partridge
Asbestos Coordinator
EPA Region X
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5560
                                         -10-

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Table 3. Respondents to EPA Survey for As
                           (As of April 2
[-Containing Materials in Schools
 0)
State
Alaska
Alabama
Arkansas
Arizona
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
No.
of forms
returned
2
0
0
122
11
3
3
8
1
1
0
6
5
0
3
3
1
4
1
0
2
44
4
3
6
3
Percentage of
total districts
that responded
3.9
0
0
57.8
1.0
1.7
1.8
50.0
1.5
0.5
0
5.2
0.5
0
0.7
0.9
0.5
6.0
0.7
0
0.8
7.6
0.9
1.9
1.1
0.5
State
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
Washington, D.C.
(citywide)
West Virginia
Wisconsin
Wyoming
No.
of forms
returned
7
5
1
1
44
18
3
24
6
6
14
134
0
1
5
2
22
4
0
85
119
1

25
2
3
Percentage of
total districts
that responded
2.0
29.4
0.2
0.2
5.0
2.5
2.0
7.8
1.0
1.0
25.9
26.6
0
1.1
2.6
1.3
10.0
10.0
0
63.0
39.3
100.0

45.5
0.5
6.1

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    The data for major school  jurisdictions  which  reported
inspection results for large portions of  their  schools  compare
favorably with the estimates.  New York City reported  that  180  of
the 1,735 city schools inspected had sprayed-on friable asbestos-
containing material in general use areas  or  10.4%  of  the city
schools.  A 1978 statewide survey of 326  schools  in Rhode Island
revealed that 24 (8%) had sprayed-on asbestos material.  In nine
schools some degree of deterioration was  noted  (Faich  1980).
Massachusetts' Special Commission on Asbestos in  Schools and
Public Buildings reported that walk-through  surveys had been
conducted in all 1,432 public  schools in  the State which were
built or renovated between 1946 and 1972.  178  schools, 12%,  were
identified as containing "sprayed-on asbestos"  (Commonwealth  of
Massachusetts 1978).
    Several factors, in addition to the low  response  rate in  some
States, affect the validity of the estimates.   First,  the
analysis is based on a small sample with  a large  response from
one geographic area (EPA Region III).  Second,  this sample  is not
random, and it may reflect a bias due to  the use  of information
from early respondents to the  survey.
    C.   Number of Persons Exposed to Asbestos  in  Schools
    Throughout the country, an estimated  3,000,000 students and
250,000 teachers, administrators, and other  staff, including
approximately 23,000 janitorial and maintenance workers are
potentially exposed to airborne asbestos  from friable  asbestos-
containing materials in public schools during the  school year.
An additional unknown number of persons may  be  exposed  in private
schools.
                               -12-

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    The number of exposed students was  estimated  from  information
contained in responses to the Agency's  survey  of  school  districts
regarding friable asbestos-containing materials.   The  survey form
included question 8(c):  "Estimate the  number  of  children  per
school year exposed to this  (friable asbestos-containing)
material."  Respondents were instructed  to  consider  whether  only
a portion of the school's population used the  area in  which
friable asbestos-containing materials were  found  and to  estimate
the "exposed" population accordingly (see survey  form).
    Adjustments were made to this data  base  by contacting
responding school districts, reviewing  data  from  New York  City,
and contacting school districts which did not  respond  to
determine whether" the response to the survey was  biased.
    To complete the analysis, the sample school districts  were
clustered by metropolitan code (inner city,  suburban,  rural), EPA
region, number of schools in the district,  and number  of students
per district.  Survey results were then  extrapolated to  the
aggregate of public school districts to  estimate  the total number
of students using areas likely to lead  to exposure.
    The number of exposed teachers was  estimated  on  the  basis of
National Center for Education Statistics data  that,  nationwide,
there is approximately 1 teacher per 20  students.  Finally,  the
number of exposed janitorial and maintenance workers was
estimated on the basis of the assumption that  there  are
approximately two such staff persons for each  of  the 8,545 public
schools with friable asbestos-containing materials.
                               -13-

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    D.   Remaining Years of Use  for  School  Buildings
    School buildings are built to  last  for  about  50 years,
although during the late 1950''s  and  the  1960's, slightly shorter
lifetimes were expected.  The 50-year estimate  is a rule of
thumb; no studies have been found  that  statistically  or  otherwise
validate this approximation (Gardner 1980).
    The schools most likely to have  friable asbestos-containing
materials were built between  1945  and 1973.   Using the 50-year
lifetime estimate, a school built  in 1945 would have  a remaining
life of 15 years,-one built in 1973  a life  of 43  years.   If  the
construction of the 8,545 schools  with  friable  asbestos-
containing materials was equally distributed  among the years 1945
to 1973, the average .expected remaining  life  would be 29 years.
Factors that affect this estimated average  are:
    (1)  spraying of asbestos was  most  popular  in the late 1950's
         and in the 1960's;
    (2)  more schools were built during  the 1950's and 1960's,  to
         accommodate the postwar baby boom, than  during  1945-
         1950;
    (3)  schools built in the 1950's and 1960's may not  be
         expected  to last as long as those built earlier or
         later;
    (4)  many schools are being  closed  across the nation
         because  of declining enrollment.
    The first two factors would  increase the  expected average
remaining life of schools; the last  two  would reduce  it.  In view
of the lack of definitive information on these  factors as applied
specifically to schools with  friable asbestos-containing
materials, an average remaining  life of  30 years  has  been chosen.
                               -14-

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III.     ASSESSMENT OF RISK FROM  ASBESTOS  IN  SCHOOLS
         A.   Introduction
    Friable asbestos-containing materials  that have  been used in
the construction of a large number  of  schools release  asbestos
fibers, and the Agency believes that occupants of  these  schools
incur risks of developing diseases  caused  by  exposure  to such
airborne fibers.
    This section assesses the risks of  adverse health  effects and
premature deaths from exposures to  asbestos  in schools.   In
making this assessment/ it was necessary to  identify  the health
hazards of asbestos exposure  (Part  B),  to  estimate the amount of
asbestos to which occupants of schools  are being or will be
exposed, and to estimate the  length of  time and the number of
occupants who are and will be exposed  (Part C).  This
information, in turn, was used to estimate the number  of people
expected to die from asbestos-caused diseases as a result of
exposure to "prevalent" (average) levels of asbestos  in  schools
(Part D), if all asbestos materials currently in the  schools
remain in place until the buildings are no longer used.
    The application of asbestos materials  by  spraying  produces a
friable coating.  The fact that asbestos fibers may be released
from these coatings was recognized  as  early as 1969  (Byrora,
Hodgson, and Helms, 1969), which  led to considerable concern  that
asbestos-caused diseases may  develop in occupants of buildings
containing the coatings (Reitze et  al.  1972).   Investigators
found that fiber levels in these  buildings varied widely because
of a combination of many factors  (Nicholson et al. 1978a,
                               -15-

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Sebastian et al. 1979a).  The wide  variation  of  asbestos
concentrations in time  and space means  that no single  measurement
can determine prevalent levels of asbestos  fibers  (Nicholson et
al. 1978a).  Studies do show, however,  that levels  in  buildings
containing friable asbestos materials can  frequently be very high
("peak" levels; see Table 13, Part  C).   Exposure  to these  levels
and to lower, prevalent levels are  predicted, as  shown in  Part D,
to result in a considerable number  of premature  deaths among
occupants of schools.
    An evaluation of the risk requires  combining  estimates of
asbestos concentrations in the buildings,  the risk of  disease due
to a given exposure, the number of  people  exposed, and the
duration of exposure.   The accuracy of  the  risk  evaluation is
limited, however, because all of the available data are on a
small number of areas sampled in a  small number  of buildings or
on the risk of asbestos-induced disease in  only  a  few
populations.  This limitation is dealt  with in two ways:  (1)  in
most cases, reasonable  assumptions  are  made about  how  well the
sampling data apply to  possible situations  in schools  and  the
validity of these assumptions is discussed; (2) when reasonable
assumptions cannot be made, cases are presented  that give  the
lowest or highest reasonable estimate of risk.   The accuracy of
the risk estimates is defined in both of these ways.
    Three sets of reasonable assumptions are  made  that give low,
medium, and high estimates of the risk  of mortality from exposure
to the prevalent concentration of asbestos  in schools.  These
estimates indicate that no fewer than 100  and no more  than 7,000
                               -16-

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premature deaths will be caused  by  exposure  to  prevalent  levels
of asbestos in schools if no controls  are  instituted.   Additional
premature deaths caused by short-term  exposures to  "peak"  levels
of asbestos also are very likely to occur.   However,  as explained
in Part D, the number of these additional  deaths as well  as
morbidity due to cancer and asbestosis cannot be estimated
quantitatively.
    B.   Hazard Assessment
         1.   Introduction
    The first step in assessing  risk from  asbestos  in schools  is
to identify the adverse health effects arising  from human
exposure to asbestos.  The evidence comes  primarily from
epidemiologic research.  Persons exposed to  asbestos  were  found
in these studies to be at increased risk of  developing specific
diseases/ thereby implicating the diseases as hazards of  asbestos
exposure.  Indications of dose-response relationships in  the
studies support these findings.
    The use of epidemiologic research  to identify a disease as a
hazard of asbestos exposure requires consideration  of four major
criteria: bias, confounding, chance, and biologic plausibility
(Cole 1979).  The proper design  of  studies and  analysis of
results to avoid misleading interpretation due  to bias and
confounding are explained in detail in many  epidemiologic
textbooks (e.g., MacMahon and Pugh  1970).  The  probability that
apparent associations between asbestos exposure and specific
diseases might be due to chance  alone  is distinguished by  the
application of standard statistical tests.   In  this assessment,
it is considered biologically plausible that asbestos exposure
                               -17-

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can increase the risk of cancer  at  a  given  anatomic  site  if
inhaled or ingested fibers can reach  that site.
    Epidemiologic studies may demonstrate dose-response relation-
ships (increasing risk with  increasing  level  of  exposure)  for
asbestos-induced diseases in various  degrees  of  detail.   Many
studies group exposure into only a  small number  of categories
(e.g., "high," "medium," or  "low").   These  studies provide
"qualitative" evidence of dose-response relationships  and  are
briefly summarized.  Other studies  contain  sufficiently detailed
exposure data to examine in more detail the shape of dose-
response curves within the range of observed  exposures.
    Part 2 below, identifies the following  diseases on the basis
of epidemiologic reasearch as hazards of asbestos exposure:  lung
cancer; pleural and peritoneal mesothelioma;  cancers of the
larynx, oral cavity, esophagus,  stomach, colon,  and kidney;  and
asbestosis.
    The next step in the assessment is  to identify factors that
influence the degree of risk posed  by asbestos exposure.   In Part
3, smoking, age, and fiber type  and size are  discussed as
possible factors that modify the degree of  risk.  As shown in
Part B, the increase in lung cancer risk among smokers exposed to
asbestos is greater than the sum of the separate increases
produced by asbestos exposure alone and smoking  alone.  Smoking
also may increase the risk of developing asbestosis.   Because
children have a greater remaining life  span than adults,  they may
have a greater likelihood of developing asbestos-induced
diseases.  The overall influence of other age-related  risk
factors, however, is difficult to assess.   All types of asbestos
                               -18-

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present in schools have  been  shown  to  be  hazardous,  and

differences in fiber size and  type  are not  likely to affect the

risk assessment substantially.

         2.   Health Hazards  of  Asbestos  Exposure

              a.   Lung  Cancer

    Epidemiologic studies demonstrate  clearly that the risk of

lung cancer is increased by exposure  to asbestos (e.g.,  Doll

1955, Selikoff et al. 1964, Peto et al. 1977, Newhouse and Berry

1979).   Several studies  show  qualitatively  that  the  greater the

exposure, the greater the increase  in  risk  (Table 4).   In

addition, the authors of two  studies  of respiratory  cancer

mortality (predominantly due  to  cancers of  the lung) among

asbestos workers have drawn linear  non-threshold dose-response

curves to summarize their data (Figure !).!/.  According to this

curve,  all asbestos exposures, even those of  very brief duration

or very low intensities, intensities,  increase risk  of cancer.
I/  Figures 1 and 2 are presented  simply  to  demonstrate  the shape
    of the dose-response relationships  in  the  two  studies.   These
    and similar dose-response  curves  appearing in  this report
    should not be compared directly to  each  other,  because
    substantial differences exist  among study  designs,
    measurement techniques, and exposure  conditions.  For
    instance, asbestos concentrations in  Figures 1A and  IB  were
    measured with the same type of instrument  (midget impinger),
    but the method does not distinguish asbestos particles  from
    other particles.  Thus, the apparent  difference in slope
    between the two curves could have resulted from a higher
    fraction of asbestos particles in samples  taken in the
    asbestos products factory  (Figure IB)  than in  samples taken
    in the mining and milling  facility  (Figure IB).
                               -19-

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                               Table 4. Studies Showing Qualitative Dose-Response Relationships
                                 Between Asbestos Exposure and Increased Risk of Lung Cancer
                  Reference
                                  Type of asbestos
                         Type of exposure
                          Measure of exposure
to
o
Newhouse and Berry (1979)
Hobbsetal. (1979)
Meurman et al. (1979)
Wagoner et al. (1973)
Mancuso and El-Attar (1967)
Selikoff and Hammond (1975)
Nicholson et al. (1978b)
Hughes and WeilM 1979)
Mixed
Australian crocidolite
Anthophyllite
Primarily chrysotile
Primarily chrysotile
Amosite
Primarily chrysotile
Mixed
Factory work
Mining and Milling
Mining and milling
Factory work
Factory work
Factory work
Factory work
Factory work
Intensity and duration
Duration
Intensity
Duration
Duration
Duration
Intensity
Cumulative exposure

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                                                                             10
   (O
    -*
    v>
to  «o
H  «
'   CC
        3
                       500
   x through 1966
   o through 1975
1000
                             Cumulative exposure1
1500
                (million particles per cubic foot x years)

         Source: Adapted from McDonald and Lidded (1979).
                                 CO

                                  .g

                                  0>
                                                                       (U
                                                                       CC
                          8


                          7


                          6


                          5


                          4


                          3


                          2


                          1


                          0
                                                                                   B
                                          0   100   200  300  400  500  600  700   800  900  1000

                                                          Cumulative exposure"

                                                (million particles per cubic foot x years)

                                         Source: Adapted from Henderson and Enterline (1979).
         aRelative risk is the mortality rate in an exposed group divided by the rate in a comparison group.
           In Study A, the comparison group is the group of leajt exposed workers. In Study B, it is the general
          population.

           Units for cumulative exposure are not directly comparable among studies. See footnote on page 22.
         Figure 1. Dose-response Curves for Respiratory Cancer Mortality in Two Groups of Asbestos Workers.
                  A, Chrysotile miners and millers; B,  retired asbestos production and maintenance workers.

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The increases are directly proportional  to  cumulative

exposure.2/  This curve, and  its  use  in  predicting  risk  increases

predicting risk increases at  low  exposure levels,  is discussed  in

greater detail below in Part  D.l.f.

