AN EVALUATION OF THREE EPA PUBLIC
SCHOOL RISK COMMUNICATION PROGRAMS:
ASBESTOS, LEAD IN DRINKING
WATER AND RADON
Final Report
Prepared- COR
William O'Neil
Ann Fisher
U.S. EPA Office of Policy Analysis
Washington, D.C.
Under Subcontract to:
Research Triangle Institute
U.S. EPA Contract No. CR-S14767-02-0
Prepared by:
Ruth H. Chapman
Lauraine G. Chestnut
Robert D. Rowe
RCG/Hagler, Bailly, Inc.
P.O. Drawer O
Boulder, Colorado 80306
(303) 449-5515
September 18, 1990
[SCHOOL]
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ACKNOWLEDGEMENTS
Many individuals greatly enhanced the quality and enjoyment of this research. Most
importantly, we thank the nearly 900 state agency, regional EPA, and school district
personnel in 9 different states who participated in the varying stages of the research. While
not every comment from these participants could be included in the report, we have
attempted to be faithful in accurately reporting the thrust of the information provided to us.
We also thank the state school board associations in the nine states for sending out advance
notification of the district surveys.
At the U.S. EPA, we were greatly aided by William O'Neil and Ann Fisher on the overall
design and execution of the project. Program office support was provided by Jeanne Briskin,
Jeff Cohen and Peter Lassovszky in the Office of Drinking Water; Anita Schmidt and
Dennis Wagner in the Radon Office; and Barbara McCoy and Betty Weiner in the Asbestos
Office. We also thank Kate Herber of the National Association of School Boards, whose
assistance at the beginning of the study was invaluable.
Our thanks to Mike Regan of the Research Triangle Institute for his work in pre-testing the
survey instrument with school districts in North Carolina. Our in-house survey
implementation and report production were supported by Dale Willingham.
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TABLE OF CONTENTS
Acknowledgements
1.0 INTRODUCTION 1-01
1.1 BACKGROUND AND OBJECTIVES 1-01
1.2 REPORT ORGANIZATION 1-02
2.0 STUDY DESIGN 2-01
2.1 OVERVIEW OF ISSUES AND STUDY DESIGN 2-01
2.2 SELECTION OF STATES 2-03
2.3 LEARNING ABOUT THE STATE ENVIRONMENTS 2-05
2.3.1 EPA Regional Staff 2-05
2.3.2 State School Board Associations 2-06
2.3.3 State Agencies 2-06
2.4 THE SURVEYS OF LOCAL SCHOOL DISTRICTS 2-07
2.4.1 The Samples 2-07
2.4.2 Designing the Survey Instrument 2-07
2.4.3 Basic Outline of the Asbestos Oucs^jflpfl^re 2-08
2.4.4 Basic Outline of the Lead in Drinking Water/Radon
Questionnaire 2-08
2.4.5 The Survey Process 2-09
3.0 MAIL QUESTIONNAIRE RESPONSE RATES AND GENERAL
RESULTS ACROSS ALL PROGRAMS 3-01
3.1 RESPONSES TO THE MAIL QUESTIONNAIRES 3-01
3.1.1 Response Rates 3-01
3.1.2 Characteristics of the Sampled Districts 3-01
3.1.3 Who Answered the Questionnaires 3-08
3.2 TELEPHONE FOLLOW-UP 3-08
3.2.1 Telephone Response Rates 3-08
3.2.2 AUSWCr?* of Telephone Respondents 3-11
3.3 GENERAL PERCEPTIONS OF THE RISKS 3-15
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TABLE OF CONTENTS, page 2
4.0 ASBESTOS CONTAINING MATERIALS PROGRAM AND ANALYSIS 4-01
4.1 BACKGROUND ON EPA PROGRAM 4-01
4.1.1 AsbestQfj HfliZyd Emergency Response Act (AHERA) 4-01
4.1.2 The Model Accreditation Plan 4-02
4.13 Abatement 4-02
4.1.4 EPA Materials 4-03
4.1.5 firant Programs 4-03
4.1.6 Additions! Comments 4-04
4.2 STATE PROGRAMS 4-
4.2.1 Colorado 4-
4.2.2 niinrm 4-
4.23 New York 4-07
4.2.4 Ohio 4-08
4.2.5 Pennsylvania 1 4-09
4.2.6 Tennessee 4-09
4.2.7 Texas 4-10
4.3 RESPONSE FROM THE SCHOOL DISTRICTS 4-11
4.3.1 Familiarity with Regulations and Rgcprpnicndfllift.ns 4-12
4.3.2 Receipt of and Response to EPA Materials 4-12
4.33 Management P^^flS 4-16
4.3.4 Abatement Activities 4-20
4.3.5 School Expenditures for Asbestos Inspection. Planning and
Abatement 4-24
4.3.6 Overall Program Evaluation and Comments 4-26
4.4 SUMMARY AND IMPLICATIONS 4-26
5.0 LEAD IN SCHOOL DRINKING WATER PROGRAM AND
ANALYSIS 5-01
5.1 BACKGROUND AND EPA PROGRAM 5-01
5.1.1 The TiCfld COPte**8**01* Control Act 5-01
5.1.2 State Coordinating Agencies 5-02
5.13 Water Coolers 5-02
5.1.4 The EPA Manual 5-02
5.1.5 Regional Training Seminars 5-03
5.1.6 National Primary Drinking Water Regulations 5-03
5.1.7 Additional Comments 5-03
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TABLE OF CONTENTS, page 3
5.2 THE STATE PROGRAMS: LEAD IN SCHOOL DRINKING
WATER 5-04
5.2.1 Colorado 5-04
5.2.2 IdaflQ 5-06
5.23 Illinois 5-07
5.2.4 New York 5-07
5.2.5 QJiifl 5-08
5.2.6 Pennsylvania 5-09
5.2.7 South Carolina 5-10
5.2.8 Tennessee 5-11
5.2.9 Ifixas 5-12
5.3 RESPONSE FROM THE SCHOOL DISTRICTS 5-13
5.3.1 Familiarity with Regulations ftnd Recommendations 5-13
5.3.2 Receipt of and Response to EPA Materials 5-16
5.3.3 Water Coolers 5-22
5.3.4 Testing for Lead in School Drinking Water 5-22
5.3.5 Overall Program Evaluation and Comments 5-25
5.4 SUMMARY AND IMPLICATIONS 5-28
6.0 RADON 6-01
6.1 BACKGROUND AND EPA PROGRAM 6-01
6.1.1 EPA Study and Recommendations 6-01
6.1.2 EPA Materials 6-02
6.1.3 Federal Grants 6-02
6.1.4 Additional Comments 6-03
6.2 THE STATE PROGRAMS: RADON GAS 6-03
6.2.1 Colorado 6-04
6.2.2 Idaho 6-06
6.2.3 niinni* 6-06
6.2.4 New York 6-07
6.2.5 Ohio 6-07
6.2.6 Pennsylvania 6-08
6.2.7 South Carolina 6-09
6.2.8 Tennessee 6-09
6.2.9 Texas 6-10
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TABLE OF CONTENTS, page 4
6.3 RESPONSE FROM THE SCHOOL DISTRICTS 6-10
63.1 Familiarity with Regulatjnn^ gnd Guidelines 6-11
63.2 Receipt gypd, Response to EPA MfltCrifrlS 6-11
633 Testing for Radon Gas in School Buildings 6-17
63.4 MfltivflPnff an<^ Impeding Factors Regarding the Ra'don
program 6-20
6.4 SUMMARY AND IMPLICATIONS 6-24
7.0 COMPARISON ACROSS PROGRAMS AND CONCLUSIONS 7-01
7.1 COMPLIANCE DIFFICULTY AND ADDITIONAL COMMENTS
FOR ALL THREE PROGRAMS 7-01
7.2 COMPARISONS OF LOCAL SCHOOL DISTRICT SURVEY
RESPONSES ACROSS PROGRAMS 7-09
73 SUMMARY CONCLUSIONS 7-11
8.0 BIBLIOGRAPHY 8-01
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1.0 INTRODUCTION
1.1 BACKGROUND AND OBJECTIVES
The U.S. Environmental Protection Agency (EPA) has, over the last decade, become more
active in developing programs to inform the public of environmental risks and of steps that
can be taken to test for and reduce these risks. These programs are often used instead of,
or in addition to, regulations that require specific actions to be taken. Several of EPA's
efforts have been targeted toward public schools. During the past several years, and in
concert with Congressional mandates, EPA has promulgated regulations to manage asbestos-
containing materials in public schools and has developed guidelines on testing for and
remediating environmental risks associated with lead in school drinking water and radon in
public schools. An early emphasis has been placed upon reducing risks at schools because
children may be more susceptible than adults to these environmental risks, both in terms
of dose-response and in terms of total remaining years of potential exposure.
This report provides an evaluation of the EPA public school risk communication programs
for asbestos-containing materials, lead in drinking water, and radon. These programs have
consisted largely of developing and distributing written materials to aid public schools in
understanding the problems, the risks, and the steps to test for and remedy situations that
might pose potential health risks. In some cases, EPA has also developed and implemented
workshops, training sessions and provided other support. This evaluation focuses upon the
characteristics and effectiveness of the EPA materials, the EPA information dissemination
procedures, and the overall program strategies. The effectiveness of these three EPA
programs is measured in terms of how successful the programs have been at disseminating
useful information to, and motivating action on the pan of, state agencies and local school
districts.
The three programs were examined in nine different and diverse case study states. The role
of state government is critical because in each of the three programs the EPA has delegated
much of the program responsibility to the states. The case study states illustrate the many
different ways that the EPA programs have been received and implemented at the state
level and identify how different state actions affect the EPA's risk communication programs.
In each of the case study states, and for each of the three programs, there were two levels
of data collection:
1. Semi-structured interviews were conducted with regional EPA and state agency
personnel charged with program responsibility. These interviews helped to
define what, if any, state actions resulted from, or occurred in conjunction with,
the EPA programs; and helped define other characteristics of the state
RCG/Hagler Bailly. Inc.
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environment (state requirements and efforts, political circumstances, funding,
public and media pressure, etc.) that might affect the success of the EPA
programs. In addition, these key individuals provided their insights about the
EPA programs. These interviews were conducted in two waves: one each at the
beginning and the end of the research.
2. A mail survey was completed with a random sample of local school districts in
each case study state. These surveys concerned risk perceptions, public pressure,
familiarity with the relevant regulations or recommendations, familiarity with and
rating of EPA materials and programs, and status of testing and remediation
efforts. Specific attention was given to determining if the districts had received
the EPA materials, if they had used the EPA materials, and their attitudes about
EPA assistance. These surveys were conducted with the use of two survey
instruments: one covering lead in drinking water and radon, and one covering
asbestos-containing materials.
Through these steps each program was analyzed and the three programs compared. This
allowed an examination of what characteristics of the different programs enhanced or
hindered the success of these types of programs and where more effort or focus is needed.
\2 REPORT ORGANIZATION
Chapter 2 of this report provides additional detail on the hypotheses to be addressed in the
analysis and the data collection procedures. Chapter 3 provides general results applicable
to all three programs. These include mail survey response rates and analysis of the
experience and representativeness of the survey participants. Also reported are local school
district responses on how these environmental issues compare in terms of perceived health
risk and public pressure to other health issues facing public schools.
Chapters 4, 5 and 6 report, in turn, upon the program implementation and effectiveness for
the EPA asbestos-containing materials, lead in drinking water and radon public school
programs. For each program, the federal environment and EPA risk communication
strategies are summarized and the state environment is reviewed for each case study state.
Next, the results of the local school district surveys are reported and summary conclusions
provided.
Chapter 7 summarizes the findings by first comparing key results across states and programs.
This allows one to ascertain characteristics of the programs and to see which state
environments are most and least influential to the success of EPA's efforts. Summary
conclusions of the overall evaluation are also provided.
RCG/Hagler Bully. Inc
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2.0 STUDY DESIGN
2.1 OVERVIEW OF ISSUES AND STUDY DESIGN
This evaluation considers EPA's overall strategy for working with state agencies and local
school districts to reduce potential health risks in public schools from exposure to asbestos-
containing materials, lead in drinking water and radon. The strategies for these three
programs generally have been to define, to some level, the required or recommended testing
and remediation steps, and then to turn over the final program implementation to the states.
EPA has supported the states and individual school districts, to varying degrees, with
information, workshops, training, and technical assistance.
Initially, this research was to be focused upon evaluating EPA's risk communication/risk
management materials and their impact upon local school districts. For example, for each
of the three study programs, EPA has developed manuals and other materials to
communicate risk, define applicable regulations and schedules, and provide risk
management information covering testing and remediation procedures. The following
questions about the EPA materials are of interest:
I. Is the message clear, informative and complete?
2. Does it enhance knowledge about the regulations/guidelines, provide needed
information to take action, and alter risk perceptions to be more consistent with
existing knowledge? Does the EPA material lead to the required or
recommended actions?
3. How, if at all, should the message be altered to be more useful to local school
districts?
However, early analysis indicated that one key difference across the programs was the
dissemination of EPA information. As discussed in Chapters 4 through 6, materials
dissemination varied considerably across the programs, ranging from notices in the Federal
Register and mailings to each school district in the U.S. under the asbestos program, to
fliers and limited distribution of materials to state agencies under the lead and radon
programs. Because the EPA materials can be useful only if they are received, the following
questions become important:
4. Are local school districts aware of information through EPA and elsewhere, and
why or why not? What would have been done without the EPA materials?
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5. Do the different distribution methods matter?
6. What percent of local school districts actually receive the materials, and from
where?
The EPA materials and distribution methods are best considered within the context of the
overall EPA risk communication/risk management strategy employed for each program.
Following Congressional mandates, the EPA programs have ranged from having very specific
regulations, approaches and schedules under the asbestos program, to having only interim
recommendations (or guidelines) with options as to the recommended approaches and few
schedule deadlines for lead in drinking water and radon. The EPA strategy has also relied
heavily upon state implementation of the programs and, therefore, EPA's interactions with
the states is important. Also important are EPA's other support efforts, such as working
with the media, working with state agencies, funding, training, etc. Therefore, this
evaluation also considers the impact of the overall program strategies on the program
effectiveness, including:
7. How important are regulations versus recommendations, and interim versus final
guidance?
8. How do states work with, respond to, and, as a result, affect the EPA program
effectiveness? How important are variations in the state environment (political
climate, funding, agency efforts, etc.)? And how effective has EPA been in
working with state agencies?
9. What aspects of EPA's other efforts, such as press releases and funding
assistance, help or hinder the risk communication/risk management programs
and why?
To address the above issues, two complementary data collection efforts were undertaken in
nine case study states.
e Semi-structured interviews were conducted with regional EPA and state agency
personnel to define regional EPA and state agency actions and attitudes and
circumstances.
A mail survey was completed with a random sample of local school districts
concerning program materials, testing and remediation actions, attitudes and risk
perceptions, and other baseline information.
The design and focus of these data collection efforts' are discussed more fully in the
subsequent sections of this chapter.
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22 SELECTION OF STATES
To evaluate the EPA programs, a sample of states was selected to obtain, consistent with
project resources, a cross-section of several characteristics. The research team attempted to
attain:
geographic diversity sufficient to enable differentiation in geopolitical and
cultural climates;
differences in population size;
differences in levels of urbanization;
differences in known or estimated levels of risk from lead in drinking
water and radon, which might motivate differing response levels; and
differentiation in perceived initial responses to the federal mandates
and/or recommendations for these programs, thereby enabling the
research team to examine the factors that might account for these
differences.
The differences in the selected states gives a sense of the variation in state responses to
EPA programs and provides insights into what motivates and hinders state and local school
district response to the EPA programs.
State selections were finalized after discussions with representatives from EPA's Lead in
Drinking Water and Radon programs and telephone interviews with:
representatives of appropriate departments in several states;
the Executive Director of the National Association of School Boards;
representatives of several state school board associations; and
EPA regional staff.
The Asbestos program became part of the study very late in the process and, therefore, had
no direct input into state selection. The addition of the Asbestos program to the study also
resulted in a decision to conduct two separate surveys of local districts, using two different
instruments and two different samples. One of these surveys concentrated on the Lead in
Drinking Water and Radon programs; the other concentrated on Asbestos. There were two
reason for this decision. The first was simply a concern about including too much content
in a survey instrument by attempting to address all three programs in one instrument. This
would require too much information and effort; additionally, in some cases, different
individuals are in charge of different programs, which would require more "passing around"
of the instrument and lower response rates. The second reason was an assumption on the
part of the research team that the asbestos experience has had a heavy impact on many
school districts and this might unduly influence responses to the other two programs.
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Nine states were included for the Lead in Drinking Water/Radon portion of the study. Two
of these states did not have a sufficient number of school districts to enable drawing two
separate samples and were, therefore, not included in the Asbestos portion of the study.
Table 2-1 describes the number of school districts in the selected states and which programs
were evaluated in each of these states.
Table 2-1
The States Selected for the Study
Total Number of
State Public School Districts
Colorado
Idaho
Illinois
New York
Ohio
Pennsylvania
So. Carolina
Tennessee
Texas
176
115
987
765
614
201
91
120
1146
Programs Evaluated
Asbestos LDW/Radon
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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2.3 LEARNING ABOUT THE STATE ENVIRONMENTS
The research team hypothesized that the ways in which school districts respond to
communication about potential environmental health risks, such as those included in this
study, are related, at least in part, to certain state characteristics and particularly to the level
of activity the state generates relative to these health risks. To examine the validity of this
hypothesis, it was necessary to gather information about each state and the ways in which
the states were responding to the federal requirements or recommendations. This required
two additional data collection efforts beside the mailed survey of local school districts. One
of these efforts was at the level of the EPA regions. The second was at the level of
appropriate state governmental agencies as well as state school board associations, some of
whom take an active role in assisting school districts to address environmental concerns.
The study team gathered data on state environments through semi-structured, open-ended
telephone interviews. This type of interview assures that certain information will be
gathered consistently but also enables the interviewer to probe and pursue salient issues
whenever appropriate. The results of these efforts on the state programs for asbestos-
containing materials, lead in drinking water and radon are summarized in Sections 4.2, 5.2,
and 6.2.
As earlier indicated some of the interviews with regional EPA staff, representatives of state
agencies and state school board associations occurred prior to state selection. This was
particularly true for the Lead in Drinking Water program, which was the initial program
slated for study.
2.3.1 EPA Regional Staff
The first interviews were conducted with appropriate staff members in several EPA regional
offices. These interviews were designed to attain information about:
particular states in the region;
the role that the regional office was taking with respect to each
program;
the relationships between the regional offices and the various state agencies;
issues perceived at the regional level; and
appropriate contacts within the states.
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2*3.2 State School Boarfl Associations
Interviews with representatives from state school board associations were conducted to
attain information about:
any role that the association had taken or might take with respect to
each program;
perceptions of salient issues within their state; and
assistance that the association might provide the study team through advance
notification about the survey to the selected school districts.
2.3.3 State Agencies
Two sets of interviews were conducted with representatives from the relevant state agencies.
The first set occurred prior to the survey of local school districts. The second interviews
were conducted several months later, after the survey had been completed but before the
survey data analysis was completed.
These first interviews were designed to attain information about:
state responses to the federal programs;
current and/or planned state actions with respect to the federal
programs;
attitudes at the state level about the federal programs;
general attitudes at the state level about EPA;
perceptions of the levels of pubic concern about the environmental
risks being addressed;
perceived issues in the state; and
perceived attitudes, responses and issues in the local school districts.
The second interviews were designed primarily to ascertain what changes had occurred
within each state since the initial conversations and to clarify initial local school district
survey results.
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2.4 THE SURVEYS OF LOCAL SCHOOL DISTRICTS
2.4.1 The Samples
The local school districts were selected using a standard random, probability sampling
procedure in which each public school district in the state had an equal chance of being
selected. The samples were drawn by Quality Education Data (QED), an educational
research firm in Denver, Colorado. The sampling procedure used was meant to assure a
cross-section of districts according to the following demographic variables:
size, including number of students and number of schools;
urbanicity (i.e., urban, suburban, rural);
level of affluence; and
percentage of minorities.
2.4.2 Designing the Survey Instrument
Mailed questionnaires were used in the survey of local school districts. As we indicated
earlier, two separate questionnaires were designed for the survey, one for the school districts
in the lead in drinking water/radon sample and the other for the districts constituting the
asbestos sample. Several questions were common to both instruments. The questionnaires.
which are found in the Appendix of this report, were essentially structured, forced-choice
instruments that included some open-ended questions. Instrument design was implemented
with significant input from EPA's Office of Policy, Planning and Evaluation and from each
of the three program offices.
The instruments were designed to:
assess the degree of seriousness with which the districts view a variety
of environmental and health issues;
assess levels of familiarity with both federal and state mandates and
recommendations for the three programs being studied;
learn what kinds of actions districts have taken or are planning to
take relative to the three programs being studied;
enable respondents to evaluate the various EPA materials that have
been published for the three programs;
assess to what degree these materials have influenced district actions;
assess the degree of difficulty that districts have had or are having in
complying with mandates and recommendations;
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determine to which sources school districts are more likely to turn for
information on environmental concerns;
assess the average or typical amount of money that districts have
spent and are spending on the asbestos program on inspections,
management plans, remediation and ongoing surveillance; and
assess general attitudes about environmental issues and the EPA.
2.4.3 Basic Outline of the Asbestos Qnestionnaire
The first three questions concerns the respondent's position in the district, the length of time
the respondent has been with the district and in that position, and who in 'he district is
primarily responsible for supervising actions that relate to environmental issues.
The second set of questions address the combined level of concern expressed by parents,
students, faculty and staff about several health and environmental issues and the
respondent's assessment of the relative health risk of each of those issues.
The next section of the questionnaire, entitled "About Asbestos in Schools" addresses the
respondent's degree of familiarity with state and federal regulations and guidelines
pertaining to asbestos in schools; asks which of several possible sources of information the
district has used in determining its actions on asbestos-containing materials (ACM)
management and abatement; addresses, in some detail, the district's overall Management
Plan and abatement activities; asks about funding sources and expenditures, to date and
projected; requests the respondent to evaluate EPA materials on the Asbestos program,
addresses which of several factors were helpful and motivating and which were impediments
to district action.
