United States
Environmental Protection
Agency
June 1969
Pesticides and Toxic Substances (TS 799i
The ABC s
Of Asbestos
In Schools
    1361

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Introduction

• When is asbestos a problem?
• What should my school and
  school district be doing about
  asbestos?
• What can I do to help?
This pamphlet, developed by the
U.S. Environmental Protection
Agency (EPA) in conjunction with
the National Parent Teacher Asso-
ciation (PTAi and the National
Education Association (NEA), can
help parents and teachers answer
questions and learn the facts
about  asbestos in  schools. It also
outlines the responsibilities of
school boards and other school offi-
cials to protect school children and
employees from possible exposure
to asbestos.

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Aa   Bb  Cc   Dd   Ee   Ff   G
  The Asbestos Issue
           sbestos fibers can
           cause serious health
           problems. If inhaled,
           they can disrupt the
  normal functioning of the lungs.
  Three specific diseases —asbesto-
  sis, lung cancer, and another
  cancer known as mesothe-
  lioma —have been linked to as-
  bestos exposure. These diseases
  do not develop immediately
  after inhalation of asbestos
  fibers; it may be 20  years or
  more before symptoms appear.
   In general, as with cigarette
  smoking, the more asbestos
  fibers a person inhales, the
  greater the risk of developing
  an asbestos-related disease. The
  most severe health problems
  from asbestos exposure  have
  been experienced by some work-
  ers who held jobs  in industries
  such as shipbuilding, where
  they were exposed to very high
  levels of asbestos  in the air.
  These employees worked di-
  rectly with asbestos materials
  on a regular basis as a part of
  their jobs. Much uncertainty
  surrounds the risk from expo-
  sure to low levels of asbestos
  fibers.
   Nevertheless, the risk of
  school children being exposed
to even low levels of asbestos is
a concern. Acting on this con-
cern, Congress passed the As-
bestos Hazard Emergency Re-
sponse Act (AHERAi in  1986 to
protect school children and
school employees from exposure
to asbestos in school buildings.
This pamphlet describes key
parts of these new federal asbes-
tos requirements for schools.

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     What Exactly

     Is Asbestos?

              sbestos is a mineral
              found in certain types
              of rock formations.
              When mined and proc-
     essed, it takes the form of very
     small fibers which are usually in-
     visible to the naked eye. A typical
     asbestos fiber is 1,200 times
     smaller than a strand of human
     hair. These individual fibers are
     generally mixed with a material
     which binds them together so that
     they can be used in many differ-
     ent products. Because the fibers
     are so small and light, they can re-
     main in the air for many hours if
     they are released from asbestos-
     containing material. This in-
     creases the chance that someone
     will inhale them.
       Asbestos became a popular  com-
     mercial product because it is
     strong, won't burn, resists corro-
     sion, and insulates well. Its com-
     mercial use in the United States
     began in the early 1900s. when it
     was used as insulation in steam
     engines. Since then asbestos has
     been used to create about 3,000 in-
     sulation, fireproofmg and other
     products.  The peak years of asbes-
     tos use in schools were from
     World War II until the 1970s.
when several major kinds of asbes-
tos materials were banned be-
cause of growing concern about
related health effects.
Where  Is

Asbestos

Likely to  Be

Found?

         PA estimates that
         there are asbestos-
         containing materials
         in most of the nation's
approximately 107.000 primary
and secondary schools. Asbestos is
most commonly used in schools as
insulation and in building materi-
als. It has also been used in floor
and ceiling tile, cement pipe, cor-
rugated paper pipe wrap, acousti-
cal and decorative insulation, pipe
                                3

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  Aa   Bb  Cc  Dd   Ee   Ff  G
and boiler insulation, and spray-
applied fireproofing. The flufYy
white substance you may find
above a dropped ceiling, for exam-
ple, is one type of spray-applied
material. The amount of asbestos
in these products varies widely,
from 1 to 100 percent, depending
on the use. Pipe and boiler insula-
tion typically contains more asbes-
tos than other building materials.
The precise amount of asbestos in
a product cannot always be deter-
mined from labels —since most
products used in the past were
not labeled—or by asking the
manufacturer. Instead, positive
identification of asbestos requires
analysis of samples by a qualified
laboratory.
When Is
Asbestos a
Problem?
         ntact and undisturbed
         asbestos materials gen-
         erally do not pose a
         health risk. Asbestos
materials, however, can become
hazardous when, due to damage or
deterioration over time, they re-
lease fibers. If the fibers are in-
haled, they can lead to health
problems.
  The potential for an asbestos-
containing material to release fi-
bers depends primarily on its con-
dition. If the material, when dry,
can be crumbled by hand pres-
sure—a condition known as "fri-
able"—it is more likely to release
fibers, particularly when dam-
aged. The fluffy spray-applied as-
bestos fireproofing material is gen-
erally considered "friable." Pipe
and boiler insulation materials
can also be "friable," but they
continued on p. 6
                           *«•»**««"***»***«»*