    Direct evidence of elevated lung  cancer risk  following  low

cumulative asbestos exposure  is provided by a  study of asbestos

production workers (Seidman et al.  1979). In this  study, men  with

less than 3 months of employment  had  a lung cancer  mortality  rate

more than two times higher than that  expected  from  general

population rates.  EPA has estimated  that the  average exposure

level in the plant was 40,000,000 f/m3 (EPA 1979a).  Thus,  an

increase in lung cancer risk  was  detected epidemiologically

following a cumulative exposure of  less  than 10,000,000

f-yr/m3.  Although it was achieved  by relatively  short-term

exposure to high concentrations,  this is the lowest level of
                                                       •
cumulative asbestos exposure  shown  epidemiologically to  lead  to

increased lung cancer risk.

              b.   Pleural and Peritoneal Mesothelioma

    Malignant mesothelioma is an  extremely  rare type of  cancer

that appears as a thick, diffuse  mass inside any of the  serous

membranes (mesothelia) that line  body cavities.^-  Considerable
2/  Cumulative exposure is calculated by multiplying  the average
    concentration of asbestos in the air by the duration of
    exposure.  When concentration  is measured  in  fibers per  cubic
    meter of air and duration is measured in years, the units  for
    cumulative exposure are fiber-years/cubic  meter (f-yr/m3).
3/  There is a benign form of mesothelioma  (Taryle et al.
    1976).  This discussion concerns only the malignant  form.
                               -22-

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epidemiologic research  (e.g., Wagner  et  al.  I960,  Mancuso  and
Coulter 1963, Selikoff et al. 1965, Newhouse  and  Thompson  1965,
Ashcroft and Heppleston 1970, Puntoni et al.  1976)  has  shown  that
exposure to asbestos can produce mesothelioma at  two  sites: the
pleura, the serous membrane  that surrounds  the lungs  and
separates them from the thorax; and the  peritoneum, the serous
membrane that surrounds the  abdominal organs  and  lines  the
abdominal and pelvic cavities.
    Neither pleural nor peritoneal mesothelioma can be  treated
effectively, and both are nearly always  fatal (Taryle et al.
1976, Kovarik 1976, Saijo et al. 1978).   One-half of  all patients
die during the first year after diagnosis,  and few  patients
survive longer than 2 years  (e.g., Whitwell  and Rawcliffe  1971,
Rubino et al. 1972, Lumley 1976).
    As in the case of lung cancer/ a  number  of epidemiologic
studies qualitatively demonstrate dose-response relationships
between occupational asbestos exposure and  the risk of
mesothelioma (Table 5).  In  addition,  Hobbs  and colleagues (1979)
found that the incidence of  pleural mesothelioraa  among Australian
crocidolite miners and millers  increased  in direct  proportion to
increasing duration of exposure.  The linear  trend  and the
occurrence of mesothelioma among the  workers  in this  study who
were exposed"most briefly (<3 months)  are reasonably  compatible
with a linear nonthreshold dose-response  relationship (See Part
D.l.f).
                               -23-

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                                      Table 5. Studies Showing Qualitative Dose-Response Relationships


                               Between Asbestos Exposure and Occurrence of Pleural and Peritoneal Mesothelioma
 i
to
Reference
McDonald et al. (1970)
Newhouse and Berry (1979)
Hobbsetal. (1979)
Selikoff (1977)
Type of asbestos
Chrysotile
Mixed
Crocidolite
Amosite
Anatomic site
Pleura
Pleura/peritoneum
combined
Pleura
Pleura/peritoneum
Measure of exposure
Cumulative exposure
Duration and intensity
Intensity
Duration
                                                                        separately

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    Pleural and peritoneal mesothelioma  are  considered  "marker
diseases" for asbestos exposure.  A marker disease  is one  that  is
often, if not always, caused by a particular agent.   In all  cases
of pleural and peritoneal mesothelioma,  extremely rare  types of
cancer, there have been very strong suspicions  that  exposure to
asbestos was the cause.  In fact, as discussed  below, close
examination of individual case histories of  mesothelioma patients
usually provides evidence of some identifiable  exposure to
asbestos above ambient levels, even if only  of  brief duration or
low intensity.
    It is estimated that "apparently complete"  case  history
information reveals some source of asbestos  exposure above
ambient levels for 85%-90% of all mesothelioma  patients (Wagner
et al. 1971).  For some patients, however, "apparently  complete"
information is actually incomplete.  Milne (1976) discovered that
the last known occupations recorded on death certificates
misleadingly indicated an absence of asbestos exposure  for 66% of
a series of mesothelioma patients later  found,  when  their case
histories were traced more diligently, to have  been  exposed.
McEwen and colleagues (1971) found that  the  hospital records of
55% of another series of patients did not contain information on
the asbestos exposures that these patients had,  in  fact,
experienced.  In addition, mesothelioma  patients who, during
personal interviews, were unable to recall experiencing any
asbestos exposure were later found to have asbestos  fibers in
sections of their lung tissue taken at autopsy  (Chen and Mottet
1978, Hourihane 1964).  These studies strongly  imply that
significantly more than 90% of all persons with mesothelioma have
                               -25-

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been exposed to asbestos above  the ambient  outdoor  exposure
levels experienced by most urban dwellers  (Selikoff and  Lee
1978).  Ambient exposure levels in urban and  rural  air may have
been responsible for a substantial proportion of  the <10%
remaining cases.  It is, therefore,  reasonable to presume  that
all cases of mesothelioma in persons who have had previous
asbestos exposure are the result of  that exposure.
    Given the status of pleural and  peritoneal mesothelioma  as
marker diseases for asbestos exposure,  the  many well-documented
cases that have followed extremely brief exposure to high
concentrations of asbestos or long-term exposure  to low
concentrations provide evidence that risk  is  increased at  these
low levels of cumulative exposure.   Table  6 lists a few  of the
cases of mesothelioma that have followed brief or low-intensity
asbestos exposure both inside and outside  the workplace.   Table  7
lists 48 cases of mesothelioma  that  have occurred in persons
sharing homes with asbestos workers.  Table 8 lists 144
mesotheliomas that have occurred in  persons who resided  within a
mile of an asbestos products factory, mine, or shipyard  and  who
had no other known asbestos exposure.   These  case histories
provide evidence that very brief or  low-intensity exposure to
asbestos can cause mesothelioma.
                               -26-

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            Table 6.  Mesothelioma Occurring After Brief or Low-Intensity Asbestos Exposure
            Reference
   Anatomic site and nature of exposure
Lieben and Pistawka (1967)
McDonald et al. (1970)
Borowetal. (1973)
Newhouse(1973)
Green berg and Lloyd Davies (1974)
Nurminen (1975)


Jones etal. (1976)



Anil and Holt (1977)


Bruckman et al. (1977)

Wiutwell et al. (1977)


Cochrane and Webster (1978)


Seidman etal. (1979)
1 pleural; helped replace plaster board
during extensive remodeling of his house

1 pleural; mixed and applied asbestos insulation
to boilers in home for "a few hours"

1 pleural; recycled asbestos filters in a brewery

1 pleural; sawed pipe coverings at home

1 (site unspecified); handled asbestos sheet
and pipe in a hardware store

2 pleural; stock boys in asbestos products
factory for 10 and 18 months, respectively

1 peritoneal; played on an asbestos factory
waste pile as a child

1 (site unspecified); relined and refitted clutches
and brakes as hobby.

1 (site unspecified); lived in a house  largely
composed of asbestos sheeting

1 (site unspecified); worked on and lived adjacent
to a chicken farm with asbestos-cement buildings

1 (site unspecified)); sawed asbestos-cement
sheets for 1  day to construct two sheds

1 pleural; did repair work on own house and
handled asbestos boards

1 (site unspecified); inspector at a gas mask
assembly plant, did not handle asbestos pads
used in assembly of masks

1 pleural; resided near an asbestos products
factory for 2 years

1 (site unspecified); toll collector

2 pleural; filled gas mask cannisters with
crocidolite for 6 months

1 pleural; jeweller, occasionally cut
sections from a roll of asbestos textile

1 pleural and 1 peritoneal; worked in an
amosite products factory for less than
9 months
                                              -27-

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                                               Table 7. MesotK^Wma Occurring in Persons

                                               Sharing Households with Asbestos Workers
                                                                                       No. of

                                            Reference                               mesotheliomas




                                    Anderson et al. (1976)                                 37a


                                    Vianna and Polan (1978)                                7


                                    Hobbsetal. (1979)                                     2


                                    Edge and Choudhury (1978)                             1


                                    Hainetal. (1974)                                      1



                                                                                 Total  48
I
ro
oo
 i                                    a
                                      Total includes cases reviewed from reports other than those listed.

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            Table 8. Mesothelioma Occurring in Persons
         Residing Near Point Sources of Asbestos Emissions
            Reference                      No. of mesotheliomas

  Hain et al. (1974)                                  105a
  Cochrane and Webster (1978)                         13
  Wagner et al. (1960)                                 13
  Borowetal. (1973)                                   2
  Greenberg and Lloyd Davies (1974)                   10
  Arul and Holt (1977)                                 1

                                            Total  144


aTotal includes cases reviewed from reports other than those listed.

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         c.   Other Cancers
    The scientific evidence reported below  supports  the
identification of cancers of the larynx, oral  cavity,  esophagus,
stomach, colon, and kidney as hazards of asbestos  exposure.
    Three cohort studies of asbestos workers  (Newhouse and  Berry
1979, Selikoff et al. 1979a, Rubino et al.  1979) and  two  case-
control studies (Stell and McGill 1973, Morgan  and Shettigara
1976) found increases in the risk of larynx cancer following
exposure to asbestos.  In one of the studies  (Rubino  et al.
1979), the risk increased with increasing cumulative  asbestos
exposure, an indication of a possible dose-response  relationship.
    The rates of mortality due to cancers of  the esophagus  and
oral cavity the latter comprised of the (buccal cavity and
pharynx) were elevated in a group of 17,800 asbestos  insulation
workers, compared with the rates in a group of  other  blue-collar
workers (Hammond et al. 1979, Selikoff et al.  1979a).  These
cancers, like cancer of the larynx, have been  shown  to be related
to cigarette smoking (Hammond 1966).  To allow  for this
association, Hammond and colleagues (1979)  accounted  for  the
smoking habits of the insulation workers and  the comparison
group.
    The asbestos insulation workers had higher  stomach cancer
mortality rates than the comparison group (Hammond et al.
1979).  In addition, stomach cancer rates were  elevated in  a
group of amosite production workers (Selikoff and  Hammond  •
1975).  In the latter group, the risk of stomach cancer increased
with duration of asbestos exposure, an indication  of a possible
dose-response relationship.
                               -30-

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    A clear excess risk of colon cancer was  reported  in  a  group
of 632 asbestos insulation workers  in New  York  and  New Jersey
(Selikoff 1977a).  Mortality .rates  for cancers  of  the colon  and
rectum combined were significantly  elevated  among  the larger
group of 17,800 asbestos insulation workers  (Hammond  et  al.  1979)
and among the amosite factory workers (Selikoff and Hammond
1975).  Because the results for rectal cancer were  not reported
separately in the latter two studies/ only cancer  of  the colon
can be said to be a hazard of asbestos exposure at  this  time.
    The large group of asbestos insulation workers  also
experienced an increase in kidney cancer mortality  (Hammond  et
al. 1979).  This epidemiologic finding and the  corroboration lent
by an experiment in which an excess of kidney cancer  was seen in
rats fed ground, paper-based beverage filters containing 53%
chrysotile asbestos (Gibel et. al 1976) lead to the conclusion
that kidney cancer should be considered a  hazard of asbestos
exposure.
    Inhaled asbestos can be expected to reach each  of the
anatomic sites at which increased risks of cancer were shown in
the epideraiologic studies discussed above.  The process  of
respiratory clearance results in exposure  of the larynx, oral
cavity, esophagus, stomach and colon to inhaled asbestos
                               -31-

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fibers -i/.  Exposure of the kidneys  was  shown  directly when
chrysotile asbestos was found  in  the  kidneys  of  rats  (Cunningham
et al. 1977) and a baboon  (Hallenbeck and  Patel-Mandlik 1978)
that had been fed the fibers.   Indirect evidence that the  kidneys
become exposed was provided  by  the  detection  of  fibers in  the
urine of persons who drank water  contaminated with  the fibers
(Cook and Olson 1979).
              d.   Asbestosis
    Exposure to airborne asbestos produces a  chronic  non-
cancerous disease of the lungs  that/  in its severest  form  is
called asbestosis.  As implied  by its name, the  disease is caused
solely by exposure to asbestos.   It is  characterized  by a
hardening and thickening of  lung  tissue that  is  called
fibrosis.  The rigidity produced  by this process restricts the
normal movement of the lungs.   Asbestosis  is  irreversible  and
there is no effective treatment (Becklake  1976,  Selikoff and Lee
1978).  In advanced stages,  the disease can be fatal.  In  a study
of mortality among asbestos  textile workers employed  under
extremely dusty conditions (Doll  1955), 63% of the  death
certificates listed noncancerous  respiratory  disease  in
conjunction with asbestosis  as  the  cause of death.
4/  The airways of the lungs  are  lined  with  a  layer of  mucus  that
    is moved along by cilia,  hairlike structures  attached  to  the
    free surface of the cells on  the  airway  surfaces.   Inhaled
    particles that become embedded  in the  mucus eventually are
    cleared to the oral cavity, where they are swallowed  or
    expectorated.
                               -32-

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    A.   Uses of Friable Asbestos-Containing  Materials  in
         Building Construction
    Asbestos is used in buildings  as  a  spray- or  trowel-applied
coating to building surfaces to retard  fire,  deaden  sound,  or
decorate; it is also used  in lagging  on boilers and  pipes,  and  in
cement products, plasters, vinyl tile,  and miscellaneous  products
such as lab table tops and ventilation  hoods.  Asbestos-
containing sprayed- or trowelled-on materials were first  used  in
the U.S. in 1935, when the material was found to  be  suitable  for
acoustical purposes and for decorative  finishes in public
buildings.  In the 1950's, one of  the most significant  advances
in the construction industry was the  replacement  of  concrete  with
asbestos to protect structural steel  against  fire.   Structural
steel must be insulated to ensure  that  it does not become soft,
bend, and collaspe during  a fire.  The  replacement of concrete by
asbestos greatly reduced the weight and bulk  of large buildings
(Sawyer 1979).
    The amount of asbestos in the  mixtures used in these
applications varies widely.  From  1%  to 80% or more  of  asbestos,
usually chrysotile or amosite or a mixture of the two,  were
combined with other fibers (including cellulose,  mineral  wool, or
fiberglass), and cement or resinous binders.   Table  1 shows the
results of analyses of a variety of sprayed-  or trowelled-on
asbestos samples from schools in the  U.S. (Battelle  1980).
Nicholson et al. (1978a) reported  similar concentrations  for
schools in New Jersey.  (Paint present  in these samples may have
been applied at the time of spraying  or during subsequent
maintenance operations.)
                               -3-

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    Asbestosis is a progressive disease  that has various degrees
of severity (Berry and Lewinsohn 1979).  Asbestos exposure can
continue to cause damage to the lungs even after direct exposure
has ceased (Becklake et al. 1979).  Symptoms likely  to prompt an
exposed individual to seek medical care, such as loss of breath
or a bluish discoloration of the skin,_^ do not appear until well
after severe oxygen deprivation has occurred (Harries 1973, Robin
1979).  In order to detect progressing asbestosis (i.e., the less
severe stages of the disease), exposed individuals must be
examined for clinical and diagnostic signs.
    Most often, medical examinations of  persons exposed to
asbestos include chest x-rays and a physical examination that
includes a determination of the presence or absence  of
crepitations/ the abnormal lung sounds that are characteristic of
asbestosis (Leathart 1968, Forgacs 1967, 1969).  Unlike lung
function tests, which are conducted less frequently, crepitations
and abnormal x-ray findings do not indicate directly that health
is impaired.  Instead, they show that the disease process has
begun.  For example, persons with crepitations have  a high
probability of suffering later decrements in lung function (Berry
et al. 1979).  Often, persons with lung  damage visible on x-rays
already have impaired lung function (Jodoin et al. 1971, Selikoff
and Lee 1978).  Abnormal x-ray findings  also indicate that a
person is at high risk of subsequently developing more severe
5/  This discoloration  (called cyanosis)  is due  to an excessive
    concentration of nonoxygenated hemoglobin  in the blood.
                               -33-

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stages of asbestosis.  For instance, Liddell  (1979)  found  that



asbestos miners and millers with lung damage  detectable on  x-rays



later experienced an asbestosis mortality rate  nine  times  greater



than that experienced by workers with normal  x-rays.