The following section, "Also About the EPA Programs", assesses the degree of difficulty the
district has encountered in implementing several environmental programs and gathers
general attirudinal information about the EPA.
A section, "About Your District's Facilities" addresses the ages of the district's buildings and
the instrument concludes with room for comments and information requests.
2.4.4 Basic Outline of the Lead in Drinking Water/Radon Questionnaire
The first and second sets of questions are identical to their counterparts in the Asbestos
questionnaire, addressing the respondent's position; length of service; who in the district
supervises environmentally related actions; levels of concern expressed about each of several
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potential health and environmental issues; and the respondent's assessment of these issues
as serious health risks.
The following section, "About Lead in Drinking Water", addresses: ownership of water
supplies; any regular testing of drinking water for contaminants; familiarity with state and
federal regulations and/or guidelines; which of several information sources the district has
used to help determine actions relating to lead in drinking water; any testing and
remediation activities (either accomplished or planned); the respondent's assessment of EPA
guidance materials on lead in drinking water; and familiarity with the EPA's list of water
coolers that require either repair or replacement. The next questions concern factors that
might have been either motivating and helpful or impediments to district action.
The segment, "About Radon Gas in Your Schools," follows essentially the same outline as
the corresponding questions about lead in drinking water.
Questions in the section, "Also about .the EPA Programs," ask the respondent to assess the
degree of difficulty the district has had in implementing several environmental programs and
asks for general attirudinal data about the EPA. "About Your District's Facilities" follows
and addresses the age of the district's buildings. The instrument concludes with comments
and information requests.
2.4.5 The Survey Process
The Lead in Drinking Water/Radon instrument was field tested in school districts in
Colorado and North Carolina. The Asbestos instrument was field tested only in Colorado.
A total of nine field tests were conducted for the two instruments.
The survey mailing process followed a modified Dillman (1978) approach. The
superintendent of each school district in the sample received advance notification of the
survey from their state school board association. Notification was in the form of a letter,
except in New York and Pennsylvania, where notification took the form of an article in a
regularly mailed newsletter. These advance notifications were mailed the first week of
November, 1989.
Questionnaires were hand addressed and mailed to the Superintendent (by name) of each
distnct in the sample during the second week in November. A cover letter requested that
the Superintendent either complete the questionnaire or send it to the most appropriate
staff member in the district for completion.
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Activities to increase the response rate included:
a reminding postcard, seat approximately ten days after the surveys were mailed;
a second letter, mailed, approximately four weeks after the first survey mailing
to everyone in the sample who had not yet responded, and containing a second
copy of the questionnaire; and
a follow-up telephone call, made in January, 1990, to 200 districts that had not
responded by that time (or about 1/3 of those not yet responding), to ask if
these districts would still return the questionnaire, gather some key data, and to
send additional copies of the questionnaire to those who did not recall receiving
one.
Copies of the survey instruments and cover letters can be found in Appendix A.
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3.0 MAIL QUESTIONNAIRE RESPONSE RATES AND GENERAL
RESULTS ACROSS ALL PROGRAMS
3.1 RESPONSES TO THE MAIL QUESTIONNAIRES
This section describes response rates, characteristics of the responding districts, and who
completed the mail questionnaires for the districts.
3.1.1 Response Rates
Table 3-1 summarizes information about sample sizes and response rates for each version
of the mail questionnaire. Response rates to the two versions were fairly similar, averaging
62 percent across all the states. Given the original sampling plan, these response rates
resulted in having completed responses for an average of about 10 percent of all school
districts in the states selected for the analysis. This percentage varied significantly across
the states primarily due to the large variation in the number of school districts in each state.
Some variation in state average response rates is apparent, with lower response from
districts in Illinois and New York and higher response rates from districts in Colorado, for
both versions of the questionnaire.
In addition to the mail returns, 126 telephone interviews were completed. The combined
response rate for both mail and telephone was therefore 72 percent (Table 3-2).
3.1.2 Characteristics of the Sampled Districts
Averages of selected characteristics for the school districts sampled and responding to the
mail questionnaire are shown in Tables 3-3 through 3-6. The selected characteristics are:
The percentage of students under poverty, the Orshansky percentile, which indicates
the percentage of students coming from families living under the poverty line
Instructional materials dollars per student (IDP)
Number of students in a district
Number of schools in a district
Percentage of Black students in a distnct
Percentage of Hispanic students in a district
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Table 3-1
Sampling Plan and Survey Response Rates
TOTAL NUMBER OP
SCHOOL DISTRICTS
IN EACH STATE
NET
SAMPLE*
SAMPLE*
OP TOTAL
NUMBER
OP GOOD
RETURNS0*
RETURN
AS%OP
SAMPLE
RETURN
AS %OF
TOTAL
LEAD/RADON RESULTS
Colorado
Idaho
Illinois
New York
Ohio
Pennsylvania
South Carolina
Tennessee
Texas
Unspecified
SUBTOTAL
ASBESTOS RESULTS
Colorado
Illinois
New York
Ohio
Pennsylvania
Tennessee
Texas
Unspecified
SUBTOTAL
COMBINED RESULTS
176
115
987
765
614
201
91
120
1146
4215
176
987
765
614
201
120
1146
4009
8224
56
59
100
90
89
85
58
59
115
711
57
101
88
90
90
60
116
602
1313
31.82%
51.30%
10.13%
11.76%
14.50%
42.29%
63.74%
49.17%
10.03%
16.87%
32.39%
10.23%
11.50%
14.66%
44.78%
50.00%
10.12%
15.02%
15.97%
41
41
57
53
47
51
36
32
76
7
441
44
59
51
58
49
37
74
2
374
815
73.21%
69.49%
57.00%
58.89%
52.81%
60.00%
62.07%
54.24%
66.09%
62.03%
77.19%
58.42%
57.95%
64.44%
54.44%
61.67%
63.79%
62.13%
62.07%
23.30%
35.65%
5.78%
6.93%
7.65%
25.37%
39.56%
26.67%
6.63%
10.46%
25.00%
5.98%
6.67%
9.45%
24.38%
30.83%
6.46%
9.33%
9.91%
Twenty of the original addresses were deleted as incorrect or inappropriate.
Four returned lead/radon surveys were later deleted due to missing pages and one
deleted due to a duplicate response from the same district.
leaving a working sample of 436.
-------
Table 3-2
Total Response Rate
Survey Version
Category
1.
2.
3.
4.
Net Sample
Mail Returns
% of Net Sample
Additional Telephone
Respondents
% of Net Sample
Total Mail and Telephone
Participants
% of Net Sample
Lead/Radon
711
441
62.03%
63
8.06%
504
70.9%
Asbestos
602
374
62.13%
63
10.47%
437
72.6%
Total
1313
815
62.07%
126
9.60%
941
71.7%
-------
Table 3-3
Average Demographic Characteristics of School Districts Sampled for the Asbestos Survey
Variable
Sample Size
Percentage of Students
under Poverty
Instructional Materials
Dollars per Student
Number of Students
Number of Schools
Percentage of
Black Students
Percentage of
Hispanic Students
Statistic
mean
SE(mean)
mean
SE(mcan)
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
All
602
13.5%
04
$72
1.4
2706
219
5.2
0.3
5.2%
0.5
6.8%
0.6
Colorado
57
17.1%
1.5
$76
38
1596
500
47
0.8
0.1%
0.05
15.8%
2.5
, Illinois
101
8.4%
0.6
$76
3.2
1476
241
3.3
0.3
3.3%
1.2
2.2%
0.4
New York
88
10.6%
0.8
$117
3.4
23i91
345
3.9
0.4
4.0%
0.0
2.7%
0.6
Stale
Ohio
90
9.2%
0.7
$59
2.2
3245
860
4.6
0.4
2.5%
0.7
1.4%
0.2
Peon
»
10.2%
06
$71
2.9
2951
2JJ
5.9
0.4
3.0%
0.9
0.6%
a/
Tcnn
60
22.0%
0.9
$43
1.8
4670
889
10.2
/.«
12.4%
1.9
0.8%
0.07
Tcus
116
19.0%
j.2
$58
27
2984
650
5.4
0.9
9.8%
I./
20.3%
2J
-------
Table 3-4
Average Demographic Characteristics of School Districts that Responded to the Asbestos Survey
Variable
Sample Size
Percentage of Students
under Poverty
Instructional Materials
Dollars per Student
Number of Students
Number of Schools
Percentage of
Black Students
Percentage of
Hispanic Students
Statistic
mean
SE(mean)
mean
SE(mton)
mean
SE(mon)
mean
SE(mcon)
mean
SE(mcon)
mean
SE(nuon)
All
374
13.4%
0.3
S71
1.8
2628
I8J
5.2
.J
4.7%
0.5
7.7%
5.9
Colorado
44
15.9%
1.5
S74
2.7
2007
660
5.5
I.I
0.1%
0.1
15.7%
26
Illinois
59
81%
0.6
$75
4.2
1686
379
3.5
0.5
1.7%
0.7
2.4%
0.7
New York
51
10.7%
1.0
$121
4.5
2676
456
41
05
4.5%
I.I
3.3%
0.9
Stale
Ohio
58
9.6%
0.9
$58
2.9
2375
JOB
5.0
0.5
2.3%
OS
1.3%
03
Penn
49
9.5%
A 7
$73
42
3127
J5J
6.0
0.6
2.4%
ft?
0.8%
0.2
Tenn
37
21.3%
1.2
$42
1.8
4036
J49
8.9
0.9
13.4%
26
09%
O./
Texas
74
189%
1.4
$57
JJ
2875
576
51
0.8
88%
12
22.0%
3.0
-------
Table 3-5
Average Demographic Characteristics of School Districts Sampled for the Lead/Radon Survey
Variable
Sample Size
Percentage of Students
under Poverty
Instructional Materials
Dollars per Student
Number of Students
Number of Schools
Percentage of
Black Students
Percentage of
Hispanic Students
Statistic
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
mean
SE(nuan)
mean
SE(mean)
All
711
14.2%
04
$67
1.3
3661
422
6.1
06
7.7%
06
6.3%
0.5
Colorado
56
1S.2%
1.4
$87
4.6
4264
1657
90
2.9
0.6%
0.4
14.5%
2.3
Idaho
59
16.4%
1.2
$54
2.5
1700
313
48
0.5
01%
0.1
4.6%
0.7
Illinois
100
9.2%
0.8
$72
2.8
1374
207
32
0.4
3.6%
1.2
21%
0.4
New York
90
10.6%
0.8
$112
3.6
2451
430
4.1
0.7
5.3%
1.7
2.6%
0.6
State
Ohio
89
9.6%
0.7
$61
2.4
3700
1078
5.4
1.2
3.8%
I.J
0.8%
A2
Pcnn
85
9J%
0.7
$69
J.0
4666
2106
7.4
29
2.3%
1.0
1.0%
O.J
S.Carolina
58
24.0%
1.6
$41
0.9
6429
1027
9.2
1.4
43.7%
26
1.3%
0.1
Tcnn
59
18.2%
1.0
$39
0.9
7830
2514
10.7
27
86%
/.7
0.8%
0.1
Teias
115
17.9%
M
$57
24
2787
o96
51
10
72%
09
206%
22
-------
Table 3-6
Average Demographic Characteristics of School Districts that Responded to the Lead/Radon Survey
Variable
Sample Size
Percentage of Students
under Poverty
Instructional Materials
Dollars per Student
Number of Students
Number of Schools
Percentage of
Black Students
Percentage of
Hispanic Students
Statistic
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
All
436
14.6%
05
$68
1.6
3858
602
7.2
0.9
08
6.0%
0.7
Colorado
41
1S.1%
1.7
$93
5.1
5676
2313
11.8
4.1
09%
0.6
12.9%
2.4
Idaho
41
172%
1.7
$49
1.6
2031
433
5.3
0.7
0.2%
O.I
4.9%
0.9
Illinois
57
98%
1.2
$77
3.7
1411
194
36
04
4.9%
2.0
2.1%
0.5
New York
53
11.6%
1.0
$112
4.8
2657
647
4.8
/./
3.3%
10
1.9%
Ad
Stale
Ohio
47
101%
0.8
$59
3.4
2037
2JJ
4.2
0.4
1.8%
A7
10%
A;
Perm
51
10.1%
1.0
$67
36
6510
3705
10.4
5.0
2.6%
1.6
1.2%
A3
S Carolina
36
24.9%
1.8
$42
/./
6109
1432
105
2.J
41.3%
J./
1.2%
0.1
Term
31
17.7%
1.3
$40
/J
8151
3469
130
5.0
109%
2.9
0.7%
0.1
Ten*
72
176%
14
$57
J./
2V* 1
994
56
/5
HVfc
f i
1H 7%
24
-------
^ 3-8
Overall, the school districts responding to both versions of the questionnaire had average
characteristics similar to the full samples that received each version of the questionnaire.
It appears, therefore, that there is not any significant response bias in terms of these
characteristics. Some of the differences among the state averages of these characteristics
are used in subsequent chapters to help explain differences in the responses to the EPA
programs.
3.1.3 Who Answered the Questionnaires
Table 3-7 summarizes who completed the mail questionnaires. About 70 percent of the
respondents were superintendents or assistant superintendents for both versions of the
questionnaire. The average experience of the respondents was substantial, with an average
of 11 years with the district and 7 years in the current position. It appears that the average
respondent was in a position to be well aware of the problems and concerns of the district
with respect to these environmental risk programs and other school district issues.
The respondents were also asked who in their district was responsible for supervising any
action by the district concerning environmental issues (Table 3-7). About 60 percent said
the superintendent or assistant superintendent. About 15 percent said the business manager
or administrative assistant. Another 15 percent said maintenance manager or school
engineer. Overall, the questionnaires were completed by individuals responsible for and
familiar with the program evaluated in the questionnaire and who have several years
experience in their districts.
3.2 TELEPHONE FOLLOW-UP
As discussed in Chapter 2, a telephone follow-up was conducted for two purposes: (1) to
stimulate additional responses to the mail questionnaire, and (2) to obtain some information
about non-respondents to the mail questionnaire.
3.2.1 Telephone Response Rates
Table 3-8 summarizes the response rates for the telephone follow-up. Approximately 230
contacts were made. About 80 percent of those contacted (182 respondents) indicated
willingness to complete the mail questionnaire. Of these, 76 (about one-third of those
contacted) did return a completed mail questionnaire. Telephone interviews were
completed for 126 respondents who did not complete the mail survey. Combined with the
mail responses, this means that information in one form or another was obtained from about
72 percent of the net sample.
-------
Table 3-7
Who Completed the Survey
(Questions I, 2, 3)
% Completing Survey Version
Lead/Radon Asbestos
1 Title
1 Supcrinlcndcnt/A&st. Superintendent
2 Business Manager. Fiscal Operations, Admin.. Asst.
3 Manager of Maintenance, School Engineer, etc.
4 Env. Coordinator, Program Coordinator
5 Others
Statistic
II. Experience of Respondent
Avg. yrt. in district mean
SE(mcan)
Avg yrs. in current mean
position SE(mcan)
III Who is Responsible
1. Supcrintcndcnl/Assl. Superintendent
2 Business manager, Fiscal operations. Admin , Assl
3 ' Manager of Maintenance, School Engineer, elc.
4 tlnv Coordinator. Program Cooidmalor
5 Others
71.6%
15.1%
9.2%
2.1%
20%
Survey Version
Lead/Radon
11.43
.44
6.73
.28
Lead/Radon
58.2%
149%
15.1%
1.7%
101%
70.8%
15.3%
9.2%
2.2%
2.5%
Asbestos
11.87
.5/
7.06
.32
Asbestos
59.3%
16.3%
185%
31%
28%
-------
Table 34
Summary of Telephone Follow-up Response Rates
1.
2.
3.
4.
5.
6.
7.
Category
Non-respondents at time of telephone interview
Number attempted
Leu: Unsuccessful contacts (never reached
target respondent)
Refusals to participate
Wrong numbers
Equals total completed or partially completed
Number indicating no intent to return mail survey
Number indicating interest in returning mail survey
Number completing part or all of the remainder of
telephone survey
Number from line S actually returning mail survey,
% returning
Total
Number
606
310
-80
-15
2
213
31
182
202
76
41.7%
Lead/
Radon
NA
NA
NA
NA
NA
NA
91
101
38
41.7%
Asbestos
NA
NA
NA
NA
NA
NA
91
101
38
41.7%
8. Number completing telephone survey who did not
complete mail survey
126
63
63
-------
3-11
3.2.2 Answers of Telephone Respondents
Four questions were asked of the telephone respondents that were comparable to questions
in the mail questionnaire (a complete copy of the telephone questionnaire is included in the
appendix). These questions were:
Perceived health risks of the three environmental problems
Relative ease or difficulty in complying with federal regulations or guidelines for
each program
Helpfulness of EPA materials and assistance
Expenditures to date on asbestos program
The mean responses of the telephone respondents who did not complete the mail
questionnaire are shown in Table 3-9. For comparison, the mean responses to the
comparable mail question are also shown. The first question is comparable to Q-5 in both
versions of the mail questionnaire. The second question is comparable to Q-33 in the
asbestos version of the mail questionnaire and to Q-40 in the lead/radon version. The third
question is comparable to Q-30 for asbestos, to Q-22 for lead in drinking water, and to Q-37
for radon. Overall, the responses to the telephone questions are one-half to one point lower
on the same five point scales. Because some of the questions are positive and some are
negative in terms of potential attitudes toward these programs, it appears more likely that
the differences in the telephone response result from the different way in which the
questions were asked rather than from dramatically different attitudes on the part of the
telephone respondents. The only significant difference in responses regarding the three
programs is the greater difficulty in complying with the asbestos programs, a response
similar to that given by the mail respondents.
There appeared to be a few problem responses to the asbestos expenditures question in the
telephone survey. Telephone respondents were unable to take time to check their figures
and probably tended to do more estimating than those respondents who completed the mail
questionnaire and had more opportunity to check the accuracy of their response. Therefore
AC are skeptical that the mean response, which was about three times the mean from the
mail questionnaire, is accurate. This is particularly true since the median expenditures are
reasonably comparable at $30,000 for the telephone respondents and S40.000 for the mail
respondents.
The telephone respondents were also asked if they hai any additional comments. About
40 percent of the respondents gave one or more comments. These are summarized and
compared to comments from the mail respondents in Table 3-10. Many of the telephone
respondent's comments were made by a similar percentage of the mail respondents. In
general, the tone of the telephone comments was slightly more negative, with more
-------
Table 3-9
Answers Gives by Telephone Respondents
Question
Telephone Responses Mail Responses
(n-126) (n-810)
Perceived health risk:
mttcntlt
Lead in drinking
water
Radon Gas
How difficult to comply.
Asbestos containing
materials
Lead in drinking
water
Radon Gas
Hf Ipfulnt M of EPA mitf naif vf f fVT*"
Asbestos containing
materials
Lead in drinking
water
Radon Gas
SE(mtan)
mean
SE(mean)
mean
SE(mtan)
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
mean
SE(mtan)
mean
SE(mtan)
mean
SE(mean)
.06
125
.06
1.21
.06
3.70
1.93
.11
1.86
./5
1S3
JJ
138
J2
115
JJ
1 7R
1. /o
.OJ
1.64
.03
1.60
4.04
.04
172
.05
2.89
.06
193
.07
3.08
.07
2.75
.08
(n-374)
(n-436)
(a- 436)
Asbestos Costs to Date
Median
$30.000
$40,000
-------
Table 3-10
Additional Comments by Telephone Respondents
About the EPA Programs
Percentage of Specific Comment (Paraphrased)
Respondents
Phone Mail*
74 843 Total number of comments given"
126 810 Total number of respondents for each version
I. EPA should provide more financial support
13% 24% EPA should provide financial support for these
programs; they are taking funds away from education.
2% 7% EPA should do/pay for the work required.
1% 4% EPA should provide more on-site help, testing, or
other direct assistance.
II. Complaints about the requirements and/or guidelines
7% 1% Asbestos drained/wasted funds.
6% 4% Abolish EPA, etc.
3% 9% EPA should provide better/simpler information and
establish clearer guidelines.
3% 2% Make less/easier regulations.
2% 3% Don't keep changing requirements/guidelines.
2% 2% EPA should coordinate guidelines with state and local
agencies.
2% 1% Need more muscle in the regulations.
-------
Table 3-10 (coot.)
Additional Comments by Telephone Respondents
About the EPA Programs
III. EPA's programs/actions exaggerate the risks
6% 3% These programs are not needed; there is no real risk;
EPA has overreacted.
3% 4% EPA should provide information about the true health
risks; problem not that serious.
2% 6% EPA should take a more realistic/common sense
approach.
IV. EPA should provide better or different information
1% 3% EPA should provide a newsletter or other periodic
updates on programs and requirements.
1% 3% EPA should provide more/better training.
1% 2% EPA should provide more information about who is
qualified to do the work and what it should cost.
V. EPA should improve communication with the schools and with the public
29& 3% EPA should conduct better public relations with the
schools and listen to feedback from the schools.
1% 3% EPA should be more responsive and supportive.
VI. EPA is doing a good job
1% 1% General positive comments about EPA.
Asbestos Q35 and Q36 and Lead/Radon Q42 and Q43.
About 40% of the telephone respondents and about 60% of the mail sample gave
one or more comments in response to these questions.
-------
5-15
complaints that the asbestos program had drained/wasted funds, that these programs are
not really needed, and that EPA should be abolished (or some similarly negative statement
about EPA).
Telephone respondents who said they would not return the mail questionnaire were asked
to give some explanation. Most of them said that it was too long, they were too busy, or
they simply got too many questionnaires. A few indicated hostility toward EPA as the
reason they would not respond.
Overall, the responses to the telephone survey do not suggest any significant response bias
for the mail questionnaire respondents. Non-respondents may be slightly more skeptical
about the need for these programs and slightly more hostile toward EPA, but these
differences were not dramatic.
3.3 GENERAL PERCEPTIONS OF THE RISKS
Two questions were included early in both versions of the mail questionnaire to obtain some
general information about how the respondents viewed the relative significance of these
environmental risks. The first question asked respondents to rate on a four-point scale the
level of concern expressed in the past year by parents, students, faculty, and staff about eight
health risks for students, including drugs and alcohol and tobacco as well as six
environmental risks. The mean responses to this question combined for both survey versions
are summarized in Table 3-11. Expressions of concern related to drugs, alcohol, and
tobacco exceed those related to any of the environmental risks. Expressions of concern
related to asbestos, radon and lead in drinking water fell close to the "a little" point on the
scale and exceeded the ratings related to the other environmental risks that have received
less attention through EPA programs directed at schools.