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        What Has the  Government
        Done about Asbestos?
                 he federal govern-
                 ment has been regu-
                 lating asbestos for a
                 number of years.
        Any material which contains as
        little as 1 percent asbestos is
        subject to federal asbestos regu-
        lations. Progress is being made
        to limit the uses of asbestos and
        to identify substitute materials.
        EPA is now considering ways to
        phase out the use of other as-
        bestos materials.
          On October 22, 1986. Presi-
        dent Reagan signed AHERA
        into law. The Act required EPA
        to develop regulations creating
        a comprehensive framework  for
        dealing with asbestos in public
        and nonprofit private elemen-
        tary and secondary schools. The
        regulations were published on
        October 30, 1987.
          The AHERA schools rule re-
        quires all public school districts
        and private schools, known as
        local education agencies or
        LEAs, to inspect all school
        buildings for both friable and
        nonfriable asbestos; to develop
        plans to manage asbestos in
        schools; and to carry out the
        plans in a timely fashion. The
        rule also provides an  opportu-
nity for parents, teachers, and
other school employees to be-
come familiar with and involved
in their school's asbestos man-
agement program. School offi-
cials are required to notify par-
ent, teacher and employee
groups about asbestos-
related activities.
  EPA also has established an
asbestos-in-schools assistance
program. Through its Headquar-
ters office in Washington, D.C..
and ten Regional offices. EPA
provides direct technical assis-
tance to help thousands of
school officials and workers un-
derstand asbestos issues. EPA
makes funds available to train
asbestos professionals, to assist
states in developing asbestos
programs, and to help schools
comply with the federal asbes-
tos regulations. Since 1985,
EPA also has provided loans
and grants to help financially
needy public and private schools
correct serious asbestos hazards
through the Asbestos School
Hazard Abatement Act
(ASHAA* program. Finally.
EPA publishes informational
pamphlets for the public.

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 Aa   Bb  Cc  Dd   Ee  Ff   G
often are enclosed in a protective
casing which prevents fiber re-
lease unless the casing is dam-
aged. Some materials which are
considered "nonfriable," such as
vinyl-asbestos floor tile, can also
release fibers when sanded, sawed
or otherwise disturbed. Materials
such as asbestos cement pipe can
release asbestos fibers if they are
broken or crushed when buildings
are  demolished, renovated or
repaired.
What Are the  Proper
Methods for  Managing
Asbestos?
         ost asbestos-containing
         material can be prop-
         erly managed where it
         is. In fact, asbestos
that is managed properly and
maintained in good condition ap-
pears to pose relatively little risk
to students and school employees.
Accordingly, the AHERA schools
rule rarely requires the removal of
asbestos materials.
  Proper asbestos management be-
gins with a comprehensive inspec-
tion by qualified, trained and ex-
perienced inspectors, accredited
through an EPA or state-approved
training course. Inspecting the
condition of asbestos materials —
initially with AHERA-accredited
inspectors and at least semi-annu-
ally with trained custodial or
maintenance staff—is extremely
important so that changes in the
material's condition, such as dam-
age or deterioration, can be de-
tected and corrected before the
condition worsens. Sometimes nor-
mal school or maintenance activi-
ties can damage asbestos material
and cause fiber release, particu-
larly if the material is "friable."
A thorough initial inspection and
regular surveillance can prevent
accidental exposure to high levels
of asbestos fibers.
 The methods (see page 7), in
AHERA terminology, are asbestos
"response actions." The last three
methods of response actions-
encapsulation, enclosure, and re-
moval—and sometimes the second
method —repair—must be done by
accredited asbestos professionals.
  The final response action, asbes-
tos removal, is generally necessary
only when the material damage is
extensive and severe, and other ac-
tions will not control fiber release.
Although the AHERA schools rule
does not prohibit schools from re-

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g   Hh   li   Jj   Kk   LI   Mm   Nn
      How To
      Respond?
       Proper methods for dealing
       with asbestos are:

      • Developing and carrying out
        a special maintenance plan to
        insure that asbestos-contain-
        ing materials are kept in
        good condition. This is the
        most common method when
        the materials are in good con-
        dition at the time of initial
        inspection.
      • Repairing damaged pipe or
        boiler covering, which is
        known as thermal system
        insulation.
      • Spraying the material with
        a sealant to prevent fiber
        release —a process called
        encapsulation.
      • Placing a barrier around
        the materials, known as an
        enclosure.
      • Removing asbestos —under
        special procedures.
    ENCLOSURE

     REMOVAL.
     moving any asbestos materials.
     removal decisions should not be
     made lightly. An ill-conceived or
     poorly conducted removal can actu-
     allv increase rather than elimi-
nate risk. Consequently, all school
removal projects must be designed.
supervised, and conducted by ac-
credited professionals and should
be performed in accordance with

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 Aa   Bb   Cc   Dd   Ee   Ff  G
state-of-the-art procedures. In ad-
dition, schools may wish to hire an
experienced and qualified  project
monitor to oversee the asbestos
contractor's work to make sure the
removal is conducted safely.
  Only an AHERA-accredited
management planner —an asbestos
professional with proper training.
qualifications, and experience —is
authorized to advise school offi-
cials on which response action is
appropriate for a particular situ-
ation. The final selection of the
proper method is up to school offi-
cials after they receive the advice
of the school's accredited manage-
ment planner.
What Should  My School  &
School District  Be  Doing?
         nder the new AHERA
         schools rule, each local
         education agency
          LEA, which means
a school district or private school)
must take the following asbestos-
related actions:

  I Designate and train a person to
oversee asbestos-related activities
in the school system.

fc Inspect every school building
for "friable" and "nonfriable"
asbestos-containing building
materials.
   Prepare a management plan
for managing asbestos and control-
ling exposure in each school.
   Consult with accredited
inspection and management profes-
sionals to identify and carry out
whatever asbestos actions are nec-
essary and appropriate to protect
health and the environment. These
actions or methods must  be docu-
mented in the management plan.
   Notify the public about the as-
bestos inspection and the availabil-
ity of the asbestos management
plan for review.

W Use only properly accredited
persons to conduct inspections, to
develop the asbestos management
plan, and to carry out the appro-
priate response actions.

I Keep records of all asbestos-
related activities in the plan and
make them available for public
review.
                             8

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g   Hh   li   Jj   Kk  LI   h  'ifA
^^^                    '                         uv  4 r^1^
        What Does the  LEA
        Designated Person Do?
          School officials may choose a
        consultant or one of their own
        employees to oversee their as-
        bestos program. This desig-
        nated person must meet certain
        training requirements, and
        serves as the single point of con-
        tact for  public information
        about asbestos-related activities
        in the LEA. He or she is respon-
        sible for:
        •  Ensuring that initial asbes-
           tos inspections, reinspections
           every three years, and semi-
           annual surveillance activities
           are conducted properly by
           qualified personnel.
        •  Including results of the in-
           spection in the management
           plan.  The plan must identify
           all asbestos-containing build-
           ing materials found in
           schools and recommend ac-
           tions  for dealing with asbes-
           tos hazards.
        •  Submitting the management
           plan to the appropriate state
           agency,  designated by the
           Governor to review and ap-
           prove plans,  by October 12,
           1988  (or by May 9, 1989, if
           the school has been granted
           a deferral by the state).
Making sure that custodial
and maintenance workers re-
ceive required safety training
and information about the lo-
cation of asbestos-containing
materials in their school.
Warning labels must be
posted in all routine mainte-
nance areas, such as boiler
rooms, where asbestos-con-
taining building materials
are found.
Assuring that response
actions specified in the man-
agement plan are carried out
according to the plan's time-
tables. The regulations re-
quire that all LEAs begin to
carry out their management
plans no later than July 9.
1989.
Seeing that all asbestos
records required by the reg-
ulations are accurately
maintained.
Informing all teacher, par-
ent and employee organiza-
tions at least once a year
about the asbestos activities
in each school and about the
availability of the manage-
ment plan for their review.

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 Aa   Bb   Cc  Dd   Ee   Ff   G
When Are School
Management Plans Due?