Consequently, although some researchers reserve  the  term



"asbestosis" for advanced stages of the disease  [e.g.,  "clinical"



asbestosis (Murphy et al. 1971) or "certified"  asbestosis



(McVittie 1965)], crepitations, x-rays findings  of lung damage,



and measurements indicating decreased lung  function  are each



considered signs of asbestosis in the following  discussion.



    A large number of occupational studies  have  used  the various



measures of asbestosis to demonstrate dose-response



relationships.  The studies in Table 9 show qualitatively  that



the risk of asbestosis rises with increasing  asbestos exposure.



McDonald and colleagues (1979) described the  dose-response  curve



for asbestosis mortality among Canadian chrysotile miners  and



millers as a linear relationship (Figure 2),  although they



cautioned against extrapolation to very low exposure  levels.  An



earlier study of x-ray-detectable lung damage among  South  African



crocidolite miners and millers (Sluis-Cremer  and duToit 1973) is



consistent with this finding (Figure 3), as is  a very recent



study of asbestos textile workers in the United  Kingdom (Berry



and Lewinsohn 1979).  Data from the latter  study are  used  in



Figure 4 to draw dose-response curves for three  stages of



asbestosis (crepitations, "possible" asbestosis, and  "certified"



asbestosis):
                               -34-

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Table 9. Studies Showing Qualitative Dose-Response Relationships
  Between Asbestos Exposure arwarious Measures of Asbestosis
Reference
Selikoff and Hammond (1975)
Nicholson et al. (1979b)
Hobbsetal. (1979)
Lacquet (1979)
Selikoff (19771))
i Sclikof fetal. (1979b)
to
en
1
Selikoff (1977c)
Sluis Cremer and duToit (1973)
Baselga-Monte and Segarra (1978)
Harfetal. (1979)
Ayer and Burg (1978)
Type of
asbestos
Amosite
Primarily chrysotile
Australian crocidolite
Mixed
Chrysotile
Mixed
Primarily chrysotile
Amosite and crocidolite
Mixed
Mixed
Mixed
Type of
exposure
Factory Work
Factory Work
Mining and milling
Factory work
Mining and milling
Shipyard work
Insulation work
Mining and milling
Factory work
Spray application
Factory work
Measure of
exposure
Duration
Intensity
Duration
Cumulative
exposure
Duration and
intensity
Duration from
exposure onset
Duration from
exposure onset
Cumulative
exposure
Mean cumulative
exposure
Duration
Duration
Measure of
asbestosis
Mortality
Mortality
Incidence
Incidence
X-ray changes
X-ray changes
X-ray changes
X-ray changes
X-ray changes
Decreased vital
capacity
Decreased forced
vital capacity

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U)

Ch
        SJ

       I
        Q>
       cc
             80
             70
             60
             50
40
             30
             20
             10
                0
                100
200           300           400           500           600




 Cumulative exposure" (million particles per cubic foot x years)
700
800
                        Source: McDonald, as reported Acheson and Gardner (1979).



                         aSlope determined by the formula, slope  =£x(y-1)/£x .


                         "Units for cumulative exposure are not directly comparable among studies. See footnote on page 22.
                         Figure 2. Dose-response Curve for.Asbestosis Mortality in a Group of Chrysotile Miners and Millers.

-------
 I
10
8
t
             60 r
             50
         0)
         en

        |

         O)
        |   40
         o>
         c

         o

        "?   30
             20
             10
              0
                                                                                                                          J
                            1,000
                                  2.000
3,000
4,000
5,000
6,000
7,000
8.000
                                        Cumulative exposure (long-fiber equivalents per cubic centimeter x years)"

                      Source: Sluis Cremer and duToit (1973).

                        "Slope determined by the formula, slope = S xy/Sx .
                        "Converted by the authors from concentrations measured in million particles per cubic foot x years. Units for
                         cumulative exposure are not directly comparable among studies. See footnote on page 22.
                        Figure 3. Dose-response Curve for X-ray Signs of Asbestos in a Group of South African Miners and Millers of
                                 Amosite and Crocidolite.

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       80
       60
       40
               slope  = 0.26a
  CD

  >

  o
  VI

  I

  §
  O
  09
  Q.
  8
  i
       20


        0
8


6


4


2


0
                   50      100      150       200      250

                             Cumulative exposure (f-yr/cm^) b


              B
              slope = 0.021a
                                                         300
          50      100       150      200       250

                     Cumulative exposure (f-yr/cm^)b
__I
 300
        2


        1
              slope = 0.00968
o -*'•
0
1
50
i
100
1
150
i
200
i
250
i
300
                           Cumulative exposure (f-yr/cm^)
         Source:  Berry, as reported in Acheson and Gardner (1979).
         aSlopes determined by the formula, slope =   xy /
          Units for cumulative exposure are not directly comparable among studies
           See footnote on page 22.

Figure 4.  Dose-response Curves for (A) Crepitations,  (B) Possible Asbestosis and
        (C) Certified Asbestosis in a Group of Asbestos Textile Workers
                                    -38-

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Possible asbestosis represents  a  judgment  by  the  factory  medical
officer, based on periodic physical  examinations  and  x-rays,  that
the disease has progressed to the  extent that a worker  should
move to a less dusty job.  The  diagnosis of certified asbestosis
qualifies a patient for workmen's  compensation (McVittie  1965).
Without extrapolation, the curves  in Figure 4 show  the  following
annual incidence rates of asbestosis for workers  with previous
cumulative exposure of approximately
25 f-yr/cm3:
    certified asbestosis     2  cases/10,000 workers/year
    possible asbestosis      5  cases/10,000 workers/year
    crepitations            65  cases/10,000 workers/year.
This represents the lowest level of  cumulative asbestos exposure
at which severe forms of asbestosis  have been detected.
    These studies of dose-response relationships  imply  that the
risk of asbestosis is proportional to cumulative  asbestos
exposure.  .Because the curves do not demonstrate  a  "no-adverse-
effect level" of exposure, signs of  asbestosis may  well result
from exposure levels lower than those present in  the asbestos
factories, mines, and mills that were studied.
    The above implication is borne out by  the results of  studies
that show that signs of less severe  stages of asbestosis  can
occur in individuals exposed to asbestos outside  the workplace.
The most important results are  those reported by  Anderson and co-
workers (1979), who found a high prevalence of lung abnormalities
on the x-rays of children and other  persons living  in the same
households as asbestos workers  (Table 10).  Persons sharing
                               -39-

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                                               Table 10.  Lung Abnormalities Detected on X-rays

                                              of Persons Sharing Households with Asbestos Workers
Group
No. of persons

  examined
                                                                                    No. of x-rays with

                                                                                 one or more abnormality
I
•J^
O
Controls
All household contacts
Sons and daughters only
-<1 year of exposure only
325
679
375
192
15 (4.6%)
239 (35.2%)a
109(29.1%)a
47 (24.5%)a
                                Source: Anderson et al. (1979)

                                Probability that the difference from control value resulted by chance alone is less
                                  than 0.001 (Two-tailed chi square test. See Fleiss 1973).

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households for less than 1 year with  persons  actively  employed  as
asbestos workers had a percentage of  abnormalities  five  times
higher than that of controls.  The  asbestos concentrations  in
these homes are not known, but they are  presumed  to  have  been
many times lower than those  to which  the workers  were  exposed at
their places of employment.  Thus,  persons sharing  households for
less than 1 year with persons actively employed as  asbestos
workers had very low levels  of cumulative exposure.
    Another recently reported study concerns  office  workers whose
only known asbestos exposure was from sprayed-on  insulation
materials in office buildings in Paris (Awad  et al.  1979).   These
individuals received medical examinations that included  a
determination of the presence-of "crackling rales"
(crepitations).  Of office workers  employed for 10 or  more  years
in building areas with "low  protection"  but no "specific
exposure," only 0.4% had crepitations.   The prevalence was  three
times higher (1.3%) among workers who were present during
construction of the building but who, at the  time of the  survey,
worked in buildings free of  asbestos  contamination.  The  highest
prevalence (2.5%) was found  among employees having direct contact
with "ceilings, sheaths, cupboards, etc." coated  with  asbestos-
containing materials.  These results  are  no reported completely
and, because of the small number of persons with  crepitations,
cannot be ruled out the possibility that  these findings should be
attributed to chance.  Nevertheless,  if  validated, they will form
the first direct evidence of asbestosis  among occupants of
buildings that, like many school buildings in the United  States,
were constructed with sprayed-on asbestos-containing materials.
                              -41-

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    In South Africa, Sluis-Cremer and  duToit  (1979)  found  lung


abnormalities characteristic of asbestos  exposure  (e.g., pleural


calcification) on the x-rays of nonworkers  residing  near asbestos


mines.  The prevalence increased with  duration  of  residence  in


the area, another demonstration of a dose-response relationship.


    The three studies of nonoccupational  exposure  cited above


support the inference from occupational dose-response  curves that


lung damage characteristic of asbestosis  can  occur in  persons


exposed to asbestos concentrations lower  than those  in


occupational settings.  The two best sources  of  information  for


predicting whether signs of asbestosis can  result  from asbestos


exposure levels found in schools would be the findings among


household contacts of asbestos workers (Table 10)  and  the  dose-


response curves in Figure 4.  Unfortunately,  the absence of  data


on asbestos concentrations in workers' homes  prevents  a direct


comparison with the situation in schools.   The  lowest  level  of


cumulative exposure actually measured  in  Figure  4  (25  f-yr/cm3)


is approximately 100 times the highest estimate  for  adults


employed in school buildings (using a  conversion factor of 1

    •5              -5
f/cm  = 33,000 ng/m ; see Table 18).   [Unlike the  assessment of


cancer risks, in which extrapolation is warranted  by the current


scientific understanding of carcinogenic  processes and by


regulatory policy, an extrapolation of asbestosis  risks over two


orders of magnitude of cumulative exposure  may  be  unduly


speculative.]  Some noncancerous lung  damage  probably  will result


from asbestos exposure in schools, but the  extent  of damage


cannot be predicted with a reasonable  degree  of  confidence.
                               -42-

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              e.    Summary and conclusions
    Epidemiologic research has identified cancers of  the  lung,
pleura, peritoneum, larynx, oral cavity, esophagus, stomach,
colon and kidney as hazards of asbestos exposure.   Inhalation of
asbestos also produces the non-cancerous lung disease
asbestosis.  Dose-response relationships (increasing  risk
correlated with increasing asbestos exposure) have  been shown or
suggested for cancer of the lung, larynx, and stomach, pleural
and peritoneal mesothelioma, and asbestosis.  Two studies of
respiratory cancer among asbestos workers provide results
compatible with linear nonthreshold dose-response curves.
    These dose-response studies imply  that  asbestos exposure can
increase the risk of cancer at lower exposure levels  than those
studied.  This expectation is supported by  evidence of adverse
health effects resulting from relatively low levels of asbestos
exposure.  Increased lung cancer risk  has been observed among
workers exposed to asbestos for the equivalent of 5 years at the
current workplace standard of 2,000,000 f/m3.  Mesothelioma, a
"marker disease"  for asbestos exposure, has occurred  in persons
with exposures as brief as 1 or 2 days and  in persons with steady
exposures as low as those found in the homes of asbestos workers
and in neighborhoods around asbestos mines, products  factories,
and shipyards.  X-ray signs of asbestosis have been detected
among persons sharing households with  actively employed asbestos
workers for less than a year.  Linear  nonthreshold  dose-response
curves predict that asbestos exposure  in schools will produce
adverse health effects (see Part D).   This  prediction is
                               -43-

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consistent with the occupational dose-response  curves  and  with
the observation of increased risks of disease at  exposure  levels
lower than those found in the workplace.
    Part B 3, below, identifies factors  that  influence  the degree
of increased risk posed by asbestos  exposure.   Part  D,  estimates
risks of cancer mortality expected to result  from exposure to
asbestos in school buildings.
         3.   Factors that Modify the Risk  of Asbestos-Induced
              Disease
              a.   Smoking
    The major factor affecting  the risk  of  asbestos-induced lung
cancer, other than the intensity and duration of  asbestos
exposure, is the smoking habits of exposed  individuals.
Although, as shown below, asbestos exposure alone and  cigarette
smoking alone can each cause lung cancer in humans,  the  combined
effects of cigarette smoking and asbestos exposure produce an
increase in lung cancer risk that is greater  than the  sum  of the
increases produced by the two agents independently.  In  one
study, a group of 283 asbestos  insulation workers who  smoked had
a lung cancer mortality rate approximately  90 times  greater than
the rate they would have had if they had  been neither  smokers nor
asbestos workers (Selikoff et al. 1968).  In a  more  recent study
of 17,800 asbestos insulation workers, the  rate was  50-60  times
greater (Hammond et al. 1979).  As discussed below,  this latter
study also showed that the combined  effect  of smoking  and
asbestos exposure exceeded the  sum of their separate effects, an
indication that the effects of  asbestos  and smoking  interact or
modify one another in some way.
                               -44-

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    In the earlier study of asbestos  insulation  workers  (Selikoff



et al. 1968)/ there were no lung cancer  deaths among  87



nonsmokers.  This study prompted speculation  that  asbestos  might



increase lung cancer risk only in  smokers  (Cole  and Goldman 1975,



Hoffmann and Wynder 1976).  The current  evidence/  however,  shows



that asbestos exposure induces lung cancer  in smokers and



nonsmokers alike.  The recent study by Hammond and colleagues



(1979), found a fivefold increase  in  the risk of lung cancer



among 891 nonsmoking asbestos insulation workers.  Because  it



covered a larger group of nonsmoking  workers over  a longer



follow-up period, the study of Hammond et  al. had  a higher



probability of detecting an increase  in  risk than  the earlier



study.  Asbestos exposure, therefore, increases  lung  cancer risk



even in the absence of cigarette smoking (Selikoff and Hammond



1979).