.Asbestos is consistently rated as evoking the greatest amount of concern. Lead in drinking
water is rated slightly above radon gas, except in a few states. Most notably, the ratings for
radon were higher in Colorado and Pennsylvania where information about high levels of
radon gas found in a significant percentage of homes has been highly publicized.
The second question on this topic asked respondents to indicate, on a five-point scale, their
opinion of the relative health risk for each item listed (Table 3-12). Again, drugs, alcohol.
and tobacco are rated well above all the environmental risks. Drug, alcohol, and tobacco
are rated on average between three and four on the five-point scale. All of the
environmental risks are rated between one and two on the scale, suggesting that in general
these risks are not viewed as very significant. Across all the states, the order of the ratings
for asbestos, lead in drinking water and radon as health risks is the same as the order of
expressions of concern, but they are closer together on the scale. In several states radon is
rated slightly higher than lead in drinking water.
-------
Table 3- II
Reported Concern Expressed by Parents, Students, Faculty and Staff about Potential Health Risks
In ihe past year, what has been the combined level of concern expressed by parents, students, faculty and staff about each of the following?
( 1 = None. 2 = Little, 3 = Some. 4 = Great) (Lead/Radon Q4 and Asbestos Q4)
Stale
Issue Statistic
Sample size
Student use of drugs and alcohol *
Student use of tobacco*
Asbestos in school building
Radon in school building
Other indoor air pollution
Outdoor air near schools
(xad in drinking water
Other drinking water concerns
n
mean
SE(mean)
mean
SE(mean)
mean
SE(mean)
mean
SE(mtan)
mean
SE(nuan)
mean
SE(mtan)
mean
SE(mcan)
mean
SE(mean)
All
810
3J2
.03
2.67
.03
2.24
.03
1.70
.03
1.57
.03
1.35
.02
1.81
.03
1.52
.03
Colorado
85
2.00
.10
1.77
.09
1.51
.08
1.23
.05
1.69
.08
1.58
.09
Idaho
41
2.20
.13
1.71
.12
1.34
.09
1.32
.09
1.59
.11
1.41
.10
Illinois
116
2.24
.08
1.57
.07
1.45
.07
1.23
.05
1.57
.07
1.40
.07
New York
104
2.60
.09
1.73
.07
1.80
.08
1.43
.07
2.05
.08
1.53
.06
Ohio
105
2.24
.09
1.62
.07
1.63
.07
150
08
1.74
.07
1.57
.07
Penn
100
2.47
.10
2.21
.09
1.89
.08
1.38
.07
2.08
.09
1.67
.09
S.Carolina
36
2.47
.17
1.68
.12
1.57
.12
1.47
.12
2.08
.15
1.49
.13
Tenn
68
2.37
.11
1.78
.09
1.51
.07
1.41
.07
1.82
.08
1.41
.07
Tew
146
l.9»
.07
1.42
.06
140
06
1.30
.05
181
.07
Itt
.07
* Slate means for these issues do not vary greatly and are omitted to focus upon environmental issues.
-------
Table 3-12
Relative Health Risk as Perceived by Respondent
"What do you think the relative health risk is for students and employees
( 1 = no risk lo 5 = great risk) (Lead/Radon Q5 and Asbestos Q5)
Issue Statistic
Sample size
Student use of drugs and alcohol *
Student use of tobacco *
Asbestos in school buildings
Radon in school buildings
Other indoor air pollution
Outdoor air near schools
Lead in drinking water
Other drinking water concerns
n
mean
SE(nuan)
mean
SE(mean)
mean
SE(mean)
mean
SE(mcan)
mean
SE(mean)
mean
SE(mean)
mean
SE{mean)
mean
SE(mean)
All
810
3.58
.04
325
.04
178
03
1.60
03
1.51
.03
143
.03
1.64
03
1.50
.03
Colorado
85
1.67
.08
1.54
.08
1.36
.06
1.28
.07
1.47
.08
159
ii
Idaho
41
1.78
.14
1.82
.13
1.53
.10
1.34
.11
1.68
.12
1.38
.09
in your district's facilities for each of the following?"
Slate
Illinois
116
181
.08
1.64
.08
144
.07
1.44
.07
157
.07
149
08
New York
104
176
.08
1.53
.07
165
.08
1.48
.09
1.72
.08
1.50
.08
Ohio
105
2.06
.10
1.87
.10
171
.09
1.61
.08
1.80
.08
167
.08
Penn
100
1.89
.09
1.72
.09
1.68
.09
1.48
.08
1.67
.09
1.65
.09
S Carolina
36
1.89
.14
1.48
.10
1.49
.10
1.46
.10
1.94
.13
1.39
.09
Tenn
68
1.87
.10
180
.11
157
09
1.49
.10
186
11
1.47
09
Teias
146
147
00
'»:
1 U
111
(M
MS
114
(M
* Slate means foi these issues do not vary greatly and are omitted lo focus upon environmental issues
-------
3-18
The ratings of perceived risks reported in Table 3-12 may be somewhat confounded by the
fact that some school districts have already tested to determine the degree of problem with
asbestos, lead in drinking water, and/or radon gas in the district's buildings. Some have
found that no problems exist and others have completed corrective actions to reduce the
problems. This suspicion is confirmed by the comments about this question offered by some
respondents (Table 3-13), several of which indicated that these problems had been fixed.
To check the effect of this on the perceived level of risk, the mean risk ratings are reported
for each of the following comparisons:
1. The asbestos health risk score is compared for those districts that report no need
to conduct any corrective action for asbestos or that have completed all planned
corrective actions (16% of the asbestos sample) versus those districts that have
corrective actions remaining to be done.
2. The lead health risk score is compared for those districts that report having
tested for lead in drinking water and have found no problems (26% of the
lead/radon sample) versus those districts that either have not yet tested, or have
tested and found retesting or corrective actions to be required.
3. The radon health risk score is compared for those districts that report having
tested for radon and have found no problems (11% of the lead/radon sample)
versus those districts that have either not yet tested, or have tested and found
retesting or corrective actions to be required.
The mean ratings were as follows:
No problem group Some problem, or no testing yet
Asbestos 1.5 1.8
Lead 1.4 1.8
Radon 1.4 1.6
This suggests that some of the differences in the relative perceived level of risk reported for
these three risks may be due to differences in how far along the school districts are in their
testing and abatement processes. For example, lead in drinking water may be rated lower
than asbestos on average primarily because a significant share of districts have tested and
have found no problems with lead in their drinking water. Radon may be ranked lower than
lead in drinking water because very few districts had.as yet tested for radon and may
presume the problem to be relatively insignificant.
-------
Table 3.13
Most Frequent Comments to Clarify Responses about Different Potential Risks'
Comment Frequencies
By Survey Version
Asbestos Lead/Radon
Specific Comment (Paraphrased)
101
374
73
436
Total number of comments given."
Total number of respondents for each version.
17
17
12
10
9
8
Asbestos problem is fixed, or will soon be.
Several environmental problems are fixed, or will soon
be.
We have strict controls over smoking, alcohol, and
drugs.
Have fixed lead in drinking water, or soon will.
Still have water quality problems (nitrates, sewers, etc.).
This is a small district with few problems.
Trying to fix these (environmental) problems is more of
a problem.
EPA/state/press has created concern that did not exist.
No risk from radon in this area.
Q6 in both survey versions.
About 20 percent of the sample gave a comment in response to Question 6 in each
version of the questionnaire.
8
7
7
6
5
1
2
6
7
3
4
5
-------
4-1
4.0 ASBESTOS CONTAINING MATERIALS PROGRAM AND ANALYSIS
4.1 BACKGROUND ON EPA PROGRAM
Asbestos was, for decades, thought of as one of our major technological advances. Until
1976, because of its ability to retard flame, the use of asbestos was specifically required by
model building codes in areas where protection against fire was essential. As a
consequence, asbestos-containing materials were regularly used in constructing school
buildings. According to a signed editorial in the Rockv Mountain News, asbestos has had
no fewer than 3,000 uses and has been used in hundreds of products, ranging from vehicle
brakes to building panels to water and sewer pipes to protective aprons and gloves
(Fumento, 1989).
The medical profession had long been aware that exposure to asbestos, and the inhaling of
asbestos particles, caused a fatal lung disease called asbestosis. In the 1960s, medical
researchers concluded that exposure to asbestos particles is also carcinogenic. It was
approximately twenty years before Congress responded to this information.
4.1.1 Asbestos Hazard Emergency Response Act CAMERA)
In 1982 the Asbestos in Schools Rule went into effect and required schools to:
inspect for friable asbestos-containing materials (ACMs), i.e., ACM that is dry
and can be crumbled in one's hand;
analyze the samples; and
make notifications of the results.
The rule did not address nonfriable ACM, which are intact and contained within walls, floor
tiles, etc.
Four years later, in October 1986, the Asbestos Hazard Emergency Response Act (AHERA)
became law, replacing the original Asbestos in Schools Rule. In October 1987, the EPA
promulgated the regulations that provide a framework for addressing asbestos hazards in
schools under AHERA.
AHERA. which is far more comprehensive than its predecessor, requires schools to:
inspect for both friable and non-friable asbestos;
develop asbestos management plans that address asbestos hazards in any school
-------
4-2
buildings owned or leased by the district, including administrative offices and
essential maintenance, storage and utility facilities; these inspections and plans
were to have been completed by October 1988; and
begin to implement management plans no later than July 9, 1989.
School districts failing to comply with these regulations are subject to fines.
Between the 1982 Asbestos in Schools Rule and the AHERA regulations, local school
districts have been subject to requirements concerning asbestos for eight years. The changes
in requirements that occurred with the promulgation of the new regulations under AHERA
are an issue both for state agencies and school districts. The implications of this issue are
addressed in later sections of this report.
4.1.2 The Model Accreditation Plan
The AHERA regulations define asbestos-containing materials as any materials containing
at least one percent asbestos. The regulations require all personnel involved with managing
asbestos (designers, inspectors, management planners, supervisors and workers) to receive
EPA approved training and become accredited. In April 1987, EPA published a Model
Accreditation Plan that specifies training, examination and other requirements for asbestos
personnel. States are required to develop their own Accreditation Plans with standards a
least equal to those specified in the EPA model. A variety of organizations and agencies.
including both universities and asbestos contractors, are approved trainers.
Each local school district must designate an individual to oversee the district's asbestos-
related activities. This person must also be trained. While outcomes of this individual's
training are specified in the regulations, how and where he or she receives that training is
left to the school district.
Review and acceptance of management plans is the responsibility of each state. EPA did
not publish a model format for a management plan nor are there requirements for the
management plan review process. To make the management plan review process more
efficient, many states have published a standard management plan format and require their
local school districts to use it.
4.1.3 Abatement
Schools have three basic alternatives for abating asbertos hazards: repair, containment or
encapsulation, and removal. The most expensive alternative is removal. Yet it is interesting
-------
4-3
to note that many school districts have selected this option even when EPA regional staff
and state officials indicate that a less expensive option is acceptable. According to several
individuals in both EPA regional offices and state offices, many school boards and
administrators have developed an attitude that can essentially be described as "just get it
out!"
4.1.4 EPA Materials
The regulations promulgated under AHERA are exceptionally complicated and have
required ongoing explanations, clarifications and definitions. As a result, the EPA has
published several sets of materials for school districts. "Asbestos-in-Scnools: A Guide to
New Federal Requirements for Local Education Agencies" was published in February 1988.
This was followed very quickly by "100 Commonly Asked Questions about the New AHERA
Asbestos-in-Schools Rule", published just three months later, in May 1988. The most recent
pamphlet, "The ABCs of Asbestos" was published in June 1989. Each of these publications
was disseminated directly to all public and private K-12 school districts in the country. In
addition, EPA will soon distribute a new guidance publication entitled, "Managing Asbestos
in Place: A Building Owner's Guide to Operations and Maintenance Programs for Asbestos
Containing Materials."
4.1.5 Grant Programs
There are currently three different federal grant programs to give financial assistance to
states and school districts with their asbestos programs:
TSCA, the Toxic Substance Control Act, includes funds for assisting state
agencies in performing random inspections of schools to determine the accuracy
of a district's inspections and management plans; these are frequently
cooperative grants between the state and the EPA regional office.
ASHAA, the Asbestos School Hazard Abatement Act, is a loan and grant
program to assist school districts with abatement; there are $43.4 million dollars
in this program for fiscal year 1990. These funds are available to local school
districts that qualify financially for the assistance.
AIMPAP, the Asbestos Inspection Management Plan Assistance Program made
grants to the states which then allocate the funds to local school districts.
-------
_ 4-4
4.1.6 Additional Commgnfif
AHERA has been a very expensive program for schools and while few question the validity
of protecting the nation's school children from potential carcinogens, questions have been
raised in both the scientific literature (Harvard, 1990; Cough, 1989) and public media as to
whether the EPA regulations go further than is necessary. Even while schools are in the
midst of implementing their asbestos management plans, the issue remains highly
controversial. For example, in the Rocky Mountain News. Fumento (1989) points out that
building occupants are rarely at the same risk as individuals actually working with asbestos-
containing materials - the individuals on whom the bulk of the medical research has been
conducted. Critics also question the need for concern about non-friable asbestos that is
embedded in walls or floor tiles, and suggest the threat of low-level asbestos exposure has
been exaggerated (Fumento, 1989). EPA responded in February 1990 to a critical article
in Science. January 19, 1990, agreeing that health risks due to low level asbestos exposures
are probably low, but stating, "Scientists have been unable to agree on a level of asbestos
at which we, as public policy makers, can confidently say, there is no risk" (McNally, 1990).
EPA also pointed out that their publications clearly state that in-place management of
asbestos containing material is, in many cases, the best abatement option.
4.2 STATE PROGRAMS
As indicated in Section 4.1, each state is required to establish an Accreditation Plan for the
training and certification of personnel who do asbestos-related work in schools. The
requirement states that the plan must be at least as rigorous as EPA's Model Accreditation
Plan, leaving room for significant variation among state programs. In addition, AHERA
specifies that states may develop procedures for reviewing and accepting management plans,
and leaves the details of this process to the states. Consequently, even greater variation can
be found among the states with respect to the process for reviewing management plans.
The regulations governing asbestos inspections, plans and abatement are, by far, the most
complex and the most costly of any of the regulations or recommendations included in this
study. Comments from study participants indicate that states' and local school districts'
reactions to the Lead in Drinking Water and the Radon programs are certainly affected by
their experiences with asbestos.
State-level activities are summarized in Table 4-1 and discussed below.
-------
Table 4-1
Summary of State Asbestos Programs
(March 1990)
STATE
ACCREDITATION
PROGRAM REGULATIONS
STANDARD COMPLIANCE
MOT. PLAN MGT. PLAN INSPEC-
REVIEW FORMAT TIO.NS
OTHER
CONSULTING/
TRAINING ASSISTANCE
COLORADO YES
EPA PARTIAL
ILLINOIS YES
>EPA
FULL
NEW YORK YES
>EPA
AHERA
FIVE'
FORMS
ONLY
OHIO
IN
REVISION
EPA
PARTIAL
IN
PLANNING
PENN
NO
NA
PARTIAL
EPA
REGION
TENN
IN
PROCESS
>EPA
FULL
TEXAS
YES
>EPA
FULL
X W/EPA
-------
4-6
4.2.1 Colorado
The Asbestos Coordinator in Colorado works under the Department of Health. The state
has complied with the federal requirements but has been somewhat inactive with respect to
this program. One respondent indicated that there was never a major expression of public
concern about asbestos in Colorado. He commented that the issue never had the "right
movers and shakers" behind it.
Colorado's Model Accreditation program is virtually identical to EPA's. The only exceptions
are that the state requires a fee from school districts for the initial review of management
plans, and the state published a standard format for writing management plans. The latter
was done after it was found that cursory reviews of variously organized plans were taking
from five to seven hours each. However, because the state's standard format was developed
after the management planning process had begun, many districts have not used it. A key
informant believes that EPA's regulations would have been much more useful if they had
included a standard format for a management plan and required all districts to use it.
The state used Toxic Substance Control Act (TSCA) grants to provide free EPA-approved
training courses for inspectors, management planners, district designees, etc. The training
was offered by a variety of approved contractors including Colorado State University.
One respondent discussed the training courses, expressing some concern that a three day
course may not have been sufficient for preparing the trainees to implement regulations as
complex as those promulgated under AHERA. Colorado returned a number of
management plans that contained flawed sampling or other problems. As inspectors.
planners, etc., have gained more experience, plans have improved.
Funding constraints prevented the department from reviewing all plans. Originally, they
reviewed plans from larger districts first and then reviewed plans from smaller districts that
were developed by the same consultants - relying on similarities in one consultant's approach
to facilitate the review of the smaller districts' plans. Insufficient funds caused the
department to stop reviewing plans in October 1989. In the last stages of the review
process, plans were reviewed against a check sheet and the department sent a letter
identifying required changes with no additional follow-up.
The department is conducting random compliance inspections with TSCA grant funds. They
anticipate completing inspections in approximately 80 school districts in 1990. This
constitutes 45 percent of the state's districts.
-------
4-7
Illinois
The Asbestos Coordinator in Illinois is in the Department of Public Health. The state has
been very active with respect to this program. The Illinois legislature had passed a bill
governing asbestos abatement in schools two years prior to AHERA. According to one
informant, this legislation was the result of an expression of public concern that began with
one parent. This same informant described Illinois as "always being in the lead on these
types of issues" (a perception borne out in this study) and further explained that the state
legislature is very responsive to public concerns.
Illinois' Accreditation Program is much more rigorous than EPA's. Before developing their
regulations, state officials contacted their counterparts in states that had asbestos regulations
in place. They developed Hlinois's regulations using the experiences of other states.
In Illinois, each category of asbestos personnel must demonstrate specific prior experience
and meet particular educational requirements to become accredited for work in schools.
State licenses are required for abatement contractors and a project designer must be a
licensed architect, engineer or industrial hygienist.
The state, in cooperation with EPA Regional staff, conducted nine seminars on AHERA
throughout the state to enhance school districts' understanding of the regulations. The
Department of Health published a standard format for management plans and is reviewing
ail plans. The state's requirements regarding management plans are also more rigorous than
AHERA's. For example, the state requires each plan to include photographs of all sampled
areas.
The department is currently inspecting a random sample of abatement projects in districts
whose plans have been filed and reviewed. These inspections are revealing that the
stringent regulations relating to personnel experience and education and the training that
the state and EPA region cooperatively conducted are, in one respondent's words, "paying
off in terms of few problems or violations being found.
4.2.3 New York
The Asbestos coordinator in New York is in the Department of Labor, working in close
cooperation with the Departments of Health and Education. The state has been very active
with respect to this program. New York initiated its own program on School Asbestos
Safety in 1979. Under this plan, the state had certified certain categories of asbestos
personnel that were not specified under AHERA.
-------
4-8
The state's law has recently been amended to coniorm with AHERA; New York's
Accreditation Program is now virtually identical to EPA's except that the state demands
state certification for certain categories of asbestos personnel and an accredited AHERA
inspector must also be a state certified asbestos worker. In addition. New York's definition
of asbestos-containing materials (ACM) is anything with a trace of asbestos while AHERA
does not define materials as ACM until they contain at least one percent asbestos.
The Department of Education has actively assisted districts by providing additional training
materials and workshops. They implement a "Management Plan Quality Assurance
Program" that has included:
quality assurance seminars;
on-site reviews of management plans in a number of districts;
awareness sessions for school maintenance personnel; and
training sessions for district designees.
This program was intended to help districts submit plans that would be accepted on first
review. Because of this intensive program, districts were required to submit only the
management plan summary sheet, which is called an "AHERA Five Form," for state review.
When EPA regional staff conducts an on-site compliance inspection, they review the
complete plan.
Inspections are revealing that schools are frequently removing the asbestos when some
other, less costly, method of abatement would have sufficed. One informant believes thai
EPA should place more emphasis on the fact that removal is often unnecessary.
4.2.4 Ohio
The Asbestos coordinator in Ohio works under the Department of Environmental Health.
Due to a lack of resources, the state has been somewhat inactive with respect to this
program.
The state's Model Accreditation Program is virtually identical to EPA's except that, in the
state's program, asbestos workers must be state certified. The first version of Ohio's
program did not meet EPA's minimal standard and EPA required them to "close some
loopholes." During the development of the state program, the Environmental Health
Department proposed a pre-requisite of a high school education for some categories of
asbestos personnel. However, the legislature refused to accept this, primarily because Ohio
is an economically depressed state and legislators were unwilling to limit the employment
opportunities that would result from the program.
-------
4-9
The department was originally reviewing all building plans but is no longer able to do this
because of funding constraints. As of March 1990, they were reviewing only a sample of
management plans from each district and were not reviewing any plans for noneducational
buildings. The state had spent three-quarters of a million dollars to review plans at that
point in time and had almost completed their review process. Some plans were reviewed
and returned to the districts as many as three times.
At the time of the last interview, the department had not conducted any compliance
inspections but was planning to inspect buildings in districts that have received Asbestos
Inspection Management Plan Assistance Program (AIMPAP) grants. They were also
tentatively planning to send reminders about abatement through the Department of
Education and to convene regional meetings with approximately six school districts at a time
to remind them of their abatement commitments.
4.2.5 Pennsylvania
It is unclear which agency coordinates the Asbestos program in Pennsylvania. As of March,
there were competing bills in the state legislature, one which would place the program under
the Department of Environmental Resources and one that would place it under the
Department of Labor and Industry. This is evidently a politically sensitive issue in
Pennsylvania and one informant speculated that the issue would not be settled until after
a primary election, which was scheduled for May 1990. As a result, the state has been
somewhat inactive with respect to this program.
There is no Accreditation Program in place. EPA approved training for management
planners, etc. has been provided by Temple University, other colleges and contractors. The
governor only recently appointed the Department of Education to review Management
Plans. Originally, reviews were to be performed by the Department of Environmental
Resources.
Compliance inspections are done by the EPA regional staff and only 24 schools in the entire
region are scheduled for inspection in 1990.