  As noted before, management
plans originally were due to the
states by October 12,  1988. Be-
cause some LEAs have had prob-
lems complying with this dead-
line, however. Congress amended
AHERA to allow school officials to
apply for extra time to inspect
their schools and prepare manage-
ment plans. The amendment per-
mitted LEAs to ask their states
for a deferral of the October 1988
deadline. If the state granted  the
deferral, the LEA must submit its
plan to the Governor no later than
May 9, 1989. Before applying to
the state for a deferral, an LEA is
required to notify parent, teacher
and employee organizations of its
plan to file a deferral request. In
the case of a public school, the
LEA was also required to discuss
its intention to file at a public
meeting before submission to  the
state.
  Schools which sought deferrals
had to certify to the state that
they made a "good faith" effort to
meet the original October AHERA
deadline. They also had to provide
a schedule outlining significant ac-
tivities leading up to submission of
the plan by May 9, 1989. This
schedule of events must include in-
specting the school, having sam-
ples of suspected asbestos material
analyzed by a qualified laboratory,
and preparing the management
plan.
  Although your LEA may have
applied for extra time to inspect
its buildings and to prepare its
asbestos management plan, all
schools are still required to begin
putting their plans into action no
later than Julv 9, 1989.
What  Can  I
Do to Help?
          s a parent, teacher,
    i ^H service worker or other
H          school employee, the
          most important thing
you can do first is to learn about
your school's asbestos activities.
As you do so, remember that the
mere presence of asbestos in a
school doesn't necessarily mean
that the health of its occupants is
endangered. Again, asbestos that
is managed properly and main-
tained in good condition poses
relatively little risk. Federal regu-
lations do not require the removal
of all friable asbestos from schools
until the building is demolished.
In fact, during the life of the
building, other methods of dealing
with the material are often prefer-
able to removal.
  In those cases when removing
asbestos is determined to be the
appropriate decision, the work
                             10

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g   Hh   li   Jj   Kk  LI   Mm   Nn
\i^                     /
     must be done under strict controls
     by trained, qualified and experi-
     enced asbestos professionals who
     are properly accredited under
     AHERA.

     Step One: Awareness

       Your first step is to find out if
     your school has prepared or is pre-
     paring an asbestos management
     plan as required by AHERA. By
     becoming familiar with this plan,
     you will know if asbestos materi-
     als are  in the school, what plans
     the school has for managing this
     asbestos, and when these activities
     are scheduled to occur.

     Step Two:  Minimize
     Disturbance

       There are several simple things
     you can do to minimize your expo-
     sure to asbestos. The most im-
     portant one is to find out which
     materials in your school contain
     asbestos; you should be able to get
     this information from your LEA's
     designated person or from the
     school's management plan.
       Once you know where asbestos
     is, use special  care to insure that
     any day-to-day activities, such as
     repair or maintenance work, do
     not disturb the material. In fact,
     special  training is required  to par-
     ticipate in any maintenance activi-
     ties which might disturb asbestos.
     In schools, asbestos-containing
     materials can also be damaged by
student activities. For example, an
asbestos ceiling in a gym may be
disturbed if basketballs or other
objects are thrown up agam.-t it
Students and others who use the
gym should be warned to avoid
such activities.
    \
   AHERA
MANAGEMENT
 PLAN FOR
 MY SCHOOL
                   K
1
             C'-.A^.
             V«C
                    u
          ....   ^*.
                                   11

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  Aa  Bb  Cc  Dd  Ee  Ff G
 Who Is
 Responsible
 for Making
 AHERA Work?
        11 of us are responsible.
        Making the AHERA
        schools rule work to
        protect the nation's
 school children and employees is a
 joint responsibility of the LEA
 and its officials, school employees,
 parents, students, federal and
state governments, and asbestos
control professionals.
  EPA conducts compliance in-
spections of hundreds of schools
each year to make sure they are
obeying the law. The Agency is re-
sponsible for insuring that schools
comply with AHERA and it will
investigate reported violations.
Since the AHERA schools rule is
intentionally designed to involve
parent, teacher and other school
employee organizations, however,
it is important that you work with
your school to make sure that
its asbestos program is properly
conducted.
t  Stft  SCHOOL.  OFFiCiALS
 '  7  MY  PRINCIPAL.      /sfATE'
   >/MY  TANiro^S         OFPiCALS
   /MY  PARENTS
   '/ASBESTOS  EXPERTS