    In the study by Hammond et al., the  asbestos workers who



smoked cigarettes could have avoided  about  the same increase in



lung cancer risk if they had not been asbestos workers as they



could have if they had not been smokers.   In 1978, Selikoff



supplied EPA with a set of unpublished data  from this study that



enables estimates to be made of the proportion of  lung cancer



deaths among the cigarette-smoking asbestos workers that can be



attributed to smoking alone, asbestos alone, interaction of the



effects of asbestos and smoking, and  unknown factors  (Table 11).



Estimates were made of the number  of  deaths that could be



expected among the smoking asbestos workers  if they had been



neither smokers nor asbestos workers  (E^),  if they had smoked but
                               -45-

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                  Table 11. Observed and ExpectecHing Cancer Deaths > 20 Years from

                         Onset of Exposure in a Group of Asbestos Workers with

                                    a History of Cigarette Smoking.
   Lung cancer deaths                                                                No. of deaths9


   Observed (0)                                                                     305

   Expected on the basis of:

       Nonsmoking non-asbestos workers (E-j)                                            4.4
       Smoking non-asbestos workers (E?)                                              57.5
       Nonsmoking asbestos workers (E3f                                              35.0

   Attributable to:
       Factors other than smoking or asbestos (£••)                                        4.4 (  1.4%)
       Smoking alone (E2 - EJ                                                      53.1(17.4%)
       Asbestos alone (E3 - Ej)                                                      30.6(10.0%)
       Asbestos /smoking interaction  (0-lEj +  (E2 - E^ +  (Eg-E^j)               216.9(71.1%)


Source:  Unpublished data supplied to EPA by Selikoff (1978)
       aThe most recently published results from this study (Selikoff et al. 1979a, Hammond et al. 1979) report
        0 = 306, E.J = 4.7; E2 and E3 were not reported. We are requesting updated figures for  0, E^, E2, and E3
        from these researchers.

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had not been exposed  to asbestos  (E2)/  and  if  they had  never



smoked but had been exposed  to  asbestos (EO.   For £•,,  the  lung



cancer mortality rates of a  group  of  nonsmoking non-asbestos



workers from a large  study  (Hammond 1966) sponsored by  the



American Cancer Society (ACS) were used.  For  E2/  the rates for



smokers in the ACS study were used.   The  rates of  the nonsmoking



colleagues of the smoking asbestos insulaton workers were used to



derive En*



    The results, summarized  in  Figure 5,  are nearly identical to



the estimates derived by Lloyd  (1979)  using published data  from



the same study and a  different  method of  derivation. Less  than



2% of the lung cancer deaths among the  cigarette-smoking  asbestos



workers were attributable to causes other than smoking  and



asbestos exposure; over 70%  were the  result of some sort  of



interaction between the effects of the  two  agents.   The most



important implication is that approximately 81% of  the  lung



cancer deaths could have been prevented if  none of  the  men  had



been asbestos workers and about 88% could have been prevented if



none had been smokers.  Thus, from a  preventive standpoint, the



impacts of smoking and asbestos exposure  on lung cancer risk were



approximately equal in this  group  of  workers.
                               -47-

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00
I
                                                           Smoking
                                                           alone
                                                           (17.4%)
                                                                           Asbestos
                                                                           alone
                                                                           (10.0%)
                                                      Asbestos-smoking
                                                         interaction
                                                           (71.1%)
                                                                                          Unknown factors
                                                                                             (1.4%)
                          Figure 5.  Proportions of Lung Cancer Deaths Attributable to Known and Unknown
                                   Factors in a Group of Cigarette-smoking Asbestos Workers

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    Smoking may also be an  important  factor  in  increasing  an
individual's susceptibility to asbestosis.   Although  asbestosis
occurs in persons who smoke and  in  those  who do  not smoke,  (e.g,
Berry et al. 1979, Hammond et al 197.9), Frank (1979)  reported
that asbestos insulation workers with  a history  of cigarette
smoking had an asbestosis mortality rate  2.9 times higher  than
that of workers who had never smoked  regularly.   In addition,
several morbidity studies have found  that clinical and  diagnostic
signs of asbestosis in asbestos workers are  more prevalent  among
smokers than nonsmokers (Langlands et  al.  1971,  Weiss 1971, Weiss
and Theodos 1978, Harries et al. 1975, Ayer  and  Burg  1978,
Mitchell et al. 1978, Rossiter and Berry  1978, Berry  et al.
1979).
    Because none of these morbidity studies  included  a  comparison
group of persons who smoked, but who  had  not been occupationally
exposed to asbestos, the "polyvalent"  (Becklake  1973) or
nonspecific nature of many of the .diagnostic signs of asbestosis
(i.e., signs that can be produced either  by  smoking or  by
exposure to asbestos) could not be taken  into account.
Consequently, the mortality study (Frank  1979) provides the
strongest evidence that smokers are at greater risk of  asbestosis
than nonsmokers under similar conditions  of  asbestos  exposure.
    Data from this mortality study also suggest  that  there may be
a greater risk of pleural mesothelioma among cigarette  smokers
exposed to asbestos than among nonsmokers  similarly exposed
(Selikoff 1977a).  As shown in Table  12,  the rate of  pleural
mesothelioma mortality among the smokers  was more than  twice the
                               -49-

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                                            Table 12. Mesothelioma Mortality Rates in a Group of

                                               Asbestos Insulation Workers, by Smoking History
                                                                           Mesothelioma deaths/10,000 person-years
                               Smoking history
                                                                            Pleura!                 Peritoneal


,                           Never smoked regularly                             1.6                     7.1
Ul
^                           Cigarettes                                          3.8                     7.3

                            Pipe or cigar                                       9.7                    11.3

                            Unknown                                          2.5                     3.7



                        Source: Selikoff (1977a).

-------
rate among the nonsmokers.   (There  is  no  evidence  that  smoking,
by itself, can cause pleural mesothelioma.)   In  contrast,  the
peritoneal mesothelioma mortality rates were  very  similar  for
both cigarette smokers and nonsmokers.  The rates  in  Table  12
were not adjusted for age or duration  of  asbestos  exposure,  but
they suggest that reevaluation of the  conclusion that pleural
mesotheliomas "occur with equal  frequency among  smoking  and
nonsmoking asbestos workers" (IARC  1977)  would be  worthwhile.
The high mortality rates from both  pleural and peritoneal
mesothelioma among workers who smoked  only pipes or cigars  are
also worthy of note.  Unpublished data supplied  to EPA  by
Selikoff in 1978 indicate that this  small group  of workers  also
had a very high asbestosis mortality rate.  Although  the possible
effect of smoking on the risk of pleural  mesothelioma should be
explored, it is not likely that  this effect (if  any)  will  be
found to be nearly as large as the  effect of  smoking  on  the  risk
of asbestos-induced lung cancer.
         b.   Age
    The highly active nature of  school children  and their
physical characteristics generate concern that,  under similar
circumstances, their degree of actual  exposure to  asbestos may be
greater than that of adults  (Kane 1976).  Because  children
generally are more active than adults, they have a higher
breathing rate.  They also inhale relatively  more  often  through
the mouth than through the nose.  Consequently,  more  fibers would
be inhaled and fewer would be trapped  by  the  nasal hairs and
mucosa.  Young children are shorter  than  adults  and their mouths
                               -51-

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and noses are closer  to  the  floor.   Therefore,  they are likely to
inhale higher concentrations of dust that  is  stirred up from the
floor.  Children also have a greater remaining  life span,  during
which the chronic effects of asbestos  exposure  can  become
manifest.
    It has also been  suggested  that  children  may be more
biologically susceptible than adults to  carcinogens, including
asbestos (Kotin 1977, Wasserman et al. 1979).   Kotin (1976)
stated that "...in the induction  of  cancer,  it  is the very young
that is always the most  susceptible."  Other  observers (Doll
1962, Cole 1977), hold the issue  to  be far from settled.   Kotin
(1979) reflected the  uncertainty  by  observing more  recently that
"special biological susceptibility has not been demonstrated"  for
children exposed to asbestos.
    One epideraiologic study  and one  experiment  with rodents shed
some light on this question  with  regard  to pleural  mesothelioma.
After examining the incidence of  this  cancer  in an  epidemiologic
study of a group of asbestos textile workers, Peto  (1979)  stated
that "the incidence 30 years after first exposure appears  to be
much the same irrespective of age at first exposure."  The
incidence rates were  not provided in his report;  nevertheless, if
the annual incidence  is not  affected by  age at  first exposure,
then persons exposed  earlier in life experience higher lifetime
risk.  Consistent results were reported  in the  experiment  with
rodents by Berry and Wagner  (1976),  who  injected  crocidolite into
the pleurae of two groups of rats:   one  at age  2  months and  the
other at age 10 months.  In  the group  exposed at  the earlier age,
                               -52-

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40% developed mesothelioraa; in  the  latter  group,  the  incidence
was only 19% (0.005 < p < 0.01,  two-tailed  chi  square  test).
    Neither of these studies could  evaluate the age-dependent
decline in the respiratory clearance  of  fibers  that occurs  in
humans, at least among smokers  (Cohen et al.  1979), and  possibly
among nonsmokers (Wanner 1977)  as well.  This decline  in
clearance capacity might greatly increase  the proportion of
inhaled fibers that reach the pleura.  Therefore,  the  possibility
cannot be ruled out that pleural tissue  in  young  persons may  be
more susceptible but, because of the  relatively unimpaired
respiratory clearance in these  individuals,  less  severely exposed
than pleural tissue in older persons.
    The two studies discussed above apply  solely  to pleural
mesothelioma, which is only one  of  the hazards  of  asbestos
exposure.  The empirical relationship of age  at first  exposure  to
the risk of other asbestos-induced  diseases remains an unexplored
subject.
              c.   Fiber size and type
    A great deal of research and discussion has been devoted  to
possible variations in risk posed by  durable  fibers differing in
size and chemical composition.   Because  these factors  are not
expected to play a major role in the  assessment of risks due  to
asbestos exposure in schools (see part d,  Summary  and
Conclusions, below), they are treated only  briefly here.
    The primary research relating fiber  size  to carcinogenic
potency applies only to pleural  mesothelioma, and  it  involves the
direct injection or implantation of fibers  into the pleurae of
                               -53-

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rats.  These studies strongly suggest  that  fibers  of  certain
sizes are more potent in producing mesothelioma  than  other-sized
fibers of identical or different chemical composition (Stanton
and Layard 1978; Stanton 1973; Stanton et al.  1977; Smith  et  al.
1969; Wagner et al. 1970, 1973 and 1977; Smith and Hubert
1974).  As a whole/ this research indicates  that fibers  less  than
1.5 microns in diameter and between 5  and 60 microns  long,
regardless of chemical composition, are  likely to  be  more
carcinogenic in the pleura than shorter  or wider fibers.   The
evidence is not sufficient, however, to  label  fibers  with
dimensions falling outside this range  (especially  short, thin
fibers) noncarcinogenic.
    Fiber size also helps to determine the ability of inhaled
fibers to reach the pleura.  Because the airways of the  lung
diminish in size as they branch outward, longer  fibers are  more
likely to become deposited on the ciliated surfaces of the  upper
airways than shorter fibers (Dement and  Harris 1979).  This early
interception of longer fibers may account for  the  autopsy  finding
of a higher percentage of longer fibers  in the lung tissue  than
in the surrounding pleura among persons  with asbestos-related
disease (Sebastien et al. 1979b).  Additionally, longer  fibers
are less readily cleared from the lung than  shorter fibers,
especially from the alveoli: the small,  saclike  pouches  that
terminate the airways of the lungs (Morgan 1979).  Thus, fiber
size is an important factor in the transport of  inhaled  fibers.
    Evidence of variation in toxicity  according  to the chemical
composition of asbestos fibers is less firm.   There are  some
                               -54-

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indications of slight differences  in  toxicity  among  the  various
types of asbestos (Acheson and Gardner 1979),  but  these
differences may result in part from the different  fiber  size
characteristics of the asbestos types.
    There is no evidence that the  fiber size distributions  to
which the epidemiologically studied insulation workers were
exposed differed substantially from the distribution of  sizes  of
fibers released from asbestos materials in  schools.   In  addition,
all asbestos fiber types found in  schools  (e.g., chrysotile,
amosite, crocidolite) are carcinogenic.  Consequently, separate
consideration of the health effects of the  individual
mineralogical types or fiber sizes of asbestos in  this assessment
is not warranted.
              d.   Summary and conclusions
    Smoking greatly increases the  risk of asbestos-induced  lung
cancer.  Although asbestos causes  lung cancer  in both nonsmokers
and smokers, smokers exposed to asbestos have  a greater  risk of
developing this disease than would be expected by  adding the
separate effects of smoking and asbestos exposure.   Smokers also
may be at a higher risk of asbestosis than  nonsmokers with
similar asbestos exposure.  Current data on the possible
influence of smoking on the risk of asbestos-induced pleural
mesothelioma are not persuasive one way or  the other. In
estimating the risk of lung cancer from exposure to  asbestos in
schools, smokers and nonsmokers will  be considered separately
when appropriate data become available from the insulation
workers study.  Current evidence indicates  that most of  the
                               -55-

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increase in lung cancer risk among  a  group  of  smokers


occupationally exposed to asbestos  could  have  been  prevented


either by their never having been exposed to asbestos  or by their

never having smoked.


    Although children may be more susceptible  to  the effects  of


asbestos exposure than adults, little  firm  evidence is available


to determine the differences in risk.   The  longer remaining life

expectancy of children compared with  that of adults is the  only


factor that can be  incorporated into  quantitative risk estimates.


    Experimental evidence strongly  suggests that  fibers of


certain sizes that  reach the pleura,  regardless of  chemical


composition, are more potent in producing mesothelioma than


fibers of other sizes.  The use of  data from a study of asbestos

insulation workers  for quantitative risk  estimates  (see Section


III, Part D) should avoid any major uncertainties that might
                                                           *
otherwise have been presented by this  finding.  Because there are


no data indicating  that the fiber types or  sizes  to which the


insulation workers  were exposed were  substantially  different  from


those present in schools, the types and sizes  in  both  settings

will be assumed to  be similar.