4.2.6 Tennessee
The Asbestos coordinator in Tennessee is in the Department of Finance and Administration.
The state has been somewhat active with respect to this program.
-------
__^ 4-10
As of March 1990, the Department of Finance and Administration was helping to develop
legislation to establish an Accreditation Program. The program will closely resemble EPA's
but will expand approved training curricula to include state-specific information.
The department developed a standard format for management plans and implements three
levels of plan review.
Level A review for completeness is implemented for all plans.
Level B review is implemented primarily in districts that have received AIMPAF
grants. These are in-depth reviews of the plans of at least five elementary
schools, one middle school and one high school.
Level C review is implemented in districts that have received Asbestos School
Hazard Abatement Act (ASHAA) grants. These are on-site audits in which
inadequate or incorrect sampling is corrected immediately.
The department developed a consulting contract for asbestos management banners,
inspectors, designers, etc. The state was divided into four regions and a "bulk" contracting
procedure was established, enabling local school districts to contract with consultants at
lower rates. School districts who wished to do so could contract with consultants
independently. Included in the regional consulting contract were two hours of training for
district personnel. Districts could avail themselves of a contract extension that provided for
an additional 14 hours of training.
The department has held three regional meetings on writing ASHA grant applications and
school districts in the state have received $3.3 million dollars in ASHA grants. In addition
to ASHA funds, which go directly to the districts, the state has been able to fund a large
number of school districts through AIMPAP grant funds because of the "bulk" contract that
reduced consulting fees. It is apparent that with the coordination of the program under the
state's Finance Department, one successful emphasis was on driving down the costs to the
local school districts.
4.2.7 Texas
The coordinating agency for the Asbestos program in Texas is the Division of Occupational
Safety and Health, Department of Health. The state has been very active with respect to
this program.
The state's Accreditation Program is almost identical to EPA's with the following exceptions:
The state charges school districts a fee for initial review of management plans.
-------
4-11
Asbestos contractors must be licensed by the state.
Workers who disturb asbestos must be registered with the state.
A high school education is recommended for asbestos personnel. As in EPA's
program, this is not required.
The situation in Texas is unique. The state School Board Association staff took the
appropriate EPA approved courses and became accredited management planners,
subsequently working directly with many school districts on their plans. The Association
also provided funds to the University of Texas and Texas A & M University to conduct
awareness seminars and training for inspectors. State officials believe that the Association's
role made the Asbestos program far easier for local school districts than it might otherwise
have been.
Management Plans were initially reviewed by engineering graduate students at the
University of Texas and Texas A & M University. The students apparently had some
difficulty communicating to the districts what they were looking for in a Management Plan.
The result was that many plans were reviewed numerous times. When the contracts with
the universities expired, the review process was transferred to the Division of Occupational
Safety and Health. All plans are reviewed in full.
Compliance inspections are being conducted in a random sample of school districts. The
state has a cooperative TSCA grant to conduct these inspections with EPA regional staff.
Many rural school districts in Texas use a cinderblock construction that requires no
insulation. As a result, many school buildings have very little ACM.
4.3 RESPONSE FROM THE SCHOOL DISTRICTS
Three hundred seventy-four school districts in seven states responded to the Asbestos
portion of this survey. Seventy-one percent of the respondents are either school
superintendents or assistant superintendents (Table 3-7). In most cases the individual
completing the questionnaire is the person who is primarily responsible for the district's
Asbestos program and these individuals have considerable experience in their district. On
average, respondents have been with their districts for close to 12 years and in their current
positions for just over seven years. This average length of service is significant in terms of
respondents' general knowledge about the given issues.
Responses to many of the survey items are very similar across states; when that is the case,
the results are reported only for the total sample. In cases where responses differ among
the states and sample sizes are sufficient, summary tables by state are provided.
-------
4-12
As discussed in Chapter 3, both the respondents' perception of health risk and expressions
of concern by the public and staff concerns regarding asbestos-containing materials are the
highest of the environmental threats considered, but are significantly lower than the
comparable ratings for drugs, alcohol, and tobacco.
4.3.1 Familiarity with Regulations and Recommendations
Question 7 in the Asbestos survey asks respondents to rate, on a five-point scale (where 1
signifies "not familiar" and $ signifies "very familiar") their levels of familiarity with both
state and federal regulations and guidelines for managing and abating asbestos-containing
materials. Since the Asbestos-in-Schools Rule under AHERA has been in effect since 1987,
it is not surprising to see that the mean levels of familiarity with the federal regulations, as
depicted in Table 4-2, are relatively high (total sample mean = 4.2). There is very little
differentiation in1 familiarity among the states, which is also in line with expectations at this
stage of the ACM program.
The levels of familiarity with the regulations fall below the sample mean in two states:
Pennsylvania and Ohio. In Pennsylvania there was still no Accreditation Plan in place at
the time of the survey. Ohio was in the process of revising their Accreditation Plan to close
some loopholes and conform more closely with federal standards. Mean levels of familiarity
with both sets of regulations are slightly higher in the state of New York, where the
Department of Education has done intensive training with school districts.
4.3.2 Receipt of and Response to EPA Materials
One focus of this study is to evaluate the guidance materials that the EPA has provided for
school districts on the three programs under study. In Question 8 respondents were asked
to indicate the sources of information that their district has used to help determine ACM
management and abatement actions. This item was included early in the questionnaire to
determine if respondents would mention EPA's materials prior to their being specifically
identified. The responses to this question are summarized in Table 4-3. Statistics for the
total sample indicate that larger proportions of the districts indicate using EPA's pnnted
materials as well as various workshops and seminars more than any other sources. Only in
Illinois, where the state's regulations are much more stringent than AHERA's, is there a
slightly larger proportion relying on printed materials from their state health department.
Of the three programs in this study, the Asbestos program is the only one in which EPA has
directly disseminated guidance materials to the nation'?,school districts. Table 4-4 reveals
that 80 percent of the respondents recall receiving the materials. This is a much higher
-------
Table 4-2
Reported Level of Familiarity with Slate and Federal Regulations Concerning Asbestos in Schools
Q7: "How familiar are you with state and federal regulations and guidelines for ihe
containing materials in schools?" (1 - not at all familiar to 5 = very familiar)
Factor Statistic
Sample size
Stale regulations and guidelines
Federal regulations and guidelines
n
mean
SE(nuan)
mean
SE(mean)
All
374
4.23
.04
4.20
.04
Colorado Idaho
44
4.30
.13
4.30
.13
Illinois
59
4.30
JO
420
.10
management and abatement of problems related to
Stale *
New York
SI
450
.10
440
.02
Ohio
58
4.00
.12
4.00
.12
Penn
49
4.13
.14
4.04
.15
S Carolina Tenn
37
4.22
JJ
423
JJ
asbestos
Tesas
74
428
09
425
09
Blanks indicate stale not in sample for this question.
-------
Table 4-3
Sources of Information Determining Actions Related to Asbestos Containing Material?
O8: "Which of the following has your district used to
(more than one may apply)
Source
Piloted materials from the U.S. Environmental
Piotedioo Agency
Printed materials from the Stale Health Dept.
Newspaper, other printed media. TV and Radio
Woikshops or seminars
No inforjpialion has been obtained
All
85%
77%
38%
83%
1%
help determine actions on the management and abatement of asbestos containing materials?"
Percentaoe bv Stale
Colorado Idaho
84%
77%
39%
84%
0%
Illinois
85%
88%
34%
80%
0%
New York
84%
78%
29%
94%
2%
Ohio
91%
81%
44%
83%
3%
Peon S.Carolina Tena
92% 78%
73% 57%
39% 54%
82% 89%
0% 0%
Teias
82%
78%
31%
77%
0%
Blanks indicate slate not in sample for this question
-------
Table 4-4
Has District Received EPA Asbestos Materials
Q26: "Several booklets and manuals such as The ABCs of Asbestos in Schools", "100 Commonly Asked Questions about the New AH ERA
Asbestos-in-School Rule" and "Asbestos in Schools: A Guide to New Federal Requirements" have been provided to local school districts
by the U.S. EPA. Do you recall receiving any of these materials?"
Percentage hv Stale
Factor
No
Yes
All
194%
ao.2%
Colorado Idaho
159%
84.1%
Illinois
14.3%
85.7%
New York
15.6%
84.4%
Ohio
25.0%
75.0%
Peon
29.2%
70.8%
S.Carolina Tenn
21.6%
78.4%
Texas
183%
817%
Blanks indicate slate not used in sample
-------
4.16
proportion than exists in either of the other two programs being considered, where state
agencies have been responsible for disseminating EPA materials (See Chapter 7.0).
The fact that EPA published and disseminated three different guidance pieces for the
schools (see Section 4.1) attests to the complexity of the regulations governing school actions
on asbestos. In Question 27 respondents rated these materials on five point scales in terms
of their being clear and understandable; instructive and informative; and complete. Mean
ratings of the materials, across the seven states, are relatively positive for each of these three
categories. Over two-thirds of the respondents report that the materials affected their
districts' actions or plans at least "somewhat" (Q28). In addition, the higher the ratings, the
more respondents report their plans and actions being affected by the materials. These
findings are described for the total sample in Table 4-5.
Table 4-6 describes the responses to Question 29, which queried respondents on where they
would have sought guidance on inspecting and correcting for asbestos problems if EPA had
not made these materials available. In most of the states, respondents would have turned
primarily to the state departments of either health or environment. In Colorado, Ohio and
Pennsylvania large proportions (two-thirds or more) say they would have turned to
environmental consulting firms. This is an interesting finding and has implications for the
EPA in terms of who should have relevant information on environmental concerns affecting
schools. EPA may wish to make even more concerted efforts to assure that environmental
consulting firms have correct and complete information on school-related programs.
4.3.3 Management Plans
By the time of the survey 98 percent of the districts responding to the survey indicated that
their management plans had been submitted to the state (see Table 4-7.) In Tennessee the
figure is 100 percent. Lower proportions of the districts said that they had already received
comments on their plans from state reviewers (Q12). For example, Table 4-7 reports that
fewer than half the Pennsylvania districts had received comments. This is consistent with
the fact that the entire AHERA process in Pennsylvania was, to a large extent, "on hold"
(See Section 42). In Illinois and Tennessee, the two states that have the most thorough
review processes and are reviewing, at some level, every plan, just under half the districts
had received comments. In several other states, such as Colorado and Ohio, agencies, due
to a lack of personnel, are only reviewing a sample of the plans. The important factor to
note here is that, for a variety of reasons, many school districts have had to begin
implementing their plans without feedback from state reviewers.
-------
1 able 4-5
EPA Material's Effect on Actions Concerning Asbestos
Q28: "Did these materials affect your district's actions or plans regarding asbestos in
Factor
No
Yes. somewhat
Yes, definitely
Ratings by" all respondents
Percentage of lespoodents (about 80%
Materials rated on a scale of 1 - not to
Percentage of Respondents *
28.2%
35.9%
35.9%
of the sample) who said they had received some or all of these
5 -very. SE of the mean score in parentheses.
schools?"
Mean Raljnf
Clear
3.36
(0.14)
3.58
(0.09)
3.60
(010)
353
(0.06)
materials.
$ of Maici ills by Rcpprii
Informative
3.39
(0.13)
364
(0.09)
3.86
(0.10)
3.65
(0.06)
cd Ettets **
Complete
3.44
(0.15)
3.58
(012)
395
(010)
3.68
(0.07)
-------
Table 4-6
Alternative Sources of Information Concerning Asbestos if EPA Materials Had Not Been Available
Q29: "If these U.S. EPA materials had not been available, where would
asbestos problem?" (more than one may apply)
Where
Stale Health or Environmental Department
Regional EPA Office
Environmental Consulting Firms
Information may not have been sought
Ail
62%
31%
52%
7%
Colorado Idaho
86%
43%
65%
3%
your district have sought guidance on inspections and correcting for
Percentaae bv Stale
Illinois
65%
14%
45%
6%
New York
53%
38%
50%
2%
Ohio
61%
34%
66%
7%
Peon
34%
37%
74%
14%
S.CaroUna Tenn
55%
28%
45%
10%
Texas
4UMO.
0T7t>
30%
34%
10%
Blank's indicate stale not in sample for this question
-------
Table 4-7
Status of Asbestos Management Plan Submission and State Review
QIO: "Has your
Response
No
Yes
Q12: "Has your
Response
No
Yes
district submitted its Asbestos Management Plan
All Colorado
1.9% 2.3%
98.1% 97.7%
district received comments on the plan from the
All Colorado
30.0% 238%
70jO% 76.2%
for state review?"
Idaho Illinois
1.8%
98.2%
state reviewers?"
Idaho Illinois
42.9%
57.1%
Percentage by State
New York Ohio Peon S Carolina Tcnn
2.0% 3.5% 2.1% 0%
98.0% 96.5% 97.9% 100%
Percentage by Stale
New York Ohio Penn S.Carolina Tcnn
22.4% 3.6% 57.4% 472%
77.6% 96.4% 42.6% 528%
Teids
14%
986%
Tc«as
21.7%
78 .1%
Blanks indicate stale not in sample for this question
-------
4-20
Some districts that have received comments waited for those comments for the better pan
of a year (Q12). In Colorado the mean amount of time between district submission and
receipt of state comments was around eight months (see Table 4-8). Districts in New York,
where only the AHERA "Five" Summaries are reviewed, waited only an average of around
three months. Table 4-8 also reveals that in Colorado, Ohio and Pennsylvania, where
agencies provided little or no training or other direct assistance, higher proportions of
districts have had to make minor changes in their management plans prior to their being
accepted. In Tennessee, where the state was very active in the management plan process,
a very large proportion of the plans were immediately accepted. However, in Texas, where
the state Association of School Boards was very active in assisting school districts with their
plans, over three-quarters of the districts responding still were required to make changes.
It is possible that this issue is a function of the communications problems between the
graduate student reviewers in Texas and the districts, discussed earlier, in Section 4.2. In
any event, there is evidence that even when a program is federally mandated, state activity
makes a significant difference in what occurs at the district level.
Responses to Question 9 indicate that the largest proportion of inspections and management
plans were done by outside contractors. Table 4-9 shows that New York and Texas had the
largest proportions of trained district staff participating in these efforts.
In summary, almost all the school districts report that they have submitted management
plans but due to various types of lags in state review processes, many are having to
implement those plans without adequate review. Levels of state training and assistance
effort seem to be making a difference in terms of the numbers of plans that have been
accepted as submitted.
4.3.4 Abatement Activities
Responses to Question IS through Question 18 addressed the types of abatement actions
that have been required and the status of these actions. Table 4-10 summarizes these
responses. Overall, 70 percent of the districts in the sample say that they had one or more
buildings requiring removal of ACM. Across all districts, management plans required
removal in an average of 57% of the school buildings. The highest proportion of buildings
requiring removal is in Pennsylvania. The lowest proportion is in Texas, which has the
largest percentage of buildings constructed since 1980 and a large number of rural school
buildings that are constructed using cinderblock with no insulation.
-------
Table 4-8
Time Taken Tor Slate Review of Asbestos Management Plan
Slate *
Variable Statistic All
1 Sample size (stale review complete) n 250
2. Length of time between Asbestos mean 39
Management Plan Submission and SE(mean) .03
slate review (fraction of a year)
3. Was your plan accepted as submitted or
were changes required?
- Plan accepted as submitted % 36.6%
Minor changes required % 62.1%
- Significant changes required % 13%
Colorado Idaho
32
.65
.09
22.6%
77.4%
0%
Illinois
32
.48
.05
56.3%
43.8%
0%
New York
38
.26
.05
735%
23.5%
2.9%
Ohio
54
.43
.04
146%
83.3%
21%
Penn
20
.58
.10
20.0%
80.0%
0%
S.Carolina Tenn
19
.39
.09
944%
56%
0%
Tcus
54
.70
05
157%
82 4%
20%
Blanks indicate slate not in sample for Ibis question
-------
Table 4-9
Who Did the Asbestos Management Plan
Q9: "Who did, or will do, the inspections and writing of your district's asbestos management plan?"
Perccnlage bv Slate
Who
Outside Contractors
District Personnel who look training
Both
Other
All
59.5%
9.5%
27.2%
3.8%
Colorado
59.1%
11.4%
29.5%
0%
Illinois
75.4%
\A%
17.5%
5.3%
New York
41.2%
15.7%
33.3%
9.8%
Ohio
77.6%
6.9%
15.5%
0%
Penn
39.6%
63%
52.1%
2.1%
Tenn
72.2%
2.8%
22.2%
2.8%
Tens
52.8%
18.1%
236%
5.6%
-------
Table *10
Asbestos Repair, Replacement, Spraying and Removal Efforts
(Asbestos Version Questions 15, 16, 17, 18)
Variable
1. % of buildings requiring repair
or replacement of pipes, boiler covers.
building materials, etc.
2. Status of repair & replacement
(% of district reporting need)
- all completed
in progress
- efforts have not begun
3. % of buildings requiring spraying
4
4. Status of spray efforts
(% of districts reporting need)
- all complete
- in progress
- efforts have not begun
S. % of districts with building (s)
requiring removal
6. % of buildings
requiring removal
- 9 buildings
- * complete
Statistic
mean
SE(mtan)
mean
mean
mean
mean
SE(mean)
mean
mean
mean
mean
SE(mean)
mean
SE(mean)
mean
mean
7. When will removal efforts be complete?
% compklcd
- % < 1 year
% < 2 years
- % ^ 2 years
- % no schedule
All
31.3%
1.78
33.7%
53.4%
12.9%
8.6%
1.08
63.7%
23.5%
12.7%
70.6%
2.44
57.5%
.02
4.09
1.89
30.1%
17.7%
129%
221%
17.3%
Colorado Idaho
235%
₯.59
48.3%
41.4%
10.3%
9.5%
3.42
70.0%
300%
0%
75.6%
6.79
49.3%
4.50
370
1.94
484%
12.9%
3.2%
25.8%
9.7%
Illinois
31.6
4.00
23.3%
53.5%
23.3%
71%
2.96
42.9%
21.4%
35.7%
63.2%
6.44
71.9%
503
2.78
1.22
294%
26.5%
23.5%
118%
8.8%
New York
428%
5.27
27.5%
60.0%
12.5%
11.4%
305
66.7%
33.3%
0%
81.4%
6.00
61.5%
4.72
4.59
1.31
175%
150%
17.5%
27.5%
225%
Slate
Ohio
42.0%
5.27
23.4%
638%
12.8%
136%
3.98
50.0%
35.7%
14.3%
73.6%
6.11
67.5%
4.81
430
2.00
23.1%
26%
26%
308%
410%
Penn
40.0%
4.64
44.4%
51.1%
4.4%
8.3%
275
89.5%
10.5%
0%
80.4%
5.91
58.8%
5.02
392
2.42
366%
237%
10.5%
184%
105%
S Carolina Term
349%
5.18
33.3%
533%
133%
108%
2.86
333%
25.0%
41.7%
892%
5.18
54.4%
4.84
500
2.12
226%
25.8%
228%
226%
6.55%
Tcu*
1 1 0%
178
3«>5%
488%
116%
24%
6.S
786%
14 V'A,
1 1%
511 7%
598
372%
4KI
4 )2
212
3<> 1%
II 1%
IV 4%
16 7%
Ih 17,,
Ubnki induce slate not in sample for this
-------
4-24
Table 4-9 also indicates that:
around one-third of repair and replacement actions are completed;
around two-thirds of encapsulation through spraying is completed; and
just under a third of removal efforts are completed.
Correlational analysis indicates there is no relationship between the status of abatement
actions and whether or not districts have received any comments on their management plans
from their state agency. This corroborates concerns that were addressed in Section 4.3.3.
The amount of effort that state agencies have had to put forth to review the plans has made
it difficult for all districts to receive adequate feedback in sufficient time. AHERA calls for
districts to have initiated implementation of their management plans by July, 1989. As
reported in Table 4-7, as of the time of the survey (primarily November and December,
1989) nearly one-third of the districts reported that they had received no comments on their
plans. These districts had no choice but to move ahead with implementation prior to
receiving feedback from state reviewers, or to be in violation of AHERA.
4.3.5 School Expenditures for Asbestos Inspection. Planning and Abatement
To assist EPA in gaining a better understanding of how well the original projections of
AHERA's cost to school districts relate to actual cost. Questions 22 and 23 addressed the
dollar amounts that districts have already expended and what additional expenditures they
anticipate. Table 4-11 summarizes the approximate amounts that school districts have spent
so far and the approximate amounts they expect to spend to fully implement their
management plans. The highest total expenditures are in New York (an average of over
$2 million), the lowest are in Texas (an average of just over $200,000). Average
expenditures by district by state are affected by variations in the average size of school
districts, and therefore facilities per district. To partially normalize for this. Table 4-11 also
indicates the average dollar amount per student that districts have spent and will spend
(total estimated expenditures). On an average, districts are spending on asbestos problems
what they spend in four and one-half years on instructional materials. In many respects,
companng a "one-shot" expenditure that occurs over a period of a few years to a regular,
annual expenditure is comparing the proverbial apples and oranges. Nonetheless, looking
at these figures certainly helps to clarify why some administrators complain that these
expenditures are taking money away from education (Section 4J.6).
-------
Table 4-11
Completed and Planned Expenditures for the Asbestos Program
Average S/Di&lrict bv State
All
Colorado
Idaho Illinois
New York
Ohio
Pcnn
S Carolina Tcnn
Tcidi
Q22: Approrimately how much money has your district
spent so far on inspection, planning and
ahatrmrni irf asforrtiM runlaii
lino materials?