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g  Hh   li   Jj   Kk   LI   Mm   Nn
     Where  Can  I
     Get More
     Information?
              nder AHERA, citizens
              have the opportunity to
              become informed about
              asbestos activities in
     their schools. If you have a ques-
     tion or concern about those activi-
     ties, you should first contact your
     LEA designated person. This per-
     son knows the most about the as-
     bestos situation in your school.
     When you find out who this per-
     son is, ask him or her what steps
     your school has taken, and will
     continue to take,  to meet the re-
     quirements of the AHERA schools
     rule.
       The LEA designated person
     also can tell you which agency in
     your state government is responsi-
     ble for state AHERA activities.
     The same agency usually  is re-
     sponsible for reviewing the LEA's
     asbestos management plan. This
     LEA designated person also should
     be aware of any local asbestos
     control requirements.
       State AHERA designees also
     are a good source of information.
     These officials can help you better
     understand the AHERA schools
     rule and can answer questions
     about your  school's asbestos
     activities.
  You also can contact your EPA
regional office. There are ten EPA
regional offices around the coun-
try, and each one has a Regional
Asbestos Coordinator iRAC>.
Their addresses and phone num-
bers are listed at  the end of this
pamphlet. School  employees can-
not be penalized for contacting
EPA or the appropriate state
agency to discuss  their concerns
about a school's asbestos program.
  Local, state, and national parent
and teacher organizations are
other good sources of information
about asbestos in  schools.  Many of
these groups worked with EPA in
                                 13

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developing the new AHERA
schools rule, and some have
started their own educational ef-
forts to improve understanding of
the AHERA requirements and
proper asbestos control practices.
The addresses and phone numbers
of the national offices of PTA and
NEA are listed at the end of this
pamphlet.
  The EPA Toxic Substances Con-
trol Act (TSCA) Hotline is avail-
able to answer your questions
about the new AHERA regula-
tions and about asbestos in gen-
eral. You can obtain a variety of
asbestos guidance documents by
calling the TSCA Hotline at
(202) 554-1404.
  Finally, EPA has an asbestos
ombudsman to help citizens with
asbestos-in-schools issues, ques-
tions, and complaints. This office
can be reached through a toll-free
number at (8001 368-5888.
Regional Asbestos  Coordinators
EPA Region 1
  JFK Federal Building
  Boston, MA 02203
  (617) 565-3835
  (Connecticut, Maine,
  Massachusetts, New
  Hampshire, Rhode Island, and
  Vermont)
EPA Region 2
  Woodbridge Avenue
  Edison, NJ 08837
  (201)321-6671
  (New Jersey, New York, Puerto
  Rico, and Virgin Islands)
                             14

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EPA Region 3
  841 Chestnut Street
  Philadelphia, PA 19107
  (215) 597-3160
  (Delaware, District of
  Columbia. Maryland,
  Pennsylvania, Virginia, and
  West Virginia)
EPA Region 4
  345 Cortland Street. X.E.
  Atlanta. GA 30365
  (404> 347-5014
  (Alabama. Florida. Georgia.
  Kentucky. Mississippi. North
  Carolina. South Carolina, and
  Tennessee)
                               15

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EPA Region 5
  230 S. Dearborn Street
  Chicago, IL 60604
  (312) 886-6003
  (Illinois, Indiana, Michigan,
  Minnesota, Ohio, and
  Wisconsin)

EPA Region 6
  Allied Bank Tower
  1445 Ross  Avenue
  Dallas, TX 75202-2733
  (214) 655-7244
  (Arkansas, Louisiana, New
  Mexico, Oklahoma, and Texas)

EPA Region 7
  726 Minnesota Avenue
  Kansas City, KS 66101
  (913) 236-2835
  (Iowa, Kansas, Missouri, and
  Nebraska)

EPA Region 8
  One Denver Place
  999 18th Street, Suite 500
  Denver, CO 80202-2413
  (303) 293-1744
  (Colorado,  Montana,  North
  Dakota, South Dakota, Utah,
  and Wyoming)

EPA Region 9
  215 Fremont Street
  San Francisco, CA 94105
  (415) 974-7290
  (Arizona, California, Hawaii,
  Nevada, American Samoa, and
  Guam)
 EPA Region 10
   1200 6th Avenue
   Seattle, WA 98101
   (206) 442-4762
   (Alaska, Idaho,  Oregon, and
   Washington)
National Parent Teacher
Association

National FTA
700 N. Rush Street
Chicago, IL 60611
(312) 787-0977

National PTA
Government Relations Office
1201 16th Street, N.W.
Suite 621
Washington, DC 20036
(202) 822-7878
National Education Association

NEA
1201 16th Street, N.W.
Washington, DC 20036
Division of Government
Relations
(202) 822-7300
or
Office of General Counsel
(202) 822-7035
                              16

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           Prepared by the

U.S. Environmental Protection Agency
              The National
              Education Association
          The National Parent
          Teacher Association

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