    C.   Exposure Assessment


    This section assesses the amount  of asbestos  that  inhabitants

of schools containing friable asbestos materials  are being


exposed to by applying current data on airborne asbestos


concentrations in various types of  buildings to the situation in

schools.  The results are a quantitative  estimate of exposures to


the "prevalent" level of asbestos in  schools and  a  qualitative
                               -56-

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description of exposures to  "peak"  levels.   A  description  of  the
methods used to make the quantitative estimates  and  a  discussion
of how closely the estimates apply  to schools  are  included.
    The' prevalent concentration of  airborne  asbestos fibers  is
the one present most of the  time  in areas  of activity  in
buildings.  Peak concentrations are those  resulting  from specific
activities such as damage to or repair of  asbestos-containing
materials, and they generally are high,  localized, and of  short
duration.  For our purposes, prevalent levels  are  those
determined by monitoring areas and  taking  measurements of
asbestos concentrations over long periods  of time, and peak
levels are determined by taking measurements of  concentrations
resulting from specific activities  over  short  periods  of time.
    Because area monitoring data  are the only  consistent data
currently available on concentrations of airborne  asbestos fibers
in buildings and because these data are  not  likely to  include
peak concentrations systematically, only exposure  to prevalent
levels of asbestos in schools can be estimated quantitatively.
The area monitoring data do  not include  peak concentrations
systematically for two reasons: (1)  peak releases  occur
sporadically; (2) peak concentrations are  limited  to very  small
areas.  Only if continuous area monitoring were  being  conducted
at the same time as and very near a specific peak  release  would
the monitoring data reflect peak  exposure  concentrations.  In
addition, the possible mechanisms by which asbestos  is dispersed
in buildings also preclude a quantitative  estimate of  exposures
at peak levels, as explained below.
                               -57-

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         1.   Asbestos Dispersion Mechanisms
    The concentration of airborne asbestos  fibers  is  determined
by how quickly fibers enter the air and by  how quickly  they  are
removed.  In buildings containing friable asbestos-containing
materials, fibers can be released from these materials  and enter
the air in several ways  (Sebastien et al. 1978, Nicholson et al.
1978a, Sawyer and Spooner 1978).  Mechanisms of fiber release
such as disturbance of the building materials by air  currents
will release fibers over a wide area and thus an elevate the
prevalent concentration.  Other mechanisms  of release such as
cutting the materials will release a large  amount  of  fibers
locally and over a short period of time and, thus,  cause peak
fiber concentrations (up to several thousand times  higher than
prevalent concentrations).  In addition, fibers that  have been
removed from the air by  settling or by impacting on surfaces
(i.e., desks, light fixtures, and floors) can be resuspended in
air either diffusely or  in the form of peak releases  by
activities such as dusting, sweeping, maintenance  work, etc.
    Fibers released during peak episodes eventually become widely
dispersed, and are either removed slowly (over periods  of hours
to days) from the air by settling or impacting on  surfaces or are
removed when ventilation exchanges indoor and outdoor air.   This
wide dispersion also elevates the prevalent concentration.   Table
13 gives airborne asbestos fiber concentrations that  were
measured in various buildings (Sawyer and Spooner  1978).  The
measurements include those of peak concentrations  produced by the
peak release of fibers directly from asbestos materials (for
                               -58-

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example, 2f, g, and h in Table 13) and as a result of



resuspension (for example, 2c, d, e, i, and j in Table 13).



         2.   Estimate of Prevalent Exposures



    The prevalent exposure levels in schools containing  friable



asbestos materials were estimated by averaging the asbestos



concentrations measured in various buildings.  The exposure



estimates were based on data from a study by Sebastien et al.



(1978) of several buildings in Paris.  These data, which are



given in Table 14, were not taken in a way which would represent



the contribution of peak episodes of exposure.  The choice of



which specific measurements of asbestos concentration within a



building to use in exposure estimates depended on certain



assumptions as to what the measurements would represent.  Three



different assumptions were made to give three different  estimates



of prevalent exposure (Table 15) that are applicable to  all



buildings containing accessible friable asbestos materials.  A



discussion of how these different assumptions apply to exposure



in schools and why the data of Sebastien et al. (1978) were used



to make these estimates is given below.
                               -59-

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Table 13. Optics I Microscope Analysis of Airborne Asbestos Fiber Concentrations in Various Buildings
      Sampling conditions or situation
Mean counts   ND. of
  If/cm"*)    samples
Standard
deviation
     1. University dormitory, UCLA.
          Exposed friable surfaces, 98% amosite.
          General student activities

     2. Art and Architecture Building. Yale
          University. Exposed friable ceilings,
          20% chrysotile.

       a.    Ambient air, City of New Haven

       Fallout
       b.    Quiet conditions

       Contact
     0.1
  0-0.8
  (range)
c. Cleaning, moving Looks in stack area
d. Relamping light fixtures
e. Removing ceiling section
f. Installing track light
g. Installing hanging lights
h. Installing partition
Reentrainment
i. Custodians sweeping, dry
j. Dusting, 'dry
k. Proximal to cleaning (bystander exposure)
General Activity
3. Office buildings. Eastern Connecticut. Exposed
friable ceilings, 5 - 30% chrysotile.
• Custodial activities, heavy dusting
4. Pnvfite homes, Connecticut.
Remaining pipe lagging (dry)
amosrte and chrysotile asbestos
5. Laundry: contaminated clothing, chrysotile

6. Office building, Connecticut. Exposed sprayed.
•ceiling, 18% chrysotile.
Routine activity

Under asbestos ceiling
Remote from asbestos ceiling
7. Urban grammar school. New Haven. Exposed
ceiling, 15% chrysotile asbestos.
Custodial activity: sweeping, vacuuming

8. Apartment building. New Jersey; heavy
housekeeping. Tremolite and chrysotile
9. Office buildings. New York City
Asbestos in ventilation systems

Quiet conditions and rountine activity
15.5
1.4
17.7
7.7
1.1
3.1

1.6
4.0
0.3
0.2


2.8


4.1
0.4



79s

99s
403


643*


296a

2.5-200*


3
2
3
6
5
4

5
6
J ~v
36


8


8
12



3

2
1


2


1




6.7
0.1
8.2
2.9
0.8
1.1

0.7
1.3
0.3
0.1


1.6


,1.8-5.8
(range)
0.1-1.2
(range)


40-110
(range)




186-1,100
(range)
c.


0-800
(range)

      Source:  Sawyer and Sponner (1978)

      aNanograms/cubic meter.  Determined by electron microscope.

                                          -60-

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I
Ot
                                   Table 14. Measurements of Asbestos Concentrations in Several

                              Paris Buildings Used to Estimate Prevalent Exposure Levels of Asbestos
Building8
Ground floor of
research building "A"'
Rooms in research
building "A"
"B" hangar
"C"
"H" .
"K" railroad
station (open walls)
n» tt
"O"
Sampling sites
Parking lots,
laos, workshops
Libraries, labs
workshops
Workshops
Dining room
Labs, workshops
Parking lot
(open walls)
Mail room
Laboratory
Mean cone.
(ng/m3)
215
55
70
29
23
16
20
38
Max. cone.
(ng/m3)
750
630
490
29
130
24
34
62
Individual samples
(ng/m3)
751,518,19,2,0.6,0.
630,460,420,225,106.
48,46.37,31.28,15,15
14,13.9,7.6,6,(21 measurements
less than 5 ng/m3)
492,65,30,24,7,6,5,2,1
28.8
134,23.14.12.11,6,5,2,1
24,12,11
34,18.17,12
62,13
i
           Source: Sebastien et al. 1979.

           aDesi(jnations are those used by the authors.

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                                             Table 15. Estimated Prevalent Exposure Levels of Asbestos
                                       (Applicable to all buildings containing exposed friable asbestos materials)
                                               Assumptions used in                         Predicted concn.

                                                making estimates                              (ng/m^)


                                       I.   Mean for a building represents
                                             the prevalent level                                     58
o>
•^                                    II.    Maximum for a building
                                             represents the prevalent level                         270

                                     III.    Average of the  few highest
                                             concentrations for all buildings
                                             represents the prevalent level                         500

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    Estimate I is the mean of  the mean  asbestos  concentration  in
each building (the mean of column 3,  Table  14).   For  each
building, this estimate gives-equal weight  to  each  measurement of
the airborne fiber concentrations but overall  Estimate  I gives
greater weight to individual measurements  in buildings  where many
measurments were taken (e.g. building A).   An  accurate  estimate
of population exposure would require  that each measurement be
weighted according to the number of people  exposed  at that
concentration.  Estimate I approximates this by  using the  mean of
the means rather than the mean of all measurements.   The
measurements listed in Table 14 were  made  in areas  where
activities similar to school activities take place, and,
therefore, they represent the  asbestos  concentrations that occur
in activity areas in schools.  However,  they are  not  accurately
weighted according to the distribution  of school  populations.
    Estimate II in Table 15 is the mean of  the maximum
concentrations of asbestos measured in  each building  (the  mean of
column 4, Table 14).  The Agency believes this estimate gives
more weight to areas of maximum human activity because  it  is
likely that areas where the maximum asbestos concentrations are
measured are areas of maximum  activity.  This  hypothesis is
supported by data which show that human activity  can  increase
airborne asbestos concentrations by 50  to 200  times (Sebastien et
al. 1979a).  The major limit to using estimate II is  that  there
is no way to verify that the highest  measurements were  obtained
in the areas of greatest human activity.  The  overall average
exposure to asbestos in buildings containing exposed  friable
asbestos materials is likely to be between  estimates  I  and II.
                               -63-

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    Estimate III in Table 15  is  the  mean  of  une  four  highest
maxima in column 4 of Table 14  (750,  630,  490, and  130  ng/m3)..
Estimate III may account for  the  future deterioration of  friable
asbestos materials now  in place.   Sebastien  et al.(1978),
describe the sites where the  value used in estimate III were
obtained as areas where asbestos  materials have  deteriorated.   In
the future, friable asbestos  materials  that  are  now in  place
likely will deteriorate through  damage  or  be subjected  to
maintenance activities  such as  cutting  and drilling.  The
assumptions in using estimate III to predict future exposure are
that deteriorated material is responsible  for the  few highest
measured levels, that all materials  eventually will deteriorate,
and that when materials do deteriorate, they will  cause
significantly high prevalent  asbestos concentrations.   There are
insufficient data to document these  assumption-s.
    These three estimates lead  to the conclusion that the  current
average exposure to asbestos  in  buildings  containing  accessible
friable asbestos materials^/  is  not  likelv to be less than 58
ng/m , it may be as high as 270  ng/itr,  and,  in the  future,  it may
become as high as 500 ng/m .  Of  course,  these are  estimates of
exposure to the prevalent concentration.   Peak exposures  add
significantly to the overall  exposure of  specific  groups  of
people.  For example, as shown  in Part  D,  janitors  can  easily be
exposed to an average level of  asbestos fibers that is  more than
twice the prevalent level.
6/  Materials not enclosed  by  a  solid  partition  such  as  a
    suspended, or false,  ceiling.
                               -64-

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    The estimates are based on data from  the  Sebastien  et  al.
(1978) study because this study meets the  following  three
criteria: (1) applicability of the data to  exposure  in  schools;  •
(2)  consistency, reliability, and accuracy  of  the measuring  and
sampling techniques; and (3) adequate data  on  "control"
buildings.   The study meets these three criteria because:   (1)
the areas and materials studied are similar to those  in U.S.
schools (see discussion below); (2) the measurements  were  made by
transmission electron microscopy (the only  technique  which is
accurate for environmental sampling at low  concentrations  -  see
below), the measurements were checked by  statistical  quality
control techniques, and the samples were  taken over  relatively
long time periods (5 days); and (3) comparisons were  made  with
outdoor air and with a significant number of  buildings  that did
not contain asbestos materials.  Data on  asbestos concentrations
in U.S. buildings from a study (Nicholson et  al. 1978a) that did
not meet these criteria were carefully assessed and  used to
verify that the results of the Sebastien et al. study are
consistent with data for U.S. buildings (Logue 1980).
    The specific data selected from the study  of Sebastien et al
represent the exposure situation in U.S.  schools.  These data are
measurements of asbestos concentrations in  buildings  with
accessible friable asbestos materials.  Enclosure of  the material
(for example, with a suspended ceiling) may greatly  reduce
exposure, and different enclosures will have  different effects.
Too little data are available to determine  whether the types of
                               -65-

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enclosures in the buildings sampled by  Sebastien  et  al.  are
similar to those in U.S. schools.  Therefore,  exposure estimates
are too high for buildings in which enclosed or covered  asbestos
materials are present.
    Friable materials were selected for the estimates because
they represent the materials of greatest  concern.
    Asbestos levels in buildings containing friable  asbestos
materials are significantly greater than  asbestos  levels in
buildings which do not contain asbestos surface materials.  A
statistical study (Levy, 1980) showed that there  is  less than  a
5% probability that chance alone caused this difference.
Therefore the Agency concludes that the presence  of  friable
asbestos caused the difference.  In addition to elevated
prevalent exposure in these buildings,  peak exposures are likely
to. be frequent when friable materials are present  because these
materials are easily damaged.
    The selection of friable materials  for the estimates does  not
mean that non-friable materials do not  make a  significant
contribution to both prevalent and peak asbestos  exposures.  The
statistical study cited above, however,  shows  that there are
insufficient data at this time to say whether  the  observed
elevation of asbestos concentration in  buildings  containing non-
friable asbestos materials (see Table 16) is caused  by the
presence of these materials or due to chance alone.  Peak
exposures from non-friable asbestos materials  can  also occur if
                               -66-

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 Table 16.  Comparison of Mean and Maximum Levels of Airborne Asbestos in Buildings Containing
                         Friable and Nonfriable Asbestos Materials3'0
Buildings containing
Buildingb
Mean concen
friable materials
Max. concen.
airborne asbestos . airborne asbestos

A-G
A-St
B
E
H
K
L
O
A-Ct
C
D
(ng/m3)
220
55
70
29
23
16
20
20
13
0.1/
3.0
(ng/m3)
750
630
490
29
130
24
34
62
28
0.2
5
Building
Buildingb
containing nonfriable materials
Mean concen.
airborne asbestos

F
T
S
G
1
J
P
Q
R


(ng/m3)
19
21
0.1
1.7
0.4
3.2
3.2
0.83
8.6


Max concen.
airborne asbestos
(ng/m3)
40
68
0.1
2.8
2.1
7.1
7.1
1.3
12


Source: Sebastien et al. (1978)
aAII asbestos measurements in buildings without asbestos-containing materials were less than 5 ng/m3.
"Building notations are those of Sebastien et al.
cBoth enclosed and exposed asbestos-containing materials are included in this table.