$290.759
$127.707
$322,505
$842.545
$178.173
$380.782
$194^21
$77.575
QM. Approximately how much njore moocv do vou
expect your district will need
to spend to
fully implement your Asbestos Management Plan
Total
Total 'Asbestos Expenditures
per'Student
Annual Instructional Materials
Dollars per Student (IDP)
Ratio of Asbestos Expenditures
tt\ Annual IDP
|U ^HBUIftaU L^B
Percentage of Buildings Built Since
mean
SE(mean)
mean
SE(mean)
mean
SE(mcan)
1980 mean
SE(mean)
Percentage of Buildings Built Before 1959 mean
SE (mean)
$676,452
$979403
$406
68
$71
2
4.6
0.4
19%
1.4
36%
1.6
$844,095
$971.802
$268
50
$74
4
40
0.7
21%
4.3
33%
4.4
$712.552
$1,035,057
$920
411
$75
4
7.0
1.4
12%
3.7
44%
4.7
$1.481.999
$2.324.544
$878
144
$121
5
7.5
1.3
17%
3.9
41%
4.2
$672,235
$850.408
$315
62
$58
3
63
2.5
9%
2.5
47%
44
$488.144
$868.926
$265
44
$73
4
3.6
0.6
16%
3.3
38%
4.0
$713.901
$908.422
$180
62
$42
2
40
1 1
18%
3.7
27%
45
$UOATH
$20^211
$55
10
$57
3
1 1
02
34%
38
25%
31
Blanks indicate stale not in sample for this questions
-------
4-26
4.3.6 Overall Program Evaluation and Comments
In Question 30 and Question 31 respondents rated, on five point scales, the factors that were
important in motivating and helping the districts in their asbestos-related actions and those
factors that were impediments. Table 4-12 indicates that federal requirements and
recommendations were rated as the most important motivating factors for the sample as a
whole. In Illinois and New York, where state requirements are more rigorous than
AHERA's, state requirements and recommendations are rated as just slightly more
important than EPA's.
Funding concerns are what respondents see as the serious impediments (Table 4-13) For
the total sample, "inadequate district funds," "inadequate state funds" and "inadequate staff
to handle the extra work" all received mean ratings of between 3.0 and 4.0 on five-point
scales where 1 signifies "not serious" and 5. signifies "very serious". In Ohio and Tennessee
"inadequate district funds" received mean ratings above 4.0 while "inadequate state funds"
received mean ratings above 4.0 in every state except Pennsylvania (3.56) and Texas (3.52).
As might be expected, the proportions of total estimated expenditures that have already
been spent (i.e., ACM work completed) are correlated negatively with ratings of "inadequate
district funds" as a serious impediment.
Very few respondents added comments to their responses about motivating and impeding
factors. Of those who did, 14 complained about the financial aspects of the program and
noted that the program is taking money from education. Twelve respondents believe that
the problem is exaggerated and that the regulations are too demanding. Other comments
addressed a need for improved communication between EPA and state agencies and a need
for clearer guidelines. These comments are summarized for all three programs in Chapter
7.
In summary, most respondents do not believe that they have bad inadequate information
from either EPA or their state agencies. If there are serious impediments to getting the job
done with respect to asbestos, those perceived impediments are insufficient funds.
4.4 SUMMARY AND IMPLICATIONS
AHERA is a federally mandated program which carries with it specific penalties for non-
compliance. As would be expected, the districts in this study are very familiar with both
federal and state regulations and are essentially in compliance. Almost all have submitted
management plans, and, in accordance with the mandated time line, have begun
imple - entation of their plans even when they have had no feedback from the state. The
arnot of effort that states have put fonh in training school district personnel and assisting
-------
Table 4-12
Rilling of Motivating Factors for the Asbestos Program
Q30: "How important, if at all. do you think each of the following has been
risks due to asbestos? (1 = not important to 5 = very important)
Factor
Sample size
Stale requirements A recommendations
Statistic
n
mean
SE(mean)
Federal requirements A recommendations mean
SE(mean)
Stale technical assistance
Stale financial assistance
U.S EPA materials and lechr;cal assisli
Concerns expressed by public, media
mean
SE(mcan)
mean
SE(mcan)
inccmean
SE(mean)
mean
SE(mcan)
All
374
4J2
.05
449
.04
263
.08
1.99
.08
2.93
.07
2.72
.08
Colorado Idaho
44
4.30
.16
445
.13
2.53
.21
166
.22
2.64
.22
2.33
.22
in motivating and helping your district to
Slate *
Illinois
59
4.44
.12
4.43
.12
2.22
.20
1.58
.16
2.32
.18
2.43
.18
New York
51
4.70
.10
4.62
.12
3.10
.22
3.00
.24
3.12
.20
3.15
.21
Ohio
58
4.24
.12
4.45
.10
2.73
.21
1.86
.18
3.10
.17
2.92
.18
Peon
49
4.06
.19
4.31
.17
2.31
.23
2.03
.21
3.37
.24
3.17
.22
take action on potential health
S Carolina Tenn
37
429
.18
469
.09
3.39
.24
274
.32
319
.23
2H4
.26
Teus
74
430
.12
458
08
241
17
12
2')7
15
2M
16
Blank indicates slate not in sample for this question
-------
Table 4-13
Rating of Impeding Factors for the Asbestos Program
Q3I: "How serious, if at all. do you think each of the following has been
( 1 = not serious to 5 = very serious)
Factor Statistic
Sample size n
Inadequate
Inadequate
Inadequate
Inadequate
Inadequate
Inadequate
district funds mean
SE(mtan)
stale funds mean
SE(mean)
information from the U.S. EPA mean
SE(mtan)
information from slate agencies mean
SE(mean)
expertise in district mean
SE(mean)
staff to handle extra work mean
SE(mean)
All
374
3.79
.08
398
.09
2.38
.07
2.49
.07
2.70
.09
3.25
.09
Colorado Idaho
44
3.83
18
4.22
.19
2.54
.21
2.60
23
2.88
.23
3.38
.23
in impeding your district in taking action on asbestos?"
State
Illinois
59
3.95
.20
4.22
.20
2.43
.18
2.51
.18
2.65
.19
2.96
.20
New York
51
3.80
.21
4.09
.21
2.40
.18
2.68
.19
2.91
.21
3.56
.19
Ohio
58
4.05
.19
4.16
.19
2.25
.16
2.29
.15
2.86
.19
3.27
.20
Penn
49
3.41
.24
3.56
.23
2.20
.17
2.33
.19
2.20
.19
2.93
.23
S.Carolina Tenn
y .
4.29
.21
4.41
.18
2.75
.23
2.66
.23
320
.29
3.91
.26
Texas
74
3.42
.19
3.52
.20
227
.18
245
.18
245
.18
307
.20
* Blank indicate stale not in sample for this question
-------
4-29
them in other ways has affected the quality of the management plans. Those states that did
little or no training generally have higher proportions of districts that had to make some
changes in their plans before they were accepted.
EPA's guidance materials on the asbestos program receive relatively positive ratings. Clear
majorities of the respondents received and are familiar with the materials, which were
disseminated directly to the districts by the EPA. A surprisingly high proportion of
respondents in some states say that they would have turned to environmental consulting
firms for information if EPA had not made guidance materials available. In most states,
respondents say they would have sought guidance from appropriate state agencies.
The economic costs of complying with AHERA are very high. While districts seem
relatively satisfied with the information that they have received from EPA and from their
states, they are likely to cite lack of funds as a serious impediment to getting the job done.
The immense efforts that result from complying with AHERA affect responses to other
environmental hazards, as we see in .later sections.
-------
5-1
5.0 LEAD IN SCHOOL DRINKING WATER PROGRAM AND ANALYSIS
5.1 BACKGROUND AND EPA PROGRAM
Prior to the 1986 amendments to the Safe Drinking Water Act, lead was one of the most
commonly used metals in the construction of plumbing systems. Copper pipes, commonly
used since World War II, were joined with lead solder and lead pipes have been used in the
water distribution systems of many cities. Water coolers that can be found in all public
buildings, including schools, were frequently manufactured with lead linings, lead solder or
lead pans. Relatively recent research indicates that lead in plumbing systems can and does
seep into the drinking water and that lead is highly toxic and harmful to the public health,
particularly to children.
5.1.1 The Lead Contamination Control Act
In response to this information. Congress passed the Lead Contamination Control Act
(LCCA). The LCCA is an additional amendment to the Safe Drinking Water Act and
became law November 1, 1988. It requires the Environmental Protection Agency to provide
guidance to states and localities in testing for and remedying lead contamination in drinking
water in schools and day care centers. The Act also contains specific requirements for
testing, recall, repair and/or replacement of water coolers with lead-lined storage tanks or
with parts containing lead.
Specifically, the Act requires:
EPA to identify and publish a list of drinking water coolers that contain lead and
to prohibit the manufacture and sale in interstate commerce of water coolers
that are not lead free;
the Consumers Products Safety Commission to issue an order requiring
manufactures to either repair, replace or recall these coolers;
EPA to publish and distribute to the states a guidance document and protocol
on testing for and remedying high levels of lead in a school's drinking water both
in coolers and all other outlets, with each state providing for dissemination of the
guidance materials and the list of water coolers that are not lead free;
state certification of laboratories that test drnking water and publication, by the
states, of lists of certified laboratories;
-------
5-2
programs for helping schools to monitor for and remedy high
lead levels in their drinking water; and
EPA grants (at this point authorized but not funded) to assist states.
The only actual mandate to the schools requires them to make available the results of any
testing for lead in drinking water that they conduct
In summary, the LCCA, as it relates to schools, is essentially a voluntary testing program.
Mandatory elements apply primarily to the states and water cooler manufacturers.
5.1.2 State Coordinating Agencies
In February 1989,- the EPA's Office of Drinking Water sent letters to all state and territorial
governors requesting that they appoint a coordinating or contact agency for the Lead in
School Drinking Water program. As of March 1990, only two states had not complied with
this request.
5.1.3 Water Coolers
The first list of affected water coolers was published in the Federal Register in February
1989, and was disseminated to state agencies in April 1989. The finalized list, which was
somewhat shorter, was published in the Register on January 19, 1990. The only recall
necessary thus far has been negotiated with the manufacturer and this information was
published in the Register on April 19,1990. However, additional information about coolers
continues to surface so the process of reviewing water coolers is a continuing one.
5.1.4 The EPA Manual
The manual, "Lead in School's Drinking Water," was published by the EPA's Office of
Drinking Water in April 1989. The manual was to be disseminated to the appropriate state
agencies through EPA regional offices. State agencies received a camera-ready copy and
a limited number of bound copies of the manual. EPA expected state agencies either to
purchase or photocopy a sufficient number to disseminate to their local school districts, as
required by the LCCA.
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S-3
Every local school district received a flyer from EPA, notifying them of the manual's
availability. The flyer contained a form to order the manual from the Government Printing
Office at a cost of S3.25. However, no Government Printing Office number appeared on
the order form, so it was not possible to track how many manuals were actually ordered as
a result of the flyer. School district survey results, reported later, indicate that relatively few
manuals were ordered from the flver alone.
The manual is labeled an interim document; no revisions have been made as yet. Final
manuals are being published for nursery schools and day care centers and these are
scheduled for dissemination during 1990.
5.1.5 Regional Training Seminars
The EPA conducted five regional training seminars for state agency personnel between April
and June 1989. These seminars were held in Atlanta, GA, Boston, MA, Chicago, IL,
Denver, CO, and Seattle, WA. Attendees were encouraged to use the materials and
information that they received in these seminars to conduct similar training sessions for
school district personnel in their own states. An additional seminar was offered by the
National Association of School Boards in Washington, D.C. in June 1989, and other
seminars that addressed lead in drinking water and other environmental concerns were
conducted jointly by EPA and various school organizations in October 1989.
5.1.6 National Primary Drinking Water Regulations
Revised National Primary Drinking Water Regulations for lead in drinking water are
scheduled to be finalized by late 1990. The final "action level" for water suppliers is likely
to be lower than the current marimum contaminant level (MCL) of 50 ppb. EPA
recommends that schools take action to limit exposure or reduce lead in drinking water from
outlets wherever current lead levels exceed 20 ppb.
5.1.7 Additional Comments
The Lead in School Drinking Water program is relatively new and is still evolving. Several
factors are important to note. The first is that the mandate to the states to establish a
program for assisting schools in testing for and remedying high lead levels is relatively vague
and contains no penalties if states choose not to comply. Secondly, while Congress
authorized the EPA to establish a grant program to assist the states in their efforts, no funds
have, as yet, been appropriated. Therefore, the mandate to the states is, at this point, an
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5-4
unfunded one, leaving the costs of implementing testing and remediation programs to the
states and the local school districts. Finally, the presentation of EPA guidelines as "intenm"
may, as a result of earlier experiences with costly changes in the asbestos regulations, lead
some schools to defer any actions. This could be compounded further by the limited direct
distribution of EPA's guidance materials.
52 THE STATE PROGRAMS: LEAD IN SCHOOL DRINKING WATER
There is a great deal of disparity among the nine states with respect to the Lead in School
Drinking Water Program. As indicated earlier, states are mandated to establish programs
to assist the school districts in testing for and correcting lead in drinking water problems but
the mandate is a vague one and specifies no sanctions if states do not comply. At the time
of this study some states had already become very active, disseminating materials,
conducting training and implementing on-site consulting with schools. Others had done very
little. Table 5-1 summarizes the activities across the states.
5.2.1 Colorado
The contact agency in Colorado for the Lead in School Drinking Water program is the
Office of Drinking Water, Department of Health. The state has been somewhat inactive
with respect to this program. According to a key informant in the Office of Drinking Water,
this inactivity is the result of insufficient resources. The office finds that they barely have
sufficient resources to enforce the original Safe Drinking Water Act "let alone the LCCA."
A representative of the office did attend the EPA training seminar in Denver in May 1989,
but, because of insufficient staffing, there ~s no subsequent training for school district
personnel. With the cooperation of the Co .do Association of School Boards, copies of
EPA's manual, "Lead in School's Drinking W u>er," have been distributed to all public school
districts. The office has not had the resources to distribute any additional materials.
The state's Office of Drinking Water receives the test results from any school district using
the state's laboratory facilities and they do contact schools whose lead levels are high. In
addition, they consult on appropriate mitigation techniques with any schools who contact
them for assistance. In other words, their position is a reactive rather than a proactive one.
At the time of the second interview, depending upon the office's ability to hire an additional
staff person in the spring, they were planning to contact districts who have not sampled and
encourage them to do so. They were also planning to ask districts who are using
laborator es other than the state's to send their results to the Office of Drinking Water. No
plans for raining or developing or disseminating additional materials were mentioned. The
issue of financial and technical resources appears to be a major one for this particular office.
-------
Table 5-1
Summary of State Lead In Drinking Water Program*
(March 1990)
DISSEMINATE OtSSEMINATB CONTACT ON-STTI
ATTEND EPA ETA ADDITIONAL WREN LEVELS CONSULTING/ COLLECT
STATE SEMINAB MATEMALS MATERIALS TRAINING* HIGH ASSISTANCE DATA
COLORADO
IDAHO
ILLINOIS
M
VEWYORK
EX
OHIO
M
PENNSYLVANIA X
SO CAROLINA X
EX
TENNESSEE
EX
TEXAS
EX
M - Moderate tritniac EX Etfeuivc Traiaiag
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5-6
5.2.2 Idaho
The contact agency in Idaho for the Lead in School Drinking Water program is the
Department of Education. This designation occurred upon the recommendation of the
Department of Health, whose situation was described as having no resources to deal with
the LCCA and as having enough difficulty keeping up with the demands of the Safe
Drinking Water Act. The state has been somewhat active with respect to this program.
A representative of the Department of Education attended the EPA training seminar in
Seattle in June, 1989. The seminar was described as inadequate for giving a non-technical
person what is needed to conduct similar sessions for school personnel. Consequently, there
was no subsequent training for school district personnel in Idaho.
In cooperation with the state's Department of Health, the agency has distributed, to every
school district, a packet that contained:
a photocopy of the manual, "Lead in School's Drinking Water";
a list of offices and agencies, in each of the state's six regions, that hold
appropriate expertise and could assist school districts with testing and
remediation;
the EPA list of water coolers with lead lined tanks or lead pans;
a list of the state's certified laboratories; and
a questionnaire, asking for the number of water coolers in each school, the
number of lead-lined water coolers, a description of sampling activities and
results, a description of remediation efforts and a response to a question about
public notification of test results.
A key informant in Idaho expressed general disappointment in the way the EPA is
conducting the Lead in School Drinking Water program. He believes that as long as the
program is "permissive," the desired actions from states and local school districts will not
occur. He suggests that, if the program to succeed, EPA must:
find some way to help states and school districts offset their costs;
give more intensive training and guidance; and
provide a model program rather than expecting state agencies to create a
program.
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5-7
5.2.3
The contact agency in Illinois for the Lead in School Drinking Water program is the
Division of Environmental Health. The state has been somewhat active with respect to this
program. The representative from the division commented that they are doing all they can,
given the lack of available funds. He also noted that school superintendents were resistant
to the program because "they know radon is coming and they were just zapped with
asbestos."
Three representatives attended the EPA training seminar in Chicago in May 1989.
Subsequently, the agency conducted a training session for state employed plumbers and
regional engineers as well as a seminar for school superintendents. They encouraged
regional engineers to conduct similar training sessions for school personnel in their regions
but are not certain if all engineers complied. The degree of compliance probably depended
upon the amount of requests for information. The division is not tracking these training
sessions.
During the summer of 1989, public school districts received packets containing the following:
a cover letter;
a photocopy of the manual, "Lead in School's Drinking Water";
an order form for additional copies of the manual;
a copy of the Lead Contamination Control Act;
the EPA list of water coolers with lead-lined tanks or lead pans; and
a list of the state's certified laboratories.
The agency is providing additional information to schools on request and regional engineers
are advised to sample for Lead in the drinking water whenever they are in a school building.
It is interesting to note how much more stringent the state is with respect to its asbestos
program than it is with respect to lead in drinking water.
5.2.4 New York
The contact agency in New York for the Lead in School Drinking Water program is the
Department of Health, working in cooperation with the Departments of Education, Social
Services and State (which is in charge of building codes). The state has been somewhat
active with respect to this program in spite of some differing ideas on approach between the
Departments of Health and Education.
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5-8
In 1989 there was a statewide prohibition on out-of-state travel because of budgetary
constraints; consequently, no one from New York attended the EPA training seminar in
Boston in April 1989. Nonetheless, the Health Department has provided training to school
districts at regional Boards of Cooperative Educational Services (BOCES) meetings
throughout the state. They have also made several presentations, by invitation, in individual
school districts.
They disseminated photocopies of the manual, "Lead in School's Drinking Water" to all
school districts in May 1989 and, at a later point, disseminated the EPA list of water coolers
with lead-lined tanks or lead pans as well as a fact sheet with additional information about
the program.
They are disseminating, through the BOCES, a questionnaire which asks for information on:
sampling activities and results; ind
a description of remediation efforts.
Respondents in New York express some frustration with the EPA, claiming that the "right
hand doesn't know what the left hand is doing." They have found that, when school
personnel contact the EPA regional office, there are differing responses to questions,
particularly about MCLs. This very probably relates to the difference between what is
currently regarded as acceptable for water suppliers (50 ppb) and what is recommended for
school drinking water at each outlet (20 ppb). EPA staff is aware that this differentiation
has been confusing.
In addition, since multiple New York agencies deal with environmental issues. EPA's
dissemination of materials to only one agency may not be adequate. Finally, one New York
respondent commented that it would be helpful if EPA "would get off this interim stuff."
5.2.5 Ohio
The contact agency in Ohio for the Lead in School Drinking Water Program is the
Department of Health. The state has been somewhat inactive with respect to this program.
Initially, there was difficulty in deciding which agency - the Department of Health or the
Ohio Environmental Protection Agency - should act as the contact agency. Both agencies
claimed insufficient funds to deal with the program. In March 1989 the two agencies
cooperatively drafted a letter to the EPA Regional Office, stating that neither agency was
willing to implement the LCCA unless federal funding, were made available. They later
notified the EPA Regional Office that the Health Department would act as the contact
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5-9
agency but that no significant progress could be made without funding. One respondent
called this "a classic case of the federal government setting up a program with no money and
then the states set themselves up to get shot at."
Two representatives of the Health Department did attend the EPA training seminar in
Chicago in May 1989. The department held eight workshops for local and county health
department personnel but none specifically for school district personnel.
There are no funds for either purchasing or photocopying the "Lead in School's Drinking
Water" manual. Consequently, none has been disseminated to school districts by the Health
Department. Schools that have their own water supplies and are, therefore, categorized as
public water suppliers have received some information on the program with advice to
sample the drinking water for lead.
Some results of sampling in both homes and schools have been sent to the department and
the department has contacted those entities with high levels of lead and advised them to
retest. Remediation procedures have been explained. The department has no statistics on
what proportion of school districts have sent them sample results nor do they have
information on how schools are dealing with repair or replacement of water coolers with
lead-lined tanks or lead parts.
One respondent expressed the opinion that this program has been "handled very loosely" by
the federal government. As of February 1990, there was still no water cooler recall from
the Consumer Products Safety Commission. (As stated in Section 5.1, this information was
not published in the Federal Register until April.) The delay in publishing this information
coupled with no funds being appropriated caused this individual to express concern about
how seriously the federal government views lead in drinking water.
5.2.6 Pennsylvania
The contact agency in Pennsylvania for the Lead in School Drinking Water program is the
Department of Environmental Resources. Inadequate funding has caused the state to be
somewhat inactive, thus far, with respect to this program.
A representative of the department did attend the EPA training seminar in the spring of
1989 but, due to insufficient staff, there have been no training sessions for school district
personnel. The department has requested funds to hire a consulting firm to train personnel
from the schools but as of March 1990, that request had not been approved.
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5-10
The department has purchased 6,000 copies of the manual, "Lead in School's Drinking
Water," but these had not been disseminated as of March 1990. The department planned
to send the manuals in packets which would also contain
a cover letter;
the newly revised EPA list of water coolers with lead-lined tanks or lead parts;
and
o a list of the state's certified laboratories.
Sending the packets was "on hold," pending the above-mentioned request for training funds.
If the request were not approved, they would delete the reference to training from the cover
letter and send the packets "soon." The department had sent around 40 packets to districts
that had requested the information.
The department originally proposed that they would provide technical consulting on
remediation, with less affluent school districts receiving the greater proportion of assistance.
No allocation of funds was made for this purpose.
A key informant described the EPA manual as a good one and found it to be clear and
well-written; but he believes that the guidelines are complex enough to require some
training for personnel and questions the state's willingness to provide the requested funding.
5.2.7 South Carolina
The contact agency in South Carolina for the Lead in School Drinking Water program is
the Bureau of Water Supply and Special Programs, Department of Health and
Environmental Control, working in cooperation with the Department of Education. The
governor of South Carolina appointed a contact agency early in the process of this program.