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they are cut or drilled.  However,  such materials  are  far  less
susceptible to damage than are friable materials.
    The application of estimates based on  various  types  of French
buildings to U.S. schools is possible/ because  (1)  the materials
containing asbestos and, as shown by  comparing  Table 1 and Table
14, the uses of areas in the French buildings are  the  same as
those in U.S. schools; and (2) the  French  data  on  asbestos levels
in rooms with friable materials are not statistically different
from comparable data  (Nicholson et  al. 1978a) for  U.S. buildings
(Logue 1980).  Asbestos-containing  materials in France and the
United States are also similar in that the French  processes for
applying these materials (Sebastien et al.  1978) are similar to
the processes used in the United States (cf. Section II  of this
document).  In both cases, "friable"  coatings are  produced by
mixing the asbestos with binders after the material leaves the
spray nozzle.  In addition, both French and United States  data
reveal that most of the airborne fibers detected are chrysotile
and that the accessible asbestos material  is located in  similar
places.
    The use of transmission electron  microscopy techniques is
necessary for the identification and  measurement of asbestos
fibers outside of the workplace.. The optical microscopy
techniques, especially the phase contrast  microscopy technique
recommended for use in the workplace  (HEW  1976), are not suitable
for measurement of low airborne asbestos concentrations  in
buildings because the phase contrast  technique  cannot distinguish
between asbestos and many other fibers and, because the
                               -68-

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measurement accuracy is limited by  the  small  number  of  fibers
counted (HEW 1976).  At low fiber concentrations  a larger
proportion of the fibers will be non-asbestos  fibers and,  thus,
the ability to distinguish asbestos  fibers  from other fibers
becomes important.  For this reason,  transmission electron
microscopy, supplemented when necessary with  electron diffraction
to specifically identify asbestos,  is the only tool  suitable for
measuring airborne asbestos concentrations  outside of the
workplace. -L-
3.  Description of Peak Exposures
    Significant "peak" releases of  asbestos fibers will occur  and
cause the total exposure of an individual to  be higher  than the
estimated prevalent asbestos concentration.   Students,  teachers,
and school administrators will only  occasionally  encounter peak
exposures.  Janitors, custodians, and maintenance workers  will
encounter them more frequently.  Available  data are  insufficient
to estimate the frequency with which either group would encounter
peak exposures.
7/  Because both asbestos and non-asbestos fibers are counted,
    measurements made by phase contrast microscopy are expected
    to be higher than those made by electron microscopy.  This is
    found in the results of Byron, Hodson and Holms,  (1969).
    They measured fiber concentrations in schools (and other)
    buildings by the phase contrast microscopy technique and
    found that 11 of 18 schools with sprayed asbestos had
    concentrations greater than .005 fibers/cm .  This
    corresponds to (using 30 fibers/ng as the conversion) to
    about 200 ng/m  which is much higher than what Sebastien et
    al. (1978) found by electron microscopy (see Table 14).
                               -69-

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    Peak exposures occur during episodes of damage  to  friable
asbestos materials, repair or renovations  involving  the
materials, cleaning operations in buildings that  contain  the
materials, or maintenance work performed in spaces  that enclose
the materials (e.g., in crawl spaces over  false ceilings).  Peak
exposures that occur during damage episodes will  affect all
                              i
occupants, including students, teachers, and  school
administrators; in general, however, maintenance, janitorial,  and
custodial personnel will experience peak exposures most
frequently.  The total exposure of these groups to asbestos may
be much greater than their exposure to  the prevalent level.
    D.   Risk Assessment
         1.   Procedure for Estimating  Risks  of Premature Death
              a.   Outline of the Risk  Estimation Procedure*
    The number of people expected to die prematurely from
exposure to asbestos in school buildings can  be predicted within
limits from available epideraiologic data.  The initial step in
the risk assessment procedure is to choose the most  appropriate
epidemiologic study or studies to serve as the basis for making
the estimates.  The key criteria are that  a study contain a
quantitative characterization of cumulative asbestos exposure  and
that the study population exhibit an increase in  risk of
premature death following asbestos exposure.  A statistical model
of the relationship between cumulative  asbestos exposure and
subsequent increases in risk (dose-response model) is then
established.  The cumulative asbestos exposure of the building
occupants is estimated using the prevalent asbestos
                               -70-

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concentrations (see Part C above),  the  number  of  persons  likely
to be exposed and the probable duration of exposure  for those
persons.  Combining the exposure estimates with  the  dose-response
model allows risk estimates to be expressed  as the number of
premature deaths expected to occur.   In this analysis, such
estimates are made for each of three  groups  of school occupants:
students, teachers and administrative staff, and  custodians and
maintenance workers.  Because of the  necessary assumptions and
uncertainties in quantitative risk  assessment, three risk
estimates will be presented for each  group:  the minimum,  maximum,
and most reasonable predictions of  the  increases  in  carcinogenic
risk expected to result from asbestos exposure in schools.
    Although asbestos exposure in schools likely  will also
produce signs of asbestosis that are  not severe enough to result
in death, this risk cannot be estimated quantitatively with
currently available data (see Section III, Part B above).  In
addition, available mortality studies do not reflect the
increased incidence of cancer because some cancers (e.g.,  larynx
cancer) frequently are treated with success.   These  necessary
omissions lead to underestimates of the risk of developing
nonfatal asbestosis and treatable cancers.   This  risk assessment
is further restricted to a consideration only  of  exposure  to
prevalent levels of asbestos in schools.  Increased  risks
resulting from exposure to peak levels  have  not been included in
the overall risk estimate because the frequency of these
exposures is unknown.
                               -71-

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              b.   Selection of  the Underlying  Study.
    The epidemiologic study selected  to  be  the  basis  for making
quantitative estimates of  the risk of  premature death  from
exposure to asbestos in schools  is a  large  study of  asbestos
insulation workers reported most recently by  Hammond  et al.
(1979) and Selikoff et al.  (1979a).   In  the original  report of
mortality among these workers,  the men were described  as
"building trades insulation workers"  who were chosen  for their
"asbestos exposure of limited extent  and intensity"  (Selikoff et
al. 1964).
    The data that will be  used  from this ongoing study concern
12,051 men who were employed in  asbestos insulation  work for at
least 10 years (Hammond et al.  1979,  Selikoff et al.  1979a).  The
results for this group are restricted  to the  time commencing at
the 20th year after each worker's first  exposure, each worker's
20th year since first exposure.   The  diseases caused  by asbestos
exposure appear after an induction period-- a minimum  length of
time following initial exposure  that  must elapse before risk
begins to increase.  In this study and in others (Peto 1978,
Berry et al. 1979, Seidman et al. 1979), the  minimum  induction
period for mortality from  asbestos-induced  diseases generally has
been reported to be 10-20  years.  The  use of  data that cover only
the period that starts X20 years following  first exposure allows
for the induction of asbestos-induced  tumors.   The results,
therefore, pertain only to the  time subsequent  to each worker's
20th anniversary of employment,  the time at which he was at
increased risk of dying from the diseases that  are hazards of
asbestos exposure.
                               -72-

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    The mortality experience of the 12,051 workers  was  observed
during the 10-year period from January  1, 1967,  to  December  31,
1976 (the "follow-up period").  As each of these  workers  was
actively employed on January 1, 1967, and had  reached the 20-year
point from initial exposure at some time before  the  end of the
follow-up period, each worker was exposed to asbestos for at
least 10 years.  Workers who had reached the 20-year mark prior
to January 1, 1967, were traced throughout the follow-up  period
(i.e., they entered observation on January 1,  1967).  Those  who
reached the 20-year mark at some time- during the  follow-up period
were followed only from that point on (i.e., they entered
observation on the date of the 20th anniversary  of  employment).
The reported increases in risk, therefore, took  place >_20 years
from initial exposure among 12,051 workers, each  of  whom
previously had been exposed to asbestos for at least 10 years.
    In addition to allowing for cancer  induction  by  providing
data restricted to the period that starts >2Q  years  from  first
exposure, the asbestos insulation workers study  has  a number of
attributes that make it uniquely suitable as a basis for
quantitative risk estimation.  No other study  combines  all of
these useful attributes:
    0    The sample of 12,051 workers surviving  >2Q  years from
         first exposure is very large,  minimizing the probability
         of chance results.
    0    Reasonable estimates of the average asbestos
         concentrations to which insulation workers  were  exposed
         are available (see Part c below).
    0    Each of the diseases identified as hazards  of  asbestos
         exposure was investigated and  was found  to  be  in excess
         (see Table 17 below).
                               -73-

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    0    The death certificates were assiduously verified with
         supplemental information (e.g., autopsy reports,
         histological specimens) in 86% of the deaths  (Selikoff
         et al. 1979a), leading to a greatly  improved  detection
         of frequently misdiagnosed mesotheliomas  (Newhouse and
         Wagner 1969, Selikoff et al. 1979a).

    0    A highly appropriate control group was used,  for which
         smoking-specific results are available (Hammond 1966).

    0    The material to which the insulation workers  were
         exposed (commercial asbestos, primarily chrysotile) was
         very similar and, in some instances, identical to the
         asbestos present in school buildings.

              c.   Asbestos Exposure Among the Insulation

                   Workers.

    The measure of exposure that will be used in this  risk

assessment is "cumulative exposure1*—the product of the average

asbestos concentration (in this study, it is expressed as

nanograras per cubic meter of air, ng/m3) times the number of

years of exposure to this concentration.  Therefore, cumulative
                                                     ^
exposure, which is expressed here in units of ng-yr/mj,

incorporates the intensity and duration of exposure into a single

measure.  This system of measuring exposure has the disadvantage

of assuming implicitly that brief, high-intensity exposure is

equivalent to extended, low-intensity exposure.  For instance, a

person exposed to 100 ng/nr for 10 years and a person  exposed to

1,000 ng/m  for 1 year would both be assigned cumulative exposure

values of 1,000 ng-yr/ra .  The influence of this assumption on

the risk estimates for cancer mortality under the linear

nonthreshold dose-response curve will be discussed later.

    During the 1940's and 1950's, when the insulation  workers in

the underlying study received the bulk of the asbestos exposure

responsible for risk increases observed during the follow-up


                              -74-

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period (1967-1976), airborne asbestos  concentrations  in  the  work
environment probably were higher than  the  concentrations  measured
in more recent years.  Because reliable monitoring  data  are  not
available for the earlier period, approximations  must be  made  on
the basis of the recent measurements and  in  light of  changing
work practices and conditions.  Nicholson  (1976)  reviewed several
monitoring studies and concluded that  "the overall  time-weighted
average exposure of United States asbestos [insulation]  workers
in the late 1960's was less than 3  f/ml"  (3,000,000 f/m3).   This
estimate, made under the assumption that  insulation workers  in
the late 1960's worked with asbestos-containing materials only
half of the time, agrees closely with  the  figure  of 4,200,000
f/ra3 derived by the National Institute for Occupational  Safety
and Health (NIOSH 1972) for full time  asbestos insulation work.
Consequently, 3,000,000 f/ra3 represents the  lowest  reasonable
estimate of .the average asbestos concentration to which  workers
in the underlying study were exposed.
    Nicholson (1976) also found that,  during  the  late 1960's,
"work practices were virtually identical  to  those of  the  past,
and ...few controls of significance were  in  use."   Nevertheless,
he identified two major changes in  the conditions of  insulation
work over the years.  First, workers in the  1940's  and 1950's
were in contact more often with insulation containing asbestos,
as opposed to insulation containing fibrous  glass and other
materials that recently have become more popular.   Second, the
asbestos content of insulation materials containing asbestos
declined by as much as one-half over the period ranging  from the
                               -75-

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1940's and 1950's to the late 1960's.  These  factors  helped  lead
Nicholson (1976)  to state that "insulators' average exposures  in
the United States during the past  years could  have ranged  from 10
to 15 f/ml" .(10,000,000-15,000,000 f/m3).  Therefore,  15,000,000
f/m3 is the highest reasonable estimate of the average exposure
level or the asbestos insulation workers.
    The most reasonable estimate lies between  3,000,000 and
15,000,000 f/m3.   If it is assumed that insulation workers  in  the
late 1960's handled asbestos one-half of  the  time, that previous
workers handled asbestos three—fourths of the  time (a  50%
increase), and that older insulation materials containing
asbestos had twice the asbestos content of newer asbestos-
containing materials, the recent average  exposure level
(3,000,000 f/m3)  can be multiplied by a factor of 3 to yield an
estimate of the earlier concentration.  This conversion yields a
"most reasonable" estimate of approximately 9,000,000  f/m3  for
the average asbestos concentration to which the workers in  the
underlying study were exposed.
    The units in which the minimum, maximum, and most  likely
average exposure levels are expressed can be converted from
fibers per cubic meter to nanograms per cubic  meter.   In a  study
conducted for the Office of Pesticides and Toxic Substances, EPA
(Versar 1980)r it was concluded that for  insulation work, a
fiber-to-mass conversion ratio of  30 f/ra  to 1 ng/m   is the best
approximation if fibers are counted by light microscopy.  This
factor is in general agreement with data  on fiber size
distributions for the asbestos industry as a whole (Dement  and
                               -76-

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Harris 1979) and for insulation work  in  particular  (Nicholson
1976).  It should be remembered that  this conversion  factor  is
rough and currently cannot be verified because  the  nature  of the
industry has changed.  It is, however, the best  available
estimate.
    Conversion of the three estimates of average asbestos
exposure for the insulation workers studied  by  Selikoff's  group
yields the following estimates:
              maximum         500/000 ng/m3
              most reasonable 300,000 ng/nr
              minimum         100,000 ng/m3
    It is important to determine  the  period  of  exposure  to these
concentrations that should be held reponsible for the  increases
in risk detected "during the observation  period  (1967  through
1976).  Asbestos-induced increases in risk do not appear until
>IQ years after exposure (Peto 1978,  Seidman et  al. 1979),  so the
attributable exposure period for  each worker in  this  risk
assessment ends 10 years prior to the time the worker  entered
observation.
         A      .   B               C                  D
          | <	> | <	10 yr	> I <	10 yr	> |
    Under the approach described  above,  A-B  (ending for  most
workers on December 31, 1956) is  the  period  of attributable
exposure.  C-D is the follow-up period,  during which  all exposure
is presumed to be "wasted" in the sense  that it  is  not
responsible for increases in cancer risk during  the same
period.  3-C is an additional period  of  time during which
exposure  is considered to be "wasted."   If the minimum induction
                               -77-

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period for death from asbestos-induced  neoplasms  were  exactly 10
years, the greatest degree of underestimation  of  exposure  would
result from the fact that exposure during  year 3+1  ended,  not 10
years, but 13 years before year D-l  began.   The choice,  however,
of a length of 10 years for  the additional  "wasted"  exposure
period (B-C) is a conservative one.   The minimum  induction period
for mesothelioma, for instance, appears to  be  closer to  20 years
than to 10 years (Selikoff et al. 1979a).   For lung  cancer,
Peto's (1978) data show the  minimum  induction  period to  be about
15 years.  If the minimum induction  period  for these diseases
were >20 years, no relevant  exposure would  be  ignored  by choosing
10 years for the length of period B-C.
    Thus, although a certain degree  of  exposure relevant to
increased risk during the follow-up  period  (C-D)  is  likely to be
ignored under this approach, 10 years for  B-C  is  considered a
reasonable length in order to optimize  three goals:  (1)  to make
use of the published mortality data  from the insulation  workers
study; (2) to avoid attributing "wasted" exposure to increased
risk during the follow-up period; and (3)  to avoid  labeling
exposure "wasted" that actually contributed to increased risk
during the follow-up period.  The attributable exposure  period
for each of the 12,051 workers was his  period  of  employment
ending 10 years before he entered observation.  The  total  number
of years of relevant exposure for the group divided  by 12,051
yields the average exposure  period.   [Note: We are  requesting
this total from the researchers.  For the  time being,  a  figure of
20 years will be used as the mean attributable exposure  period in
the calculations.  When the  actual value becomes  available, it
will replace the 20-year figure.]