The Bureau of Water Supply had published their own booklet on the original requirements
of the Safe Drinking Water Act and the state has been very active with respect to this
program.
A representative of the bureau attended the EPA training seminar in Atlanta in May 1989.
The agency conducted subsequent seminars for school officials and maintenance personnel
throughout the state and also met with individual school boards.
Copies of the manual, "Lead in School's Drinking Water" were distributed to all school
districts in packets which also contained:
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5-11
the EPA list of water coolers with lead-lined tanks or lead parts;
e a list of the state's certified laboratories; and
two booklets developed by the state, "Lead in Your Drinking Water" and
"Common Water Quality Problems and Their Treatment."
In addition, staff members of the bureau have visited all schools in the state and provided
consultation on sampling. Considerable publicity has been generated about the issue and
the bureau is finding that schools are contacting them and taking action if their samples
indicate lead in drinking water problems.
5.2.8 Tennessee
The contact agency for the Lead in School Drinking Water program is the Division of Water
Supply, Department of Health. The state has been somewhat active with respect to this
program.
A representative of the division attended the EPA seminar in Atlanta in May 1989. In July,
the agency, in cooperation with the Department of Education and the Association of School
Boards, conducted a series of training sessions for school districts on lead in drinking water,
radon gas, underground storage tanks and asbestos. A second series of training sessions was
conducted in December 1989 and January 1990.
Because they believe that some portions of the manual, "Lead in School's Drinking Water"
are unnecessarily complicated, the agency reproduced only particular sections and, in
cooperation with the Department of Education, disseminated these to all school distncts in
packets also containing:
a letter from the Consumer Products Safety Commission;
o a list of the state's certified laboratories; and
information on ordering the manual, "Lead in School's Drinking Water."
Updates and reminders about the program are included in the Department of Education's
periodic mailings.
The division is receiving questions from school superintendents about what the law actually
requires them to do. One respondent noted that a close reading of the LCCA indicates that
schools do not have to sample for lead in the drinking water and commented that EPA's
procedures could have been "a lot better."
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5-12
The division has requested schools to send copies of their sampling results from water
coolers to the Consumer Products Safety Commission, but they have no way of knowing if
this is occurring. As of February 1990, they were relatively sure that only a fraction of the
schools were complying with this request.
5.2.9
The contact agency in Texas for the Lead in School Drinking Water program is the Division
of Water Hygiene, Department of Health. The state has been somewhat active with respect
to this program, in spite of initial expressions of concern about insufficient staff and funding.
During the initial interviews, one respondent commented that the federal government cannot
"just give this to the states and expect them to take this on; the state's resources don't allow
for it."
One representative of the division attended the EPA training seminar in Atlanta in May
1989. Subsequently, the agency conducted a seminar for school superintendents. The Lead
Contamination Control Act has been addressed at approximately 15 to 20 regional seminars
and a representative of the division spoke about the Lead in School Drinking Water
program at a National Education Association day-long meeting on environmental issues.
In June 1989, the division, in cooperation with the Department of Education, sent each
school district a packet which contained:
a photocopy of the manual, "Lead in School's Drinking Water";
the EPA list of water coolers with lead-lined tanks or lead parts;
a suggested protocol for determining which water coolers are not lead free; and
cost information.
This packet was followed by a letter that was signed jointly by the Commissioner of Health
and the Commissioner of Education and requested schools to send their sampling results
to the Consumer Products Safety Commission with a copy to the Division of Water Hygiene
There has been considerable response from the schools to this request and, while the
respondent had no firm statistics, he believed that he had "about a foot" of sampling results
on file.
According to one respondent, the delay in publishing water cooler recall information caused
some confusion for school personnel as did the delay in publishing a final list of water
coolers requiring repair or replacement.
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5-13
5.3 RESPONSE FROM THE SCHOOL DISTRICTS
Four hundred and thirty-six school districts in nine states responded to the survey on Lead
in Drinking Water. Over two-thirds (72%) of the respondents are school superintendents
(Table 3-7). Respondents are primarily the individuals who are directly responsible for the
program(s) being studied and have considerable experience in their district. On average,
respondents have been with their district about 11 years and in their current position for
seven years. These figures indicate that respondents' average length of service is significant
in terms of respondents' general knowledge about their district.
Responses to many of the survey items are very similar across states and when that is the
case the results are reported for the total sample. When differences among states are worth
noting, and where sample sizes are sufficient, findings are reported by state in summary
tables.
Early questions in the survey instrument (Q7 and Q8) dealt with some descriptors of the
districts such as the sources of their water supplies and any regular drinking water testing
programs. Districts that own their own water supplies are considered public water suppliers
and are, therefore, affected differently by the LCCA (See Section 5.1.6.). Only one-fourth
(25%) of the districts in the sample indicate that they own their water supply. A clear
majority (80%) of the sample purchase all or some of their water from their local
community while a very small proportion (7%) purchase water from private suppliers.
Nearly half (47%) of the districts report that there is no regular program for testing their
districts' water for contaminants, metals or other problems. Those districts that do have
regular testing programs report a very wide range of frequencies from annually to weekly.
These findings are summarized in Table 5-2.
.As discussed in Chapter 3, both the respondents' perceptions of health risk and expressions
of public and staff concerns regarding lead in drinking are relatively low across the whole
sample. These ratings fall just ahead of those for radon and other drinking water concerns,
but significantly less than concerns about asbestos containing materials.
5.3.1 Familiarity with Regulations and Recommendations
In Question 9 respondents were asked to rate, on a five-point scale from "not at all familiar"
[1] to "very familiar" (5], their level of familiarity with both their state's and the federal
regulations and guidelines for testing for and correcting lead in school drinking water.
Table 5-3 describes the mean ratings for the total sample and for each state.
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Table 5-2
Drinking Water Testing Frequency
Q8: "Is there a regular program for testing your districts drinking water for contaminants, metals, or other problems?"
(N=4I1)
Number Percent
No 191 46.5%
Yes 220 53.5%
Q8A: (If yes to Q8), "How often does your district test drinking water supplies?" (N = 188)
Number Percent
More often than monthly 17 9%
Monthly 62 33%
Less often than monthly bu.t
more often than annually 63 33%
Annually 46 25%
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Table 5-3
Reported Level of Familiarity with Slate and Federal Regulations Concerning l^ead in School Drinking Water
Q9: "How familiar are you with slate and federal regulations and guidelines for testing for and correcting lead in school drinking water?"
( 1 = Not at all familiar to 5 = very familiar)
Stale
Factor Statistic
Sample size
Stale regulations and guidelines
Federal regulations ar*d guidelines
n
mean
SE(mean)
mean
SE(mean)
All
436
3.07
06
3.06
06
Colorado
41
307
.19
3.05
.18
Idaho
41
300
.16
3.00
.16
Illinois
57
2.35
.16
233
.15
New York
53
3.44
.17
3.36
.17
Ohio
47
289
.15
278
.15
Perm
51
314
.16
3.10
.16
S Carolina
36
3.S6
.16
3.56
.15
Tenn
31
245
.17
255
18
Tc»ai
72
3.58
.15
361
14
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5-16
Within the total sample the levels of familiarity with state and with federal regulations and
guidelines are very similar but reported levels of familiarity are somewhat higher in three
states (New York. So. Carolina and Texas). As we noted in Section 5.2, each of these states
has conducted relatively extensive training on lead in drinking water for school districts and
each has fully disseminated both EPA and other materials on the program. The state of
Tennessee has also implemented training and disseminated materials and had accomplished
both these actions by the time of the districts' survey; nonetheless, the mean ratings of
familiarity in Tennessee are lower than would be expected, given this level of state effort.
Subsequent analysis (Section 53.5) suggests that financial considerations may be affecting
the responses of Tennessee's districts to the Lead in Drinking Water program.
5.3.2 Receipt of and Response to EPA Materials
One focus of this study is to explore the importance and usefulness of EPA's training
activities and materials to the nation's school districts. Question 10 of the survey inquires
about the information sources school districts have used to help determine their actions on
testing for and correcting lead in drinking water problems. This question preceded any
detailed discussion of the program to see if respondents would identify EPA efforts and
materials prior to their being described in the questionnaire. The results of Question 10,
reported in Table 5-4, indicate that EPA materials were important. In general, more
respondents cite printed materials from the EPA than they do any other source. Printec
materials from state health departments are also used significantly; in Colorado and Texas,
state materials are cited by a higher proportion of respondents than are EPA materials.
Respondents in Colorado are also more likely to use the media in this regard.
Subsequent questions about the EPA materials find that nearly half the respondents report
they have received EPA's manual, "Lead in School's Drinking Water (Q17)." Nearly one-
third reported that they did not have the manual and almost one-fifth said that they did not
know.
Table 5-5 summarizes from where, if at all, school districts have obtained the EPA manual
(Q16) and reveals some interesting facts. First, the states that have been at least somewhat
active with respect to materials dissemination and training (i.e. Idaho, New York, So.
Carolina, Tennessee and Texas) do have the lowest proportions of districts reporting no
awareness of the manual. This is certainly indicative that state activities have had an impact
on the awareness of EPA materials. Secondly, relatively low proportions across the states
say that they have "no current plans to obtain the manual" (from 2% in Idaho to 15% in
Colorado). And, finally, state departments of health or education are, in general, the more
likely sources for obtaining the manual, while the Government Printing Office, through the
order form enclosed in EPA's flyer, is the least likely source. These findings strongly suggest
-------
Table 5-4
Sources of Information Determining Actions Related to Lead in Drinking Water
QIO: "Which of the following has your district used to help determine actions on testing for and correcting lead in drinking waer problems?"
(more than one may apply)
Percentage bv Slate
Source All Colorado Idaho Illinois New York Ohio Pcnn S.Carolina Tcna Tcias
Printed material* from the U.S. EPA 70% 61% 76% 54% 70% 68% 72% 92% 58% 78%
Printed materials from the Stale Health Department 64% 78% 68% 42% 64% 57% 52% 78% 55% 88%
Newspaper, other printed media. TV and Radio 24% 41% 22% 33% 21% 11% 36% 19% 19% 15%
Workshops or seminars 22% 22% 12% 4% 38% 11% 28% 22% 48% 21%
No information has been obtained 11% 17% 10% 26% 2% 21% 4% 3% 13% 3%
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Table 5-5
Where Districts are Obtaining the EPA Manual Entitled 'Lead in School Drinking Water"
QI6: "In the spring of 1989, (he U.S. Environmental Protection Agency (EPA) sent a flyer to all local school districts and state health and education
agencies announcing a manual entitled "Lead in School Drinking Water". From where, if at all, have you obtained or will you obtain this
manual?" (more than one may apply)
Perccnlae bv Stale
Where
Government Pruning office using order form
in the flyer
Slate Department of Education or
Department of Health
From the Regional EPA or the Federal EPA offices
Not aware of this manual
No current plans lo obtain Ibis manual
All
13%
34%
18%
23%
8%
Colorado
15%
33%
25%
35%
15%
Idaho
10%
51%
17%
12%
2%
Illinois
21%
18%
18%
33%
11%
New York
17%
48%
8%
13%
8%
Ohio
4%
17%
13%
49%
9%
Penn
11%
16%
25%
29%
10%
S.Carolina
17%
42%
22%
6%
3%
Tenn
10%
55%
23%
13%
3%
Texas
10%
39%
18%
14%
10%
QI7: Have you receive*! the manual?
No
Yes
Don't know
31.8%
49.2%
19.1%
46.2%
28.2%
25.6%
19.5%
68.3%
12.2%
46.4%
37.5%
16.1%
26.9%
59.6%
13.5%
46.7%
22.2%
31.1%
43.8%
37.5%
18.8%
11.1%
77.8%
11 1%
290% 171%
48.4% 629%
22.6% 20jO%
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5-19
that attempting to reach the school districts with a flyer and an order form that requires
them to pay for materials is not a successful information dissemination strategy. Such time
and money would appear to be more effectively spent in more substantive communication
with appropriate state agencies.
In Question 18 and Question 19 respondents who had obtained the "Lead in School's
Drinking Water" manual were asked about its effects on their districts' actions or plans
regarding lead in drinking water tests and were also asked to use five point scales to rate
the manual on three descriptors: clear and understandable; instructive and informative; and
complete. Table 5-6 shows that almost two-thirds of those who have obtained the manual
report that it had at least some impact on either their actions or their planned actions. The
table also indicates that the mean ratings of the manual in the three above-mentioned
categories are positive. In addition, Table 5-6 shows that the higher the mean ratings of the
manual, the greater its reported effect on a district's actions or planned actions.
Receipt of the manual is positively correlated with familiarity with federal regulations and
recommendations and with state regulations and recommendations. These correlations
reinforce two points.
1. The manual is having a positive effect with respect to imparting necessary
information about federal regulations and recommendations.
2. Since the manual obviously does not address state programs, a relationship
between receipt of the manual and familiarity with state regulations and
recommendations can only be occurring because of the additional state
efforts that are accompanying the manual's dissemination.
Table 5-7 describes the sources that state agencies would have used for information on
testing for and remedying lead in drinking water if the EPA's manual had not been available
(Q20). The majority of respondents indicate that they would have sought the information
from their state department of health or environment. It is interesting to note that, in
Colorado, Illinois, Pennsylvania and Texas, relatively substantial proportions of respondents
say they would have sought guidance from environmental consulting firms. This has
implications for EPA in terms of the audience for its materials. If school districts turn to
private consulting firms for this type of information and guidance,'then EPA may wish to
assure that such firms have the correct information to impart.
In summary, those respondents who have obtained "Lead in Schools' Drinking Water"
generally regard it as a useful tool that is clear, informative and complete. It has had an
effect on districts' actions. The problem lies, not in the nanual itself, but in its distribution.
Reliance on state agencies to disseminate this tool has not been totally effective. In
-------
Table 5-6
Manual's Effect on Actions or Plans Concerning Lead
QI9: "Did the manual affect your district's actions or plans regarding testing the drinking water for lead?"
Response
Number of
Respondents
Percentage of Ropondcnls*
MciB BalJBB flf MflBUil trV Reported Effect **
Ckar Informative Complete
No
Yes, somewhat
Yes. definitely
73
72
60
36.0%
35.0%
29.0%
3.53
(0.14)
3.79
(O.t0)
4.05
(0.63)
3.63
(0.13)
3.87
(0.10)
4.18
(0.97)
3.65
(0.15)
3.79
(0.11)
425
(0.11)
Ratings'!)} all respondents
3.77
(0.07)
3.87
(0.07)
3.87
(0.07)
Percentage of respondents (approximately 50%) who reported having received the manual
* Standard error of.im.in in parentheses
-------
Table 5-7
Alternative Sources of Information Concerning Lead in Drinking Water if the EPA Manual had not Been Available
Q20: "If the manual 'Lead in School Drinking Water' had not been available, where would your district have sought guidance on testing and
correcting for lead in drinking water supplies?" (more than one may apply)
Percentage bv Slate
Souicc All Colorado Idaho Illinois New York Ohio Pcnn S.Carolina Icon Texas
Sine Health or Environment Department 65% 62% 68% 45% 69% 67% 43% 71% 75% 76%
Regional EPA office 25% 38% 25% 32% 22% 42% 52% 21% 7% 15%
Environmental Consulting Firms 17% 31% 7% 23% 16% 0% 43% 14% 0% 20%
Information may not have been sought 12% 15% 29% 5% 9% 0% 5% 18% 20% 7%
-------
5-22
addition, school personnel seem to want more specific direction than the manual alone can
provide and rely, primarily, on state agencies for this assistance - assistance that not all
states are prepared to give.
5.3.3 Water Coolers
A clear majority of the respondents say that they have seen EPA's initial list of water
coolers that should be tested, repaired or replaced. Table 5-8 summarizes these responses
by state. The results indicate that high familiarity with the list is again correlated with state
efforts. Those states in which the coordinating agencies disseminated the list generally have
higher proportions of districts reporting that they have seen the list.
5.3.4 Testing for-Lead in School Drinking Water
Fewer than half of the sampled districts had tested their buildings for lead in the drinking
water at the time of the survey. However, approximately two-thirds of those who had not
yet tested reported that they were planning to do so within the next twelve months. When
these two variables (have, issifid and plan IQ ISSl) are combined, the highest proportions of
positive responses are in three of the states with strong Lead in School Drinking Water
programs: Texas, So. Carolina and New York. Texas and New York also have the highest
proportions of districts that have already tested. These results are summarized in Table 5-9
The "plan to test" responses should be cautiously interpreted because there is no guarantee
that all the plans will be executed.
The number of districts who had tested by the time of the survey is small; therefore, the
statistics for this group are summarized for the sample as a whole rather than by state.
Over half (57%) of the districts that have tested report that no
re testing or corrective actions were necessary.
Those few districts that have tested and found problems are more likely to
consider lead in drinking water a more serious health risk (Q5).
Having tested is positively correlated with familiarity with both federal and state
regulations and recommendations.
Districts are primarily using their own staff to implement both the tests and any
corrective actions.
Only one respondent reported that the district's testing uncovered water cooler
problems.
Over three-quarters (79%) of the districts say that funds for testing for and
correcting lead in drinking water problems have come from or will come from,
their general funds.
-------
Table 5-8
Proportion Who Have Seen EPA's List of Lead Lined Water Coolers
Q21: "Have you seen the list published in the spring of 1989 of lead lined water coolers that the U.S. Environmental Protection Agency
recommends should be tested, repaired or replaced?"
Percentage bv Stale
Factor
No
Ye*
Doo'l know
All
32.2%
624%
49%
Color ado
53*%
38.5%
7.7%
Idaho
22.0%
75.6%
2.4%
Illinois
46.4%
46.4%
7.1%
New York
19.2%
75.0%
3.8%
Ohio
62.2%
31.1%
6.7%
Pcnn
36.0%
60.0%
4.0%
S.Carolioa
19.4%
75.0%
5.6%
Icon
40.0%
60.0%
0%
Tcias
7.2%
89.9%
29%
-------
Table 5-9
Testing for Lead in Drinking Water
Slate
Factor
Sample size
Have tested
All
436
46%
Colorado
41
48%
Idaho
41
35%
Illinois
57
23%
New York
53
63%
Ohio
47
35%
Penn
51
58%
S.Carolina
36
50%
Term
31
13%
Texas
75
70%
Plan to test in
next 12 months 65% 68% 77% 44% 61% 61% 63% 94% 60% 90%
(of those who have not tested)
Tested or plan to
lest 77% 80% 78% 54% 84% 72% 82% 92% 52% 96%
-------
5-25
The last item is interesting in view of the fact that fully one-fourth (26%) of the respondents
commented that EPA should provide financial support for these types of programs, and
some indicated further that these programs take funds away from education. Respondents'
comments are addressed in more detail in Chapter 7.
S.3.S Overall Program Evaluation and Comments
Three summary questions, which addressed the relative importance of motivating and
helping factors (Q22), impeding factors (Q23) and general comments (Q24), completed the
evaluation of the Lead in Drinking Water program.
The relative importance of motivating factors is summarized in Table 5-10. State and
federal requirements and recommendations are ranked, overall, as the most important
motivating factors. EPA materials and assistance are also important, reflecting the high
ratings given to the materials by those who had obtained them. It is interesting to note that
only moderate importance is placed on parental, staff and public pressure. Apparently,
public pressure has some impact but, given other pressure upon schools, is less important
than more direct routes in motivating school districts to act.
Table 5-11 summarizes the mean ratings given to a variety of factors that might be serious
impediments to a district's taking action on lead in drinking water problems. Two points
are worth noting. First, the factor given the most serious rating is "inadequate information
from state agencies" while "inadequate information from the EPA" is not considered serious.
This is true even for the states that have disseminated significant amounts of information
and have conducted training sessions for school personnel. It appears that, since the states
are mandated to set up a program, districts are asking their states to give them much more
specific information and guidance on what to do and how to do it. These results, plus
comments made in interviews of state agency officials, suggest that the number of available
alternatives for both testing and remediation demand more decision-making than the
districts believe they either can or want to do.
Secondly, districts in Tennessee, whose responses have generally been incongruous with the
s;ate's reported level of effort, rate every factor as a more serious impediment than do the
districts in any other state. This is particularly evident with respect to the funding items:
inadequate district funds, state funds and inadequate district staff. We recall from Table
3-6 in Section 3, that Tennessee districts have one of the higher proportions of students
below the poverty line and the lowest instructional dollars spent per pupil (mean = $40.00)
of all nine states. It may be that financial considerations have more influence on Tennessee
schools than any communication and training activities undertaken by either EPA or the
state. This is somewhat corroborated by correlational analysis, which indicates a small but
negative correlation (across the entire sample) between the proportion of students under the
poverty line in a district and the district having tested for lead in the drinking water.