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    It was estimated above that the average exposure  level  for
the insulation workers was between 100,000 and  500,000  ng/m^,
with the most reasonable estimate being 300,000 ng/nr.  Over  a
20-year average exposure period, these figures  yield  the
following estimates of cumulative exposure:
         maximum            1.0 x 10  ng-yr/m^
         most reasonable    6.0 x 10^ ng-yr/nr
         minimum            2.0 x 10  ng-yr/m
    The three values are estimates of the average cumulative
asbestos exposure of the 12,051 workers at the  time 10  years
before observation began.  Many continued to be exposed,  but
exposure beyond that point is not thought to have contributed to
the observed increases in risk.
         d.   Increased Risk Among the Asbestos Insulation
              Workers.
    Following the 20-year induction period, the researchers
compared the observed number of deaths from specific  causes among
the 12,051 workers to the number expected on the basis  of
mortality rates in an appropriate comparison group ._^_  The
greater number of observed than expected deaths indicates
increased risk.  The results for cancer deaths  are shown  in Table
17.  The use of 95% confidence intervals for the observed number
8/  The data for the control or comparison group were obtained
    from a large study sponsored by the American Cancer  Society
    (Hammond 1966) of the age-, calendar year-, and  smoking-
    specific experience of white males with at most  a high  school
    education and a history of occupational exposure to  dust,
    fumes, vapors and gases, excluding farmers.
                               -79-

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          Table 17. Mortality Data Taken from the Study of 12,051 Asbestos Insulation
                 Workers and Used To Make Quantitative Estimates of Risk from
                                Asbestos Exposure in Schools




1
00
o
1




Cause of death

Cancer, all asbestos-
relaied sites
Lung
Pleura
Peritoneum
Larynx, buccal
cavity, pharynx
Esophagus
Kidney
Colon-rectum
Stomach
Expected
deaths (E|)a

145.8
81.7
0
0
7.5
5.1
8.5
30.5
12.5
Observed
deaths (Oj)

692
397
61
109
21
17
15
54
18
95% Confidence
limitsb
Lower
641.4
358.9
46.6
89.5
13.0
9.9
8.4
40.6
10.7
Upper
745.6
438.1
78.4
131.5
32.1
27.2
24.7
70.5
28.4
Statistical
significance
level0

< 0.001
<0.001
<0.001
< 0.001
< 0.001
<0.001
0.027
< 0.001
0.084
Source: Hammond et al. (1979)

aNumber of observed deaths based on death certificate information only, except for pleura! and
 peritoneal mesothelioma. Supplemental information was used for these two cancers. This
 [procedure was recommended by Hammond et al. (1979).

^Method of Bailar and Ederer (1964), assuming a Poisspn distribution of observed deaths. Values
 from Documunta Geigy (1970), some by linear interpolation.

cMethod of Bailar and Ederer (1964), assuniing a Poisson distribution of observed deaths. One-tailed
 test, values from Molina (1942).

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of deaths is a way of accounting  for  the  role  of  chance  variation
in the results.  In comparisons with  the  expected number of
deaths, the minimum risk estimate  is  provided  by  the  lower 95%
confidence limit for observed deaths,  the maximum estimate by the
upper 95% confidence limit for observed deaths, and  the  most
likely risk estimate by the actual number of deaths  observed.
    The measure of increased risk most useful  for predicting
premature mortality from asbestos exposure  in  schools  is the
difference between the observed (  Oj_) and  expected  (  Ej)
numbers of deaths from the cancers related  to  asbestos exposure
divided by the total number of deaths expected from  all  causes
(ET = 1,148.0)  (Hammond et al. 1979).  This measure  is  the
fraction of all expected deaths that  were "in  excess"  because of
the asbestos exposure.  It is called  "lifetime risk"  (LR)  by the
EPA Carcinogen Assessment Group, Office of  Research  and
Development, EPA, and is defined as follows:   LR= (Oi-Ei)/ET.   If
the study were carried out until all  were deceased (actually,
only 16% of the 12,051 workers died during  the observation
period),  (Qj_-Ej_) would equal the total number of "excess,"  or
premature deaths.
    In using lifetime risk, as defined above,  as  the measure of
increased cancer risk in this assessment, certain assumptions
must be made.  First, it must be assumed  that  the estimate of
lifetime risk when only 16% of the workers  have died will  be the
same when all 12,051 have died.  Second,  it must  be  assumed  that
this estimate of lifetime risk among  persons exposed as  adults
will be indicative of the lifetime experience  of  exposed school
                               -81-

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children, who have a greater remaining period  of  expected  life
during which the effects of asbestos exposure  can become
manifest.  The use of the lifetime risk measure,  therefore,  does
not allow the greater remaining life expectancy of children  to  be
taken into account and for this reason may  underestimate risk.
    The mortality rates for each of the cancer hazards of
asbestos exposure were increased among the  insulation workers
(Table 17).  The data for the separate causes  of  death can be
combined in order to estimate overall lifetime risk for all
asbestos-induced cancers:
    maximum »      (745.6 - 145.8)/l,148.0  = 0.522
    most reasonable =  (692 - 145.8)/l,148.0   =  0.476
    minimum =      (641.4 - 145.8)71,148.0  = 0.432
    The results give a most reasonable estimate that the overall
mortality rate was increased by 48% above the  expected value by
asbestos-induced deaths from cancer.  (Additional premature
deaths from asbestosis are not included here.)  The  above
lifetime risk estimates will be used to predict the  risks of
mortality from asbestos exposure in schools.
              e.   Asbestos Exposure in Schools
    In Section III, Part C, three prevalent asbestos
concentrations were estimated for school buildings.  Estimates  I
(58 ng/m3) and II (270 ng/m3) were developed to reflect current
concentrations and Estimate III (500 ng/m ) to reflect
concentrations in the future, as the building  materials
deteriorate.  The risk assessment concerns  exposures over the
next 30 years.  Consequently, Estimates I and  III  will be used  as
                               -82-

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the minimum and maximum future concentrations,  respectively.
Estimate II, although developed as a maximum estimate  of  the
current concentration, will be used as  the most reasonable
estimate of future concentrations.
    Three groups of school building occupants  are  considered:
students; teachers and administrative staff; and custodians and
maintenance workers.  It was estimated  in Section  II that
approximately 3,000,000 students, 222,000 teachers  and
administrative staff, and 23,000 custodians and maintenance
workers are occupying schools that contain friable  asbestos
materials (See Section II above).  These numbers of exposed
school occupants at risk of death from  asbestos-induced cancers
need to be adjusted to reflect the number expected  to  die before
a minimum period of time from first exposure has elapsed.
Adopting the same 20-year minimum induction period  as  in  the
insulation workers study and assuming that the  average student is
first exposed at age 12 and the average adult  school occupant at
age 30, national life tables (NCHS 1978) can be used to estimate
that 2.2% of exposed students and 5.9%  of exposed  adults  will die
before 20 years have elapsed from first exposure.   The estimated
number of school occupants at risk, then is 3,000,000  - 2.2% =
2,934,000 persons exposed while attending school,  222,000 - 5.9%
= 208,900 teachers and administrative staff, and 23,000 - 5.9% =
21,600 custodians and maintenance workers.  The average remaining
service time for the buildings is approximately 30  years  (See
Part II above).  Therefore, the average cumulative  exposure for
the adult occupants is equal to the prevalent  asbestos
                               -83-

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concentration times 30 work years.l^ For  students,  it  is  the
prevalent concentration times 15 work years.  These  estimates  are
shown in Table 18.
    The calculations were made under the assumption  that each  of
the current school occupants will be exposed for the entire 30-
year period that the buildings will  remain  in service.  Although
this assumption is not technically correct  (as students graduate
and adults leave their positions, others will replace them)/ as
long as the exposed populations continue to average  3,000,000,
222,000, and 23,000, respectively, the risk estimates will not be
affected.  This is because of the nature of the cumulative
exposure measure (1,000 ng-yr/m  resulting  from either  10 years
at 100 ng/m3 or 1 year at 1,000 ng/m3) and  the linear
nonthreshold dose-response model (cumulative exposure of 1,000
persons to 1,000 ng-yr/m  yielding the same number of premature
deaths as cumulative exposure of 100 persons to 10,000  ng-yr/m3).
              f.   Selection of the  Extrapolation Method
    Once the most suitable epideraiologic study of asbestos
workers has been chosen for the risk assessment, a method must be
selected for using the results of the study to predict  the
9/  A work year is assumed to be made up of 50 weeks at 5 days a
    week and 8 hours a day.  A school year is assumed to be made
    up of 33 weeks at 5 days a week and 6 hours a day.  /
    Therefore, 2 school years equal one work-year:
    33 weeks x 5 days x 6 hours = 0.5.
    50 weeks   5 days   3 hours
                               -84-

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                              Table 18. Estimates of Cumulative Asbestos Exposure in Schools3
o
Cumulative exposure levels (ng-yr/m J) for:
i
CO
en
1


Population group
Students
Teachers, administrative
. staff
Custodians, maintenance
workers
Average
number exposed
2,934.00
208,900
21.600
Minimum
estimate of risk
870
1,740
1.740
Most reasonable
estimate of risk
4,050
8,100
8.100
Maximum
estimate of risk
7,500
15,000
15,000
aAssuming 30 work years of exposure per adult and 15 work years of exposure per student. See discussion on page 92.

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increase in carcinogenic risk that will  result  from  asbestos
exposure in schools.  The prediction  is  made  by extrapolating^0^
from the exposure levels experienced  by  the asbestos insulation
workers to the lower levels of asbestos  to which  school  occupants
are exposed.  A dose-response curve is developed  to  describe  the
relationship between cumulative asbestos exposure and subsequent
increases in cancer risk.  From this  curve, predictions  of
increased risk can be derived that correspond to  cumulative
exposure levels lower than those for  which epidemiologic data  are
available.  Because the empirical relationship  of dose to
response at these exposure levels is  unknown, criteria must be
established for selecting the most appropriate  dose-response
curve.
    Two general types of evidence can be used to  show that a
dose-response curve or model is unsuitable:   (1)  knowledge of  the
biological processes that influence the  degree  to which  inhaled
asbestos increases carcinogenic risk, and (2) the dose-response
data available from epidemiologic studies or  experiments with
laboratory animals.  The first type of information,  often called
"pharmacokinetics," includes a carcinogen's "absorption,
distribuiton, reactions with cellular components, and
elimination," as well as its interaction with physiologic
10/ If, as in most risk assessments, it is assumed that the dose-
    response curve passes throught the point corresponding to
    zero exposure and zero increase in risk, the prediction is
    technically an interpolation.  Nevertheless, the conventional
    term, extrapolation, will be used here.
                               -86-

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mechanisms of activation and detoxification  (Gehring  et  al.
1977).  This kind of information, if available,  can lead  to
inferences about the shape of the dose-response  curve at  low
doses, including the possibility of a threshold  dose  below which
the risk of cancer would not be increased  (Cornfield  et  al.
1977).  EPA is unaware of information about  the  pharmacokinetics
of asbestos that would enable such inferences  to be drawn.
    The second type of evidence, dose-response data from
epidemiologic and toxicologic studies,  is  available for  asbestos-
induced carcinogenicity.  Table 19 shows the results  of
statistically "fitting" several dose-response  models  that have
been developed for cheraicas carcinogens to data  from  two  studies:
an epidemiologic study of asbestos workers (Henderson and
Enterline 1979, see also Figure 1-B) and an  experiment with rats
(Wagner et al. 1974).  By the usual and widely accepted  criterion
that a p-value greater than 0.05 or 0.10 indicates an adequate
fit (Remington and Schork 1970), none of the models can  be
dismissed on the basis of these studies.
    Current scientific evidence alone cannot be  used  to  select
the most appropriate dose-response curve for this extrapolation
because none,of the curves in Table 19  can be  ruled out on the
basis of pharmacokinetics or available  dose-response  data.  Of
these curves, however, linear nonthreshold regression (see, e.g.,
Figure 1) usually provides the highest  predictions of increased
risk and there is no strong scientific  reason  to prefer any of
                               -87-

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                                                       le 19. Dose-respite Curves Applied to Two Studies of
                                                       Asbestos Exposure and Carcinogenic Response
                                                                                      Goodness-of-f it p-value

                       Dose-response curve       Reference                   Epidemiologic study9*"     Experiment with rats"

                       One-hit                  Brown (1976)                    0.58                         °-°°
                     .  Multi-hit                 Van Ryzin and Rai (1980)         0.42                         °13
                       Multi-stage (1 stage)       Crump (1980)                    0.58                         011
                       Multi-stage (5 stages)      Crump (1980)                    0.53°                        °°fjC
                       Linear regression          Neter and Wasserman              0.87                         0.10
                                                (1974)


                       "Henderson and Enterline (1979)

                       bWagneretal. (1974)

                       cThe results of a Monte Carlo simulation

,                      "The "p" values calculated from the chi square (X 2) statistic are based on the difference
oo                      between the observed (Oj) and the expected (Ej) counts in the ith dose group. The
^                      degrees of freedom equal number of dose levels-1-(number of parameters estimated).

                                                      X2  = E (O--E-)2/E-


                       eln the epidemiologic study, each measure of response concerns a group of people with a
                        unique age distribution; hence, the "background" mortality rates will differ among the
                        groups. To fit models with this type of data, it is necessary to adjust the observed response
                       to what they would be if there were a common "background" rate. The risk attributable
                        to the carcinogen is calculated from Abbott's equation:

                                                    P = "close  ""control*' *-control*

                        The adjustment to common "background" is done by recalculating the observed response,
                       pdose- as p' dose •  Where P' con|ro| represents the common "background" rate:

                                                          p'      — P/1  P'       \ +  P'
                                                        ' r  dose  m-r control'    r control

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the dose-response curves that yield  lower  estimates  of  increased
risk.  Consequently, the Agency has  chosen to  take the  most
prudent course with respect to public health by  using a linear
nonthreshold dose-response curve to  extrapolate  from the  asbestos
exposure levels experienced by the  insulation  workers to  the
lower levels of asbestos to which school occupants are  exposed.
         2.   Risk Estimates for School Building Occupants.
    Figures from Tables 17 and 18 and the.  preceding  discussion
are summarized in Table 20.  They are arranged in  the way that
yields minimum, most reasonable and  maximum estimates of
increased risk for school building  occupants.
    When the linear nonthreshold model is  used,  calculation of
predicted risk levels is fairly simple.  For instance,  as shown
in Table 21, the minimum lifetime cancer risk  for  school  children
would be:
    (0.432 x 870 ng-yr/m3)/(1.0 x 107 ng-yr/ra3)  =  3.8 x 10~5.
    Multiplying this figure by the  number  of students yields  the
minimum estimate of premature deaths:
    (3.8 x 10 ~5) x (2,934,000) = 111.
                               -89-

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I
vo
o
I
                 Table 20. Summary of Cumulative Exposure and Lifetime Risk Estimates To Be Used in


                              Quantitative Risk Assessment of Asbestos Exposure in Schools
Estimates leading to:
Minimum
Population group ™k estimate
Insulation workers 1.0 x 10'
Students 870
Adult schools occupants 1,740
Insulation workers 43.2
Most reasonable
risk estimate
O
Cumulative exposure (ng-yr/m );
6.0 x 106
4,050
•
8,100
Lifetime cancer risk (%)
47.6
Maximum risk
estimate
2.0 x 106
7.500
15,000
52.2

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Table 21. Quantitative Risk Estimates of Mortality from Exposure to Asbestos in Schools
Lifetime risk
o , Most
Population group Minimum reasonable
2.934.000 students 3.8 ;< 10~5 3.2 x 10~4
208.900 teachers, t- ,,
administrative svaff 7.5 x 10"° 6.4 x 10~*
21.600 custodians, K -
maintenance workers 7.5 x 10~° 6.4 x 10"^
• -
Premature deaths
Most
Maximum Minimum reasonable Maximum
2.0 x 10~3 111 960 5.868
3.9 x 10~3 16 142 814
3.9 x 10'3 2 15 84
Totals 129 1,117 6,766

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    The results of this and similar calculations  ara  shown  in
Table 21.  A total of approximately 100  to  7,000  premature  deaths
are. anticipated to occur as a result of  exposure  to prevalent
concentrations of asbestos in schools containing  friable  asbestos
materials over the next 30 years.  The most reasonable  estimate
is approximately 1,000 premature deaths.  About 90% of  these
premature deaths are expected to occur among persons  exposed as
school children.  The remaining 10% include teachers, custodians,
and other adult occupants of the buildings.  The  most reasonable
estimates represent extrapolations of approximately four  orders
of magnitude from the exposure levels experienced by  the
insulation workers.
    The risk estimates in Table 21 are subject to further
refinement.  For instance, the influence on risk  of the greater
remaining life expectancy of children compared with that  of
adults has not yet been incorporated into the assessment.   In
addition, when supplemental information  requested from  the
investigators who conducted the insulation  workers study  is
supplied, it will alter these estimates  to  some degree.   The
information requested is:
    0    the total number of person-years of exposure accumulated
         by the 12,051 workers up to the time 10  years  before
         they entered observation;
    0    the number of person-years of observation and  the  number
         of observed and expected deaths from lung cancer,
         asbestosis, and pleural raesothelioma by  smoking  history;
    0    the number of observed and expected deaths due to  cancer
         of the colon separate from those due to  cancer of  the
         rectum.
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    This additional information, with  the possible  exception  of
the smoking-specific data for lung cancer,  is  not expected  to
have a major effect on the overall results  of  the risk
assessement.  At present, an assumption  is  implicit  that  the
distribution of smoking habits among exposed school  occupants
will be the same as among the insulation workers.
    It is important to emphasize that  the risk estimates  in Table
21 concern only a portion of the total adverse impact on  health
expected to result from asbestos exposure in schools.  The  less-
than-fatal effects of asbestos exposure  on  lung  function  and  the
number of cases of certain types, of cancer  that  may  be treated
successfully (e.g., larynx cancer) are not  included  in this
quantitative risk assessment.  The substantial but  unquantifiable
risks resulting from peak exposures also are absent  from  the
assessment.
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IV.  IDENTIFICATION OF FRIABLE ASBESTOS-CONTAINING  MATERIALS  IN
     SCHOOLS
    A.   Introduction
    In order to control the release or  resuspension  of  asbestos
in schools or other types of buildings/  it  is  necessary to
determine whether asbestos is, in  fact,  present  in  the  bulk
building materials.  This determination  can  be made  by  examining
building records and by analyzing  samples of the materials.
Records will not establish conclusively  that asbestos is  not
present in a building, as they may be incomplete or  there may
have been a substitution (e.g., of asbestos  for  nonasbestos
fibers) of the components in the material that was applied.  The
magnitude of the risks involved makes it necessary  to take
additional, more extensive steps such as sampling/analysis to
ensure the accurate identification of friable  asbestos-containing
materials.
    To locate friable materials, it is  necessary to  visually
inspect the steel support beams, columns, ceilings,  and walls  of
all areas of the school.  Asbestos-containing  materials also may
have been applied to hidden areas, such  as  those above  a
suspended ceiling, and they must be checked.   Inspectors  should
direct particular attention to boiler rooms  and  other equipment
areas, in view of the frequent use of asbestos as insulating
material.
    Procedures for inspecting buildings  and  taking  samples of
friable materials and guidelines for establishing the presence of
asbestos in these materials are described in two recent EPA
publications (EPA 1979b and EPA 1980, respectively).
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    3.   Sampling
    A sample of friable material can be obtained  by penetrating
the depth of the material with a small canister or jar or  by
dislodging the material with a knife.  An  amount  equal  to  2
tablespoons is sufficient for analysis.  Proper sampling requires
that each sample container be tightly sealed, wiped clean  with a
damp cloth, and labeled.  The label should be recorded by  the
sampler (EPA 1979b).
    Samples must be taken in a manner that will provide a
representative indication of the composition of the material.
The amount of asbestos  in the friable asbestos-containing
materials on a building surface may vary.  If the material is
homogeneous in appearance and was applied  at one  time/ the amount
may not vary greatly over one surface area.  From three to seven
samples may be needed,  however, to establish whether  asbestos is
present and, if so, the approximate percentage that is present.
EPA recommends that 3 samples be taken for homogeneous surfaces
                        2
that are up to 1,000 ft / 5 samples for surfaces  that are  between
1,000 and 5,000 ft  , and 7 samples for surfaces that  are >5,000
ft2 -(EPA 1980).
    A random selection  of sampling sites is necessary to
eliminate the bias  that may result from taking samples from
convenient locations.   Representative sampling can be achieved by
extracting material from different places  within a sampling area
(close to walls, at joints, etc.).  A more involved method for
the random selection of sample sites (EPA  1980) involves the use
of a random number  table and a diagram of  the area to be sampled.
                               -95-

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    Friable material is disturbed during  the  sampling  process,
and asbestos fibers, if present, may be released.   Release  of  and
consequent human exposure to asbestos can be  minimized by  taking
samples when the area is not in use and limiting  the number of
persons present, lightly spraying water on  the  area to be  sampled
to discourage dust formation, holding the sample  container  away
from the face, and wet cleaning the area  if any pieces are
dislodged and fall to the floor.
         C.   Analysis
    Three analytical methods can be used  to identify asbestos
fibers in bulk materials.  The first, polarized light  microscopy
(PLM), uses the different refractive indices, birefringence, and
other optical crystallographic properties of  asbestos  minerals to
distinguish them from nonasbestos ones.   PLM  also characterizes
and identifies other fibers such as glass fibers  and cellulose.
The second method, x-ray diffraction (XRD), uses  the unique
diffraction pattern produced when x-rays  strike any crystalline
material to identify specific asbestos minerals.   The  third,
electron microscopy (EM), uses electron diffraction or energy-
dispersive x-ray analysis to identify asbestos  fibers  by
examining the structure of individual -fibers.
    EPA's Guidance Manual on Asbestos Analytical  Programs  (SPA
1980) recommends PLM as the method of choice  for  determining
asbestos in suspect material and XRD as a backup  technique  to
confirm the PLM analysis.  Although electron  microscopy can be
used, it is not recommended, because only very  small quantities
of sample can be analyzed at one time and the analysis of
multiple samples is prohibitively expensive.

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    The EPA Environmental Monitoring Systems  Laboratory,  Research
Triangle Park, North Carolina, has prepared and  currently is
field testing interim PLM and XRD analytical  protocols  to be
followed in identifying asbestiform minerals .in  bulk  samples.
The protocols clarify and refine the guidance  originally  offered
in Appendix H of the Guidance Manual.  They have  been circulated
to laboratories currently participating  in the Technical
Assistance Program.  An Asbestos Particle Atlas  with  color PLM
photomicrographs has been developed by McCrone Research
Institute.  The Atlas is available from  Ann Arbor Press.
    EPA has identified and complied a list of  laboratories that
analyze bulk samples for asbestos using  PLiM.   This list is based
in part on the laboratories' successful  participation in  a
proficiency analytical testing program.  A report on  this testing
program will be available in September,  1980.  Copies of  the  list
can be obtained from EPA by calling the  following toll-free
number:  800-344-8571, extension 6892.
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V.  CONTROL OF ASBESTOS IN SCHOOLS
    This section presents information on  the steps  that can be
taken to control exposure to asbestos in  school buildings once
friable asbestos-containing materials have been identified.
    EPA has published guidance materials  on the corrective
actions that can be taken in schools and  other buildings  if
asbestos-containing materials are found to be damaged or
deteriorating.  Long-term solutions to the release  of asbestos
fibers from these materials are removal,  encapsulation, or
enclosure.  Removal eliminates the source of contamination,
enclosure (with a barrier such as a suspended or false ceiling)
reduces the likelihood that incidental contact with the asbestos-
containing material will occur, and encapsulation  (with an
effective sealant) reduces the likelihood that fibers will be
released into the building environment.
    Exposure to asbestos in buildings also can be  controlled to
some extent by a number of other actions, most of  which are aimed
at reducing physical contact with asbestos-containing surfaces.
These actions simply interrupt the process by which asbestos
fibers enter building air.  Asbestos fibers enter  a school
environment from friable asbestos-containing materials as a
consequence of:
    (1)  disturbance of the material during maintenance or
         renovation operations, implementation of  the long-term
         corrective actions described above, and vandalism;
    (2)  fallout encouraged by normal activity in  the building;
         and
    (3)  resuspension of settled fibers caused by  normal activity
         or custodial dusting or cleaning.
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    Usually, asbestos enters the air as a result of physical
contact with asbestos-containing material.  Contact can cause
significant amounts of fibers to be released  to the air,
resulting in airborne concentrations that frequently exceed
industrial standards (Sawyer 1977).
    Loosely compacted friable materials are more likely to
release fibers than tightly bound materials.  When a friable
material was brushed by hand to simulate mild damage, fiber
counts as high as 3.3 f/cm3 were measured as  far away as 10 feet
from the site of the damage (Nicholson et.al. 1978a).  In
contrast, counts of 0.2 f/cm  were noted when a cementitious
material was brushed (Table 17 in Nicholson et.al.).
    Repair, renovation, or maintenance of buildings may bring
about the highest airborne concentrations of airborne fibers,
because these activities disturb asbestos-containing materials
directly.  Sanding or cutting asbestos-containing solid materials
during construction or repair produces the greatest release of
fibers.  Incidental contact that occurs when other maintenance
chores (e.g., installing a lighting unit) are performed can lead
to significant release.  In addition, damage  to the material from
vandalism, maintenance work, or, simply, deterioration can
increase the rate of fiber release by fallout (Sawyer 1977).  In
schools, there is the additional opportunity  for damage of
friable materials by students.  Whether it is the result of
normal school activity (such as throwing a ball around a
gymnasium) or acts of vandalism, damage caused by students can be
significant.
                               -99-

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    Small amounts of asbestos can  fall  spontaneously  from
ceilings or walls/ building up the airborne  fiber  concentration
over time.  Low harmonics and vibrations  caused  by machinery  and
other sources also can increase  the release  of  fibers.   Once  a
wall or ceiling is damaged, it can shed  fibers  without
significant further disturbance.   These  fibers  can accumulate
around a room and be continually resuspended any time there  is
movement of the air.  Accumulation of asbestos  fibers caused  by
fallout can be significant.
    Finally, the resuspension of fibers  that have  been  released
can continue to cause asbestos exposure.   Cleaning or other
maintenance work or the movement of people through an area can
cause settled fibers to be resuspended.   Suspended ceilings can
hide the accumulation of fibers  until maintenance  work  causes the
suspended ceiling to be disturbed; this  could result  in the
release of a large amount of fibers to  the air  (Sawyer  1977).
Custodial services such as sweeping and  dusting  also  can elevate
fiber levels by disturbing material that has collected  on floors
and other surfaces.  Asbestos, fibers tend to stay  suspended  in
the air for a long time; for smaller fibers,  this  time  may be on
the order of days.  When they do settle  out,  the fibers can
easily be resuspended.  They do  not diffuse  as  a gas  does;
rather, they tend to be confined to a given  area.
    Exposure to asbestos can be  controlled to some extent by
reducing the physical contact of individuals with  friable
asbestos-containing materials.   Sawyer  reported  on the  beneficial
effects of wet cleaning, wet handling during maintenance, and
barrier systems in inhibiting the  movement of fibers  in a
                              -100-

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building.  The simple rearrangement of  schedules  so  that  direct
work on asbestos-containing material will occur when  the  building
is not in use and provision of workers  with  respirators also  can
reduce inhalation of asbestos.  Regular wet  cleaning  of building
surfaces can remove accumulated fallout, thus  reducing the
resuspension of asbestos.  Sawyer reported that wet  cleaning
reduced fiber concentrations due to custodial  activity from 4.0
f/cm  (before control) to 0.3 f/cm  .  Wet cleaning is
particularly effective in reducing  the  exposure of the person
doing the cleaning.
    General exposures throughout the building  also might  be
reduced somewhat as a result of wet cleaning,  although no studies
have been done to show the effectiveness of  regular  wet cleaning
per se on the building environment.  Unless  care  is  taken in
disposing of any fibers collected during either wet  or dry
cleaning, fibers will remain available  to be resuspended  in
building air.
    Sawyer reported that during removal operations, wetting bulk
asbestos-containing materials with water containing  wetting
agents reduced mean fiber counts to 8.1 f/cm3, compared with  the
mean count of 82.2 f/crn3 that was calculated for  dry
conditions.  [Nicholson et al. (1978a)  reported fiber counts  of
up to only 1.78 f/cra  during wet removal of  asbestos-containing
materials in a New Jersey school.]  Sawyer also demonstrated  that
fiber levels dropped more quickly when wet methods were used.
    The migration of fibers to non-work areas  can be  inhibited by
barriers.  When removing asbestos in a New Jersey school,
Nicholson et al. isolated the work area with plastic  barriers.

                              -101-

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Fiber counts outside the work area ranged from 0.01 to 0.03
f/cra3,  but counts within the removal area ranged from 0.02
(during wetting) to 1.78 f/cm .
    Vacuum cleaners equipped with high-efficiency particulate
absolute (HEPA) filters can collect asbestos dust.  Sawyer showed
that, whereas dry dusting of shelves and books in a library
raised fiber counts to 4.02 f/cm^, use of HEPA filters raised
counts to only 0.4 f/cm .  Wet wiping the shelves produced a
count of 0.2 f/cra .  Household and normal industrial vacuums
without HEPA filters cannot collect asbestos fibers.
                              -102-

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