-------
Table 5-10
Ratings of Motivating Factors for the Lead in Drinking Water Program
Q22: "How important, if at all, do you think each of the following has been in motivating and helping your district to
risks due to lead in school drinking water?" (1 = not important to 5 = very important)
Stale
Factor
Sample size
Stale remiiremenls A. recommendations
Statistic
n
mean
SE(mean)
Federal requirements A recommendations mean
SE(mean)
Stale technical assistance
Slate financial assistance
U.S. EPA materials and technical assistai
tt*
Concerns expressed by the public; media,
parents and staff
mean
St(mcan)
mean
Se(mean)
iccmean
SE(mcan)
mean
Se(mean)
All
436
3.86
.06
3.86
.06
2.67
M
2.31
.09
3.08
.07
2.78
.08
Colorado
41
3.78
.19
3*3
.19
3.10
.28
2.60
.31
3.22
.23
2.86
.27
Idaho
41
3.61
21
3.84
&
2.64
.26
2.10
.29
3.66
.22
2.34
.23
Illinois
57
2.98
.22
3.00
.21
2.16
.19
2.27
.23
2.67
,20
2.59
.22
New York
53
4.34
.16
4.23
.15
2.58
.22
2.31
.24
3.07
.19
3.05
.24
Ohio
47
3.73
.20
3.65
.20
2.89
.26
2.80
.27
3.05
.21
3.10
.24
Penn
51
3.98
.19
4.15
.15
265
.24
2.47
.28
3.43
.21
360
.10
lake action on potential health
S.Carolina
36
3*8
.18
4.09
.19
2.52
Jl
1.66
.24
3.16
.25
2.45
.25
Tenn
31
4.28
.17
4.00
.24
3.56
.25
3.15
JJ
3.21
.23
2.95
.28
Teus
72
4.24
.13
412
.13
2.60
.22
1.92
.20
275
.20
2.78
.19
-------
Table 5-11
Kalings of Impeding Factors fur the Lead in Drinking Program
Q23: "How serious, if at all, do you think each of the following
( 1 = not serious to 5 = very serious)
Issue Statistic
Sample size
Inadequate district funds
Inadequate stale funds
Inadequate information from
the U S fcPA
Inadequate information from
stale agencies
Inadequate expertise in district
Inadequate staff lo handle edra work
n
mean
SE(nuan)
mean
SE(mean)
mean
SE(mtan)
mean
SE(mean)
mean
SE(mcan)
mean
SE(mean)
All
436
2.92
.09
302
.09
.52
.07
386
.06
2.65
.08
2.88
.08
Colorado
41
2.38
.26
2.46
.26
261
25
3.83
.19
2.44
27
2.38
25
has been
Idaho
41
3.23
.25
338
.28
2.19
.18
384
.20
2.76
.24
3.19
.26
in impeding your district in taking action on lead in
Slate
Illinois
57
340
.23
3.50
.25
287
.21
300
.21
320
.21
311
.22
New York
53
212
.21
2.23
.23
214
21
4.23
.15
211
.20
2.42
.23
Ohio
47
2.82
.27
3.00
.28
2.79
.23
3.65
.20
2.84
.25
2.89
.27
Pcnn
51
2.40
.25
234
.25
2.44
.22
4.15
.15
2.02
.20
2.14
.22
S Carolina
36
2.81
.29
2.78
.31
184
.18
4.09
.18
2.78
.27
3.09
.27
drinking
Tcnn
31
3.96
.29
395
J/
3.13
.31
4(10
.24
328
.31
383
.31
water?"
Teiai
72
311
.22
343
22
251
IV
412
n
26S
211
322
20
-------
5-28
Very few respondents chose to add comments about EPA requirements, materials or
assistance regarding lead in the drinking water. The most frequent comments were about
1) funds, indicating that these programs are taking funds away from education and
addressing the issue of unfunded mandates, and 2) about the need for more clarification of
the guidelines, technical assistance and responses to school personnel's questions.
Comments are summarized in Table 7-3.
5.4 SUMMARY AND IMPLICATIONS
There is wide diversity among the nine states with respect to their levels of effort m
implementing a Lead in School Drinking Water program for the local school districts. Much
of this seems to depend on the financial situation in individual state agencies, attitudes
toward an unfunded federal mandate with no penalties attached and, at least in part, the
interest of key individuals in state agencies. It becomes very apparent that the level of state
effort is the key factor affecting the ways in which school districts respond to this type of
program.
For the most pan, school districts in states that have fully disseminated EPA and other
materials, and have conducted training for school personnel, are more responsive than
districts in states that have not put fonh the same efforts. This is less accurate in
Tennessee, where school district finances appear to be more significant than anything either
the EPA or the state is doing.
The EPA manual. "Lead in School's Drinking Water," receives relatively high ratings frorr.
those respondents who have obtained it. It is viewed as being clear, instructive and
complete and is relied upon by the districts who are using it to help them determine their
actions. The manual is an important and positive motivational tool. Reactions to the
manual's contents, however, do not seem to be the most critical factor affecting district
activities. Assuring that districts receive the manual and have adequate training for its use
is critical. If states are responsible for disseminating the manual and, for various reasons,
they do not, it seems to be unlikely that districts will make much effort to obtain the manual
on their own. They rely significantly on their appropriate state agency for information on
what they must do. Even states that have been very active in disseminating information and
conducting training don't seem to be doing enough to satisfy the local districts' needs for
guidance and information.
It is apparent that the appropriate state agency or agencies provide a critical
communications link between EPA and local schools for this program. EPA can enhance
the effectiveness of programs like Lead in School Drinhing Water by increasing its efforts
to help state agencies in assisting local school districts. These efforts can include
-------
5-29
coordinated information dissemination, targeted training and model programs. While states
might appreciate flexibility in program design, EPA can significantly assist them by
developing, as a starting point, straightforward, detailed guidelines for preferred model
programs. The number of options available for implementing the Lead in School Drinking
Water program at the local district level appears, as presented by EPA, to be more
confusing than helpful. School administrators are educators not environmental technicians.
It doesn't appear that the majority of them would be insulted by a more directive approach
on dealing with environmental hazards in their districts and it appears that most states
would undertake the effort to develop refined guidelines on an interim voluntary program.
-------
6-1
6.0 RADON
6.1 BACKGROUND AND EPA PROGRAM
Radon is a colorless, odorless, tasteless radioactive gas that results from the natural decay
of uranium in rocks and soil. Because uranium occurs in small quantities in most rocks and
soil, radon is continually released into soil gas, underground water and outdoor air.
Relatively high concentrations of radon can occur inside buildings if radon-containing soil
gas infiltrates into a building through cracks, building joints or openings around pipes.
Recent medical research indicates that high levels of radon act as a carcinogen and that
children may be at a greater risk from radon exposure than adults.
6.1.1 EPA Study and Recommendations
In April, 1989 the Environmental Protection Agency released the results of a radon study
that was conducted in 130 schools in sixteen states around the country.1 These study results
indicated that 19 percent of the 3,000 rooms tested for radon had levels above the
recommended maximum of 4 Pci/L. In addition, 54 percent of these schools had at least
one room with levels over 4 Pci/L. and three percent of the rooms tested had levels
exceeding 20 Pci/L.
In addition to the school study, the EPA, in cooperation with the states, conducted
measurements for radon in thousands of homes throughout the United States.2 Although
the information is not available for all the states included in this study, the following
summarizes the information that is available on the percentages of homes with measured
radon levels over 4 Pci/L.
State Percent Homes > 4 Pci/L
Colorado >2S%
Idaho no information
Illinois no information
Ohio >25%
1 Information on the study done on schools was provided to us by personal communication with Dennis
Wagner, Chief, Public Information, Radon Office, US EPA, May 7, 1990.
J Information on the study of homes was provided to us by personal communication with Bill O'Neil, Office
of Policy Planning and Evaluation, US EPA, April, 1990.
-------
6-2
New York no information
Pennsylvania >2S%
So. Carolina 0 - 10%
Tennessee 15 - 20%
Texas no information
At the same time that the EPA released the results of the school study to the
press (April 1989), the agency also released working, interim recommendations that all
schools should measure radon levels in frequently used rooms that are at ground level or
below. Recommendations call for testing with either charcoal canisters or alpha track
detectors and retesting, over a period of several months, those rooms where elevated levels
are found. There is no mandate requiring that this testing be done; it is only recommended.
6.1.2 EPA Materials
Copies of a booklet, "Radon Measurements in Schools-An Interim Report," were
disseminated to state radon offices and state education departments along with the
information kits provided to the press. Since the press release came before disseminating
of these materials to the state agencies, the public was aware of a potential hazard before
either state agencies or school districts had the required information. Initially, the EPA did
not communicate directly with local school districts about either the issue or their guidelines
but relied on the state agencies to contact school districts and disseminate information.
The entire procedure used by EPA to disseminate this information was a cause of some
dissatisfaction by state and school district personnel contacted for this study. Releasing
information about a potential health hazard in schools before releasing this same
information to either state agencies or the schools left the states and the schools unable to
respond to parental and public concerns.
The radon guidelines have not yet been finalized. However, subsequent to the school
district survey in February 1990, the EPA sent a new publication, "Radon Reduction
Techniques in Schools," to National Education Association chapters and parent-teacher
organizations. This publication was also made available in information stands in 2,400
supermarkets across the country and has now been mailed to all 42,000 school districts.
6.1.3 Federal Grants
No federal funds were initially available to assist either states or school districts. However,
for fiscal year 1990, funds totaling $8.7 million were appropriated for an EPA grant program
to the states.
-------
6-3
These grants can be used:
10 work directly with schools;
for training;
for public awareness campaigns; or
for a variety of other activities related to radon testing and
remediation.
6.1.4 Additional Comments
EPA's mandate from Congress regarding radon in schools is to assess the extent of
contamination in the nation's schools and coordinate efforts to address the problem. It is
hoped that by providing both information relating to the health risks associated with high
levels of radon and guidelines for monitoring and remedying the situation, then state
agencies and local school districts will be motivated to take appropriate actions. Activities
related to radon testing and remediation are usually relatively inexpensive.
One of the larger obstacles the EPA may be facing in gaining cooperation from school
districts is the fact that the guidelines are labeled "An Interim Report." There is evidence
that school administrators, following their experiences with asbestos, tend to be concerned
about taking actions now and then having to redo everything when new information becomes
available. The fact that this program is only a year old makes it difficult to have a clear
sense of schools' responses and levels of cooperation thus far.
A few schools with high radon levels are now participating with the EPA in a project to
evaluate remediation techniques.
6.2 THE STATE PROGRAMS: RADON GAS
There are three factors that are affecting states' levels of effort relative to measuring for and
re me dying radon gas in schools.
1. Radon is the newest program of the three included in this study.
2. The announcement of the program followed very quickly after the announcement
of the Lead in Drinking Water program and whUe school districts are still reeling
from the expense of the asbestos program.
-------
3. The guidelines are very conspicuously labeled as "interim", which causes
both state personnel and school administrators to wonder aloud about the
possibilities that the ground rules will change after the agencies and
districts have already expended both time and money.
The result of these factors is that, generally, EPA recommendations relating to measuring
for radon have, thus far, had the least effect of any of the recommendations or requirements
being evaluated in this study.
Radon program activities are summarized, by state, in Table 6-1.
6.2.1 Colorado
The contact agency in Colorado for the Radon program is the Consumer Protection
Division, Department of Health. The state has been very active with respect to this
program. According to one respondent, the Consumer Protection Division tries to operate
with a basic "progressive rather than reactive" philosophy with respect to health protection.
In July 1989, the state's Department of Health adopted regulations that mandate all schools
to test for radon. All testing is to be completed by March 1,1991 but schools that are newly
constructed or have undergone recent remodeling or extensive work on heating and air
conditioning will have 19 months after the completion of that work to conduct their testing.
The state regulations require that tests be conducted according to the procedures outlined
in the EPA's booklet, "Radon Measurements in Schools: An Interim Report". Test results
must be kept on file and made available to the division on request. Corrective measures
are recommended but not mandated.
The division has sent bound copies of the EPA manual, "Radon Measurements in Schools"
to all school districts. In addition, the division has developed and disseminated to the school
districts, state guidelines that are intended as an addendum to the EPA interim report
Training and additional information are provided on request.
An open training session on several environmental concerns, including radon, was conducted
in March 1990 in cooperation with the Colorado Environmental Health Association; all
school districts were invited to send a representative to this meeting (at their own expense).
One representative of the Health Department noted that there is a danger in mandating that
schools use the procedures recommended in EPA's booklet: if EPA changes course in the
future with regard to testing techniques or acceptable levels, school administrators are likely
-------
COLORADO
IDAHO
ILLINOIS
NEW YORK
OHIO
so CAROLINA
TENNESSEE
Table 6-1
Summary of State Radon Programs
(March 1990)
STVTE
MANDATE
EPA MATERIALS EPA MATERIALS
SENT TO PROVIDED
ALL D1STS. BY REQUEST
TRAINING
GRANT
OTHER
CONSLUTTNG/
TESTING
PENNSYLVANIA
X
TEXAS
EPA materials given to training seminar attendees
-------
6-6
to be unhappy that the state mandated them to act at such an early stage in the process.
But, at the time of the last interview, the division was very pleased with the progress of the
radon program.
6.22 Idaho
The contact agency in Idaho for the Radon program is the Department of Health and
Welfare. The state has been relatively inactive with respect to this program and report that
school administrators have appeared resistant, voicing fears that this "will turn into another
asbestos". In April 1989, the department, in cooperation with the Department of Education,
disseminated copies of the booklet, "Radon Measurements in Schools" to all school districts
along with a list of reliable testing firms. The department has been approved for an EPA
grant to test for radon in schools. During the summer of 1990 the department will send a
Request for Proposals to contractors who might wish to bid on implementing the testing.
Some school districts tested during the past fall and winter but the department has no
statistics on this. One respondent, while commenting on the 1989 EPA press release on
radon, noted that this kind of information is often released to the press prior to being sent
to appropriate state agencies. Consequently, parents "panic" and call their schools who know
no more than the parents do. He suggests that it would be more constructive to send the
appropriate information to state agencies who can contact school districts prior to notifying
the public through the media.
6.2.3 Illinois
The contact agency in Illinois for the Radon program is the Department of Nuclear Safety.
The state has been somewhat active with respect to this program. The state leg-slature
appropriated $ 100,000 for general radon testing and public information for fiscal year 1990.
The Illinois pubic schools are divided into 18 regions. As of February. 1990, the department
had presented information on radon testing in schools at six regional seminars. All other
regional superintendents have received letters notifying them of the department's availability
for this type of training.
Photocopies of the booklet, "Radon Measurements in Schools," are provided to districts on
request. As of February 1990, 96 districts (of the 987 total) had requested and received the
booklet.
-------
_^^ 6-7
In cooperation with another state agency, the department provided free alphatrack detectors
for all of the schools in two counties. The state has applied for an EPA grant to test both
homes and schools. The S 100,000 state appropriation is categorized as matching funds. The
proposal calls for providing alphatrack detectors to all lower income school districts in the
first year. If sufficient funding is received, in the third year a random sample of all the
schools in the state would be tested.
The agency has been hesitant to press schools to test early, using their own resources, in
case federal funds become available at a later date.
6.2.4 New York
The contact agency in New York for the Radon program is the Department of Health
working in cooperation with the Department of Education. Because of a difference of
opinion between the two departments on the correct approach, the state has been inactive
with respect to this program. The Department of Education is very cautious about anything
from EPA that is labeled "interim". Many New York schools implemented asbestos
abatement under the first set of regulations arid then had to duplicate their efforts after the
adoption of AHERA.
In April 1989, the Commissioner of Health and the Commissioner of Education issued a
joint press release recommending that all school districts except New York City and Long
Island test for radon in the fall. Residential testing in the two areas that were excepted had
indicated a low potential for radon problems.
State modifications of the EPA guidelines and an extensive workshop for school
superintendents, originally planned for the fall of 1989, have been placed "on hold" until the
differences between the Health and Education departments can be reconciled. As of
February 1990, no materials had been disseminated to school districts. In addition to their
concerns about interim guidelines, the Department of Education would like to develop, with
the Departments of Health and Energy, a public education program that would proceed
along parallel lines with anything transpiring in the schools. The purpose of this would be
to alleviate any parental concerns that might develop when schools begin testing for radon
6.2.5 Ohio
The contact agency for the Radon program in Ohio is the Radiological Health Program,
Department of Health. The state has been somewhat inactive with respect to this program
because of inadequate resources.
-------
6-8
Ohio has had no formalized program for radon testing in the schools. No training has been
conducted for school personnel and the EPA booklet, "Radon Measurements in the Schools"
has been sent to districts only on request. Only the city of Columbus has a program for
testing schools. A bill currently in the state legislature will establish licensure procedures
for contractors doing radon testing and mitigation.
The State Department of Health has applied for an EPA grant to:
identify problem areas with respect to radon;
conduct a public awareness campaign; and
and test homes and some schools in identified problem areas.
If the state receives the EPA grant the agency will become more active. They report that,
without federal funds, they have neither money nor personnel to implement the program.
Most questions coming from school districts have dealt with whether or not radon testing
is mandatory. In other words, little concern is being indicated about the potential health
risk.
6.2.6 Pennsylvania
The contact agency in Pennsylvania for the radon program is the Bureau of Radiation
Protection. The state has been afliifi with respect to the Radon program. Radon has long
been an issue in Pennsylvania and the state is aware of a cause for concern even though
they receive very few calls from parents.
Prior to EPA's announcement of a Radon program, the state of Pennsylvania had tested all
schools in a four-county area known as the Reading Prong area. Since that time it has been
up to local districts to conduct their own initial screening. When initial screening indicates
high levels of radon, the state will provide alphatrack detectors for long-term testing.
Bureau personnel will send staff to schools where indicated levels are exceptionally high.
The bureau sent an advisory letter to all school districts in April 1989. This letter
recommended testing and was enclosed in a packet containing a copy of the booklet, "Radon
Measurements in Schools" and a list of state certified contractors. In order to attain state
certification, contractors must meet certain educational requirements, have a specified level
of experience and complete an EPA approved course.
-------
6-9
The bureau has developed a database on schools. Information includes:
test results;
location of buildings;
who conducted the tests; and
the type of test.
EPA's newest booklet, "Radon Reductions in Schools" is being sent to all schools where tests
indicate high levels of radon.
6.2.7 South Carolina
The contact agency in South Carolina for the Radon program is the Division of
Environmental Radiation, Department of Health. The state has been inactive with respect
to the Radon program.
Ten thousand homes have been tested throughout the state and elevated radon levels were
found in only four percent of these. Consequently, the state sees little reason for concern
about health risks from radon and has no plans to develop a testing program for schools.
No materials have been disseminated to school districts and no training has been conducted.
The department reported that they had received probably no more than a half dozen calls
from schools about radon. In addition, the department notes that it has no funds to do
anything about this program.
6.2.8 Tennessee
The contact agency in Tennessee for the Radon program is the Division of Air Pollution
Control. Department of Health and Environment. The state has been somewhat active with
respect to this program.
Tennessee was one of the states in which the EPA conducted its initial surveys for radon
Eievated levels were found in Eastern and Middle Tennessee. Subsequently, the state and
EPA offered a three-day course for school districts on testing and mitigating for radon.
The booklet, "Radon Measurements in Schools" has been disseminated only through training
courses and workshops. The department has made several presentations to school district
maintenance personnel on radon testing; however, these were not well attended.
Presentations on radon testing were also made at two regional meetings conducted by the
-------
6-10
Department of Education in January 1990 on grant and loan applications for asbestos
abatement. A weekly information packet from the Department of Education contains
updates and reminders on various environmental issues.
One state agency respondent commented that there will be little response from the schools
on radon unless testing is mandated. The respondent went on to say that this non-response
does not result from a lack of concern but because local school districts have "too much
thrown at them today"; they are both financially overburdened and overworked.
62.9 Texas
The contact agency in Texas for the Radon program is the Bureau of Radiation Control,
Department of Health. The state has been inaflixfi with respect to this program. There are
no funds in the agency's budget to disseminate materials or provide training. Postage to
send materials to schools who request it must be taken from other programs. Therefore,
the bureau sends the booklet, "Radon Measurements in Schools," only on request and no
training has been offered. The Department of Health has applied for an EPA grant to test
a sample of homes throughout the state. If the results of this survey indicate high radon
levels anywhere in the state, testing schools in those areas might be considered.
The state legislature meets in regular session only every other year and the next regular
session begins in January 1991. Consequently, there is no chance for any state appropriation
of funds for radon testing before next year.
6.3 RESPONSE FROM THE SCHOOL DISTRICTS
Questions concerning the radon program were included with the questions concerning the
lead in drinking water program in the second version of the questionnaire sent to local
school districts. As indicated in Chapter 2, four hundred and thirty-six completed responses
to this version of the questionnaire were received. Over two-thirds (72%) of the
respondents were school district superintendents or assistant superintendents.
It is important to note again that the radon program is the newest of the three programs
considered in this report, and information on responses at the school district level is based
on questionnaires completed primarily in November and December 1989 (about 80%) and
in January and February 1990 (about 20%). As discussed in Chapter 3, both the
respondents' perceptions of health risk and expressions of public and staff concerns
regarding radon gas in schools are relatively low. Across the whole sample, these ratings
fall just behind those for lead in drinking water. Activities in response to the program can
-------
6-11
be expected to increase as states continue their activities supporting school district actions
and as EPA disseminates additional information such as the "Radon Reduction Techniques
in Schools" publication released in February 1990.
6.3.1 Familiarity with Regulations and Guidelines
In Question 25, respondents were asked to rank, on a five-point scale from (1) "not at all
familiar" to (5) 'Very familiar,11 their level of familiarity with both their state's and the
federal regulations and guidelines for testing for and correcting problems with elevated
levels of radon gas in school buildings. The sample mean indicates less familiarity with the
radon guidelines than for lead in drinking water, as might be expected with a more recently
started program (see Table 6-2). The state means indicate that actions by the states make
a difference in terms of reported familiarity with the guidelines. Reported familiarity is
significantly above the sample mean in Colorado and Pennsylvania, states with the most
active programs of the states in this sample (see Section 6.2).
It appears that this higher level of reported familiarity is the result of more than simply
sending the EPA materials to the districts. The mean familiarity reported for Idaho is about
the same as the sample mean, even though Idaho is the only state in the sample in addition
to Pennsylvania and Colorado that reports having sent the materials to all the school
districts. Unlike Colorado and Pennsylvania, Idaho does not have an active training
program for local school districts regarding testing for and remediating high levels of radon
gas. Idaho is participating in the 1990 EPA State Survey Program, and this should yield new
information on risk levels in the state.
6.3.2 Receipt and Response to EPA Materials
Before being asked some specific questions about the EPA materials on radon, respondents
were asked a general question about information sources they have used to help determine
actions regarding radon gas (Question 26). About half of the respondents indicated that
they have used materials from EPA (see Table 6-3). State health departments were listed
as the second most frequent source. Variation in these responses across the states is largely
consistent with the descriptions of the state level efforts. In states with more activity at the
state level, respondents indicate more reliance on information from the state. Newspapers
and other printed media and workshops or seminars were also listed by one-fourth to one-
fifth of the respondents as sources of useful information.
-------
Table 6-2
Reported Level of Familiarity with Slate & Federal Regulations and Guidelines Concerning Radon Gas
Q25: "How familiar are you with state and federal regulations and guidelines for testing for and correcting the presence of radon gas?"
(1 = not at all familiar to 5 = very familiar)
Slate
Issue
Sample size
Stale regulations and guidelines
Federal regulations and guidelines
Statistic
a
Mean
SE(mean)
Mean
SE(mean)
All
436
2.62
.06
2.61
.06
Colorado
41
3.28
.18
3.35
.17
Idaho
41
2.44
.18
2.66
.17
Illinois
57
2.53
.15
2.46
.15
New York
S3
2.78
.16
2.50
.16
Ohio
47
2.54
.17
2.50
.16
Peon
SI
3:29
.16
3.24
.16
S.Carobna
36
2.03
.10
2.06
.10
Tenn
31
2.58
.21
2.57
.21
Teias
72
2.19
.1J
2.26
.14
-------
Table 6-3
Sources of Information Determining Actions Related to Radon Gas
Q26: "Which of the following has your district used
(more than one may apply)
Source
Sample ftixe
Printed materials from the US. EPA
Printed materials from the slate health dept.
Newspapers and other printed media
Workshops or seminars
No information has been obtained
All
436
52%
41%
26%
20%
25%
to help determine actions on testing for and correcting radon gas problems?"
PcfCf nlUC of Rcsoondcnls
Colorado
41
63%
61%
39%
39%
12%
Idaho
41
66%
32%
29%
10%
20%
Illinois
57
54%
44%
35%
12%
18%
New York
53
40%
42%
21%
32%
17%
Ohio
47
47%
34%
32%
15%
26%
Pcnn
51
65%
53%
47%
33%
14%
S Carolina
36
42%
33%
14%
11%
47%
Tcnn
31
55%
55%
10%
42%
23%
Teus
72
40%
25%
7%
4%
46%
-------
6-14
A surprisingly high percentage (one-fourth) of respondents said they had obtained no
information regarding radon gas, and nearly half the respondents from South Carolina and
Texas said they had obtained no information. These two states are putting little or no effort
into reaching the school districts on this issue and these responses underline the importance
of state level involvement in this program in terms of getting the information to the schools.
Texas has not yet participated in EPA's State Survey Program and available information
suggests risks in South Carolina may be small. These facts may discourage state agencies
and local districts from taking action.
Just over one-fourth of the respondents report having received the EPA report, "Radon
Measurements in the Schools" (Question 32). About one-half reported that they had not
received the report, and just under one-fourth said they did not know if they had received
the report (see Table 6-4). The percentage of respondents who report having received the
report ranges from a low of about twelve percent in Ohio, where little is being done at the
state level, to a high of fifty-four percent in Colorado, where the state is very active in
providing information and training for local school districts regarding radon gas.
About one-third of the sample reports that they have or will receive the report from a state
agency. Only eight percent report have used or are planning to use the Government
Printing Office. Almost twice as many respondents (40%) said they were not aware of this
report as gave a similar answer regarding the "Lead in School Drinking Water" manual.
More than half of the respondents in three of the six states in the sample that are sending
the report to schools only on request said that they were not aware of this report. Less than
thirty percent of the respondents report no awareness of this report in the three states that
report having sent it to all school districts. Awareness of the report in Tennessee, which has
an active training program through which the EPA materials are distributed to all attendees,
is comparable to that reported in the three states that have sent the report to every district.
Only eight percent of the sample reports having no plans to obtain this report. This suggests
that only a small percentage of districts willingly or intentionally ignore the availability of
information from EPA on this topic. This percentage is comparable to that obtained for a
similar question regarding the "Lead in School Drinking Water" manual.
Respondents who had obtained the "Radon Measurements in Schools" report were asked
to use a five-point scale (1 being "not at all" to 5 being "very") to rate the degree to which
they found the report (1) clear and understandable, (2) instructive and informative, and (3)
complete. The mean ratings for all three characteristics were 3.8, suggesting that the
majority of respondents found the report relatively clear, informative and complete (see
Table 6-5). These are similar to the ratings given for the "Lead in School Drinking Water"
manual.
-------
Table 6-4
Where Districts are Obtaining the Report "Radon Measurements in Schools"
Q32: "From where, if at all, have you obtained, or will you obtain, the report "Radon Measurements in School"?"
(more than one many apply)
Percenlane of Resnondents
Where
Sample size
Government Printing office
Stale Department of Education or
Department of Health
From the Regional EPA or
Federal EPA offices
Not aware of this report
No current plans to oNain this report
033. Have you received the report?
No
Yes
Don't kii..«
All
436
8%
33%
17%
40%
8%
49.8%
27.3%
23.0%
Colorado
41
5%
43%
23%
28%
10%
28.2%
538%
17.9%
Idaho
41
7%
37%
17%
24%
7%
350%
45.0%
20.0%
Illinois
57
12%
23%
16%
51%
14%
702%
15.8%
14.0%
New York
53
4%
36%
13%
32%
6%
49.0%
20.4%
30.6%
Ohio
47
4%
26%
11%
60%
11%
60.5%
116%
27.9%
Peon
51
16%
41%
29%
29%
6%
41.2%
35.3%
23.5%
S Carolina
36
11%
33%
14%
44%
3%
61.1%
22.2%
16.7%
Tena
31
10%
55%
23%
23%
3%
36.7%
36.7%
267%
Tcias
72
3%
22%
11%
54%
7%
57 h%
152%
21 V'A.
-------
Table 6-5
Report's Effect on Actions or Plans Concerning Testing for Radon
Q35: "Did the
Response
No
Yes, somewhat
Yes. definitely
An respondents*
report affect your district's actions or plans regarding testing for radon?"
Number of
Respondents Percentage of Respondents
40 367
42 38 5
27 24.8
109
Clarity
3.53
(0.14)
382
(0.12)
423
(0.14)
3.81
(0.08)
Mean Score of Report
Information
350
(0.15)
3.78
(0.13)
4.28
(0-14)
3.79
(0.08)
For**
Completeness
3.63
(0.15)
3.71
(0.16)
4.04
(0.20)
377
(0.09)
Respondents (about 25*1 of the sample) who said they had received the report.
** Rated on a scale of 1 = not to 5=very. Standard error of mean in parentheses.
-------
6-17
Almost two-thirds of those respondents who reported having received the report said that
it had at least some effect on their district's actions or plans regarding testing for radon gas
(see Table 6-5). These responses are very similar to those obtained for the same question
regarding the "Lead in School's Drinking Water" manual. Mean ratings for clarity,
information, and completeness were positively correlated with the degree of effect of the
report on the district's actions or plans.
Question 36 asked respondents who had received the EPA report on radon where they
might have sought guidance regarding potential radon gas problems if the EPA report had
not been available. More than half of these respondents said they would have sought
guidance from their state's departments of health or environment (see Table 6-6). A
significant but much smaller share of respondents indicated they would have sought guidance
from regional EPA offices and/or from private consulting firms.
6.3.3 Testing for Radon Gas in School Buildings
Fifty percent of the respondents reported that they had tested or planned to test for radon
gas in the next 12 months (Table 6-7). The highest percentages of respondents reporting
testing, either planned or completed, were in Colorado (83%) and Pennsylvania (76%),
states with the most active state programs and where evidence of high levels of radon gas
in some homes has been found. These two states also had the highest percentages of
districts reporting some radon testing completed. The percentages reporting testing,
completed or planned, were significantly below the sample mean in New York, South
Carolina, Tennessee, and Texas. Tennessee is the only state of the four with an active state
program at the time of the survey. Texas has not yet participated in EPA's State Survey
Program, information for South Carolina suggests small risks and New York's program is
at an impasse. Testing efforts, including plans to test, seem related to availability and
seventy of risk information and to the level of state programs.
Less than one-fifth (18%) of the sample had completed any testing for radon gas at the time
of the survey. Of those who had conducted tests, a little more than half (58%) reported that
no re testing or corrective actions were necessary. About thirty percent reported that
retesung was necessary at some sites and about ten percent reported that corrective actions
uere necessary. These results should be treated as preliminary because most of the districts
u-ere just beginning the testing process and the sample size was small for those whose
findings were complete. For this reason we do not report the findings by state. The
percentage reporting that no retesting or corrective actions were necessary was similar to
the sample mean in most of the states, but was higher than the sample mean in Idaho,
Illinois, and South Carolina (suggesting or reflecting possibly lower radon levels in these
states).
-------
Table 6-6
Alternative Sources of Information Concerning Kadon if the Radon Report Had Not Been Available?
Q36: "If the report "Radon Measurements in Schools" had not been available, where would your district have sought guidance on testing for and
correcting radon gas problems?" (more .than one may apply)
Percentaoe of ResDondenls
Source
Sample size*
Stale Health or Environment Department
Region*! EPA office
Environmental consulting firms
Information may not have been sought
All
114
54%
38%
27%
8%
Colorado
21
77%
41%
41%
0%
Idaho
18
42%
32%
16%
26%
Illinois
9
44%
44%
22%
11%
New York
10
64%
50%
29%
0%
Ohio
5
56%
44%
0%
0%
Penn
18
30%
67%
67%
0%
S.Carotioa
8
75%
25%
38%
13%
Tcon
11
50%
25%
0%
8%
TCJUS
10
44%
19%
13%
6%
Respondents who have received the radon report.
-------
Table 6-7
Radon Testing
Percentage of Resoondenls
ource
ample uxe
riave luted
PUn lo lest in ned 12 months
AU
436
18%
50%
Colorado
41
34%
91%
Idaho
41
12%
56%
Illinois
57
18%
56%
New York
53
20%
37%
Ohio
47
22%
41%
Peon
51
37%
76%
S Carolina
36
6%
46%
Tenn
31
7%
29%
Texas
72
7%
33%
(of those who haw not tested)
Total have tested or plan lo lest
50%
83%
56%
56%
40%
48%
76%
42%
26%
30%
-------
6-20
About forty-five percent of the respondents said that private contractors had been or would
be hired to conduct the radon testing. About thirty-five percent said that district staff were
doing the testing. About thirty-five percent said that private contractors would do the
corrective action and about thirty-five percent said that district staff would do the corrective
action. Most of the remainder of the respondents said they did not know who would do the
testing or the corrective action. Also of interest is that most respondents (81%) said that
money for the testing and the corrective action for radon gas would come from the school
district's general funds.
Correlation analysis revealed several factors significantly related to whether or not the
school district had tested or had plans to test for radon gas in the next twelve months.
Factors associated with a positive response concerning testing included:
reported familiarity with state and federal regulations and guidelines (Q2S)
level of concern expressed by parents, students, faculty and staff about radon
(04)
receipt by the district of the EPA report, "Radon Measurements in School" (Q33)
identification of priced material from EPA as helpful in determining actions
regarding radon (Q26)
identification of workshops or seminars as helpful in determining actions
regarding radon (Q26)
The correlation analysis also revealed that districts with a higher percentage of students
living below the poverty level were significantly less likely to have tested or to have plans
to test for radon gas in the next 12 months. Higher instructional materials dollars per
student (IDP) was associated with higher rates of testing and planned testing, although the
correlation was not as great as was the negative correlation with poverty.
6.3.4 Motivating and Impeding Factors Regarding the Radon Program
The evaluation of the radon program was completed with two summary questions dealing
with the importance of selected potential motivating and helping factors (Q37), and the
importance of selected potential impeding factors (Q38).
-------
6-21
The ratings for the potential motivating and helping factors are summarized in Table 6-8.
Overall, the most important motivating factors appear to be the state and federal
requirements and recommendations. State and federal level requirements and
recommendations are rated similarly across the full sample and across most of the states
individually. One exception is Idaho, where the state requirements and recommendations
are rated lower than the sample mean and lower than federal requirements and
recommendations are rated. The highest ratings for state and federal requirements and
recommendations were given in states with the most active programs: Colorado,
Pennsylvania, and Tennessee.
Concern expressed by the public, media, parents and staff was the next most important
motivating factor. The ratings for this factor varied considerably across the states, with the
highest rating in Pennsylvania where the radon problem was first identified and publicized.
EPA materials and technical assistance were rated similarly to the public concern for the
sample as a whole. The lowest ratings for EPA materials and technical assistance were
given in South Carolina and Texas, where the states are doing little to disseminate the EPA
materials to the districts or to publicize the problem. State technical assistance was
generally rated slightly lower in importance than EPA technical assistance.
Correlations between the ratings for the potential motivating factors and whether or not the
district had tested or planned to test for radon in the next twelve months revealed
relationships similar to those identified in the previous section. A higher rating for federal
and state (especially federal) requirements and recommendations was significantly associated
with a positive response concerning testing. A higher rating for public concern as a
motivating factor was also related to a positive response regarding testing, especially for
testing already done.
Financial constraints appear to be the most serious of the potential factors impeding the
districts from taking action on radon gas (Table 6-9). Across the whole sample the order
of importance of financial-related impediments, with most serious first, was inadequate state
funds, inadequate district funds, inadequate staff in the district, and inadequate expertise in
the district. Inadequate information from the states and from EPA were rated similarly and
as somewhat less serious than the other four factors. It is of interest that the financial
constraints were rated as serious impediments well above the sample mean by respondents
from Tennessee. This actual or perceived financial constraint might explain why there
seems to be little being done in terms of radon testing and corrective actions by the districts
in Tennessee, even though the state has been active in getting information about the
problem to the districts. (Note that the average IDP in Tennessee is far below the other
states and may reflect funding problems in Tennessee districts.)
-------
Table 6-8
Rating of Motivating Factors for the Radon Program
Q37: "How important, if at all. do you think each of the following has been in motivating and
health risks due to radon gas?" (1 = not important to 5 = very important)
Factor Statistic
Sample size
n
Stale requirements A recommendations mean
SE(mean)
Federal requirements and
lecommeodalions
SIMC technical assistance
Stale finanoal assistance
U S EPA materials and technical
assistance
Concerns expressed by Ibe public,
parents and staff
mean
SE(mean)
SE(mean)
mean
SE(mean)
mean
SE(mean)
media, mean
SE(mtan)
All
436
333
.08
3.32
.07
2.46
.08
2 JO
.09
2.75
.08
2.83
.08
Colorado
41
3.78
.18
3.68
.17
2.47
.23
2.19
.28
306
.23
2.97
.26
Idaho
41
2.84
.25
337
.23
2.52
.27
2.30
.30
3.21
.27
2.17
.21
Illinois
57
2.72
.21
2.70
.21
2.02
.17
2.00
.19
2.45
.20
2.79
.22
New York
53
3.76
.22
3.50
.22
2.31
.24
2.22
.26
2.71
.23
2.83
.25
helping your district to take action on potential
Slate
Ohio
47
3.50
.24
338
.22
2.68
.29
2.69
.28
2.82
.25
3.00
.23
Pena
51
3.91
.17
3.80
.17
2.84
.23
2.48
.28
3.16
.22
3.84
.17
S.Carolina
36
263
.12
2.85
.31
1.86
.JO
1.65
.26
2.21
.26
115
.31
Tenn
31
3.85
.22
3.72
.2J
3.39
.26
314
.J2
3.30
.27
3.00
.JO
TCJUU
72
3.00
.25
3.10
.2J
2.50
.25
2.25
.26
2.03
.20
244
.27
-------
Table 6-9
Haling of Impeding Factors for the Radon Program
Q38: "How serious, if at all, do you think each of the following
( 1 = not serious 10 5 = very serious)
Factor Statistic
Sample size
Inadequate district funds
Inadequate stale funds
Inadequate information from
the U^EPA
Inadequate information from
stale
Inadequate amortise in district
Inaitrip'lrf* ««" « luuuUe e«lr
n
SE(mtan)
mean
SE(mean)
SE(meon)
SE(nuan)
mean
SE(mean)
a work mean
SE(mean)
All
436
3.18
.09
3.26
.09
2M
.06
2.92
.08
3.00
.09
3J06
.09
Colorado
41
2.89
.27
2.84
.26
2.58
2.63
.25
2.4S
.26
2.56
.27
has been
Idaho
41
3.28
.25
3.45
.26
2.35
.21
2.69
.22
3.14
.26
3.38
.24
in impeding your district in taking action on radon gas?"
Slate
Illinois
57
3.27
.21
333
.23
2.98
.19
2.96
.20
3.22
.22
2.98
.22
New York
53
2.33
.26
2.39
.27
2.57
.24
2.81
.25
2.38
.25
2.40
.25
Ohio
47
292
.27
3.17
.27
3.03
.25
3.22
.23
3.22
.28
2.97
.27
Peon
51
2.69
.23
2.78
.25
2.74
.21
2.79
.21
2.60
.22
2.63
.24
S.Carolina
36
3.19
.34
3.38
.35
2.89
.25
2.89
.29
3.26
.31
3.46
.31
Teon
31
4.48
.16
456
.15
2.73
.26
245
.24
316
.27
3.91
.26
Te&u
72
3.72
.24
361
.24
340
24
343
.23
352
.24
361
.26
-------
6-24
Correlation analysis suggests that the respondents who report having received the EPA
report "Radon Measurements in Schools" were less likely to say that inadequate information
from the EPA or the state was a serious impediment to taking action on radon. Those who
had received the report were also less likely to say that inadequate expertise in the district
was a serious impediment Correlation analysis also suggests that those who have tested or
plan to test for radon were less likely to say that inadequate information from the state or
federal agencies was a serious impediment.
6.4 SUMMARY AND IMPLICATIONS
The radon program had not been underway for very long when this survey was conducted
and the results may therefore not be representative of the final response to the program.
Some states included in the sample were still in the process of developing their programs
for assisting local school districts on this issue, and EPA has distributed additional materials
on radon since the survey was completed. Nonetheless, the results of the school district
survey and the interviews with state personnel provide some useful information with which
to evaluate the effectiveness of the radon program.
It appears that the EPA report, "Radon Measurements in Schools," has been useful for
school districts who have received it. Respondents who have received it give it fairly high
marks for clarity, information, and completeness, and a large share say that it has affected
their actions regarding radon gas. However, it also appears that the districts are more likely
to have obtained the report if their state agencies have been actively distributing it. A
significant share of respondents in states that are not actively distributing the report do not
even know that it exists.
As with the lead in drinking water program, it appears that although the EPA materials are
we!' received and useful, they are not alone sufficient in spurring a high percentage of
districts to test for radon gas. It appears that state level follow-up with seminars, workshops,
and additional guidelines and recommendations are needed to obtain a high level of
response from the districts. Idaho provides an interesting test case for this conclusion. State
agencies in Idaho have distributed the EPA materials to all school districts but have done
little else to assist the schools. Reported rates of testing for radon by school districts in
Idaho are similar to the sample means. In Colorado and Pennsylvania, states that have also
distributed the EPA materials to all school districts and have followed-up with active state
programs of workshops and training, rates of testing are well above the sample means;
although the availability of information that high radon levels occur in these two states may
also be an important motivational factor for the schools.
-------
6-25
Expressed concern by the public and district staff regarding radon gas seems to be a factor
in motivating action by the schools. This seems especially true for states where high levels
of radon have been measured in a significant share of homes and the problem has had
significant publicity. States in the sample that fit this description are Pennsylvania and
Colorado.
An important factor motivating state agencies appears to be the availability of risk
information and the degree of risk. In cases where there is no EPA risk information, state
actions are lacking, and whenever states are less active, school districts tend to be less
active. Where EPA or state risk assessments suggest lower risks, activity is also relatively
less than in states where quantified risks are larger. In short, EPA can stimulate
appropriate action in states by conducting risk assessments and providing that information
to the state agencies and public. Without this information an old axiom seems to hold,
"Ignorance is bliss" (or as stated in Koines, Cummins and Rowe, 1990, "Knowledge leads to
consensus" about what actions to take).
As with lead in drinking water, financial constraints come through as significant impediments
to the districts when it comes to taking action on radon gas. We see again that there is a
low rate of testing by schools in Tennessee even though the state has a fairly active program
providing information, training, and recommendations to the schools. Financial constraints
were more likely to be given as serious impediments by school districts in Tennessee and
we see that schools with lower instructional materials budgets and with a higher percentage
of students living in poverty are less likely to be testing for radon gas. School districts in
Tennessee have the lowest budgets for instructional materials and have a higher than
average percentage of students living in poverty for the states in this sample.
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7-1
7.0 COMPARISON ACROSS PROGRAMS AND CONCLUSIONS
This chapter presents the responses to the final questions in the mail survey concerning all
three of the programs, as well as summaries of the comments offered by the mail
respondents. Overall conclusions about the effectiveness of these three programs are then
presented.
7.1 COMPLIANCE DIFFICULTY AND ADDITIONAL COMMENTS FOR ALL THREE
PROGRAMS
In both versions of the mail questionnaire respondents were asked to rate the overall
difficulty of complying with EPA regulations and/or guidelines for each of the three
programs. Respondents were also asked to offer additional comments regarding the EPA
programs at several different points in both versions of the questionnaire.
Compliance Difficulty
Respondents to both versions of the questionnaire were asked to rate on a five-point scale
how easy or difficult it has been for their districts to comply with the EPA regulations or
guidelines for each of the programs (Table 7-1). The mean responses across all the states
indicate that school districts have found the asbestos program significantly more difficult
than either the lead in drinking water program or the radon gas program. The mean rating
for asbestos was at four on the scale, while for the latter two programs the means were just
below the mid-point between "easy" and "difficult".
There are several likely reasons why the asbestos programs has been more difficult for the
school districts.
« Many of the district's actions are mandated under the asbestos program, while
with lead and radon the districts have more discretion about what they do.
Asbestos abatement typically requires more effort and much more expense than
abatement for lead or radon.
The asbestos program has been going longer and has had some changes along
the way.
Respondents also indicated that complying with regulations or recommendations on
underground storage tanks (UST) has been fairly difficult. This may relate to the fact that
EPA has no program or materials on UST that are designed specifically for schools.
-------
Table 7-1
Ralinp «f Ov< -M Difficulty in Complying with U.S. EPA Regulations
"Overall, how easy or how difficult has it been for your district to comply with U.S. Environmental Protection Agency regulations and/or guidelines
for the following issues?" (Lead/Radon Q40 and Asbestos Q33) (1 = very easy to 5 = very difficult)
Stale
Issue Statistic
Sample tat
Lead in drinking water
Radon Gas
Asbestos
Underground storage tanks
a
mean
SE(mean)
mean
SE(nuan)
mean
SE(mean)
mean
SE(mean)
All
810
2.72
.05
2.89
.06
4.04
.04
3.38
.05
Colorado
85
2.50
.15
2.85
.15
3.95
.13
3.20
.16
Idaho
41
3.03
.24
3.38
.25
4.32
.15
4.03
.22
Illinois
116
2.51
.15
2.64
.15
4.08
.11
3.21
.16
New York
104
2.42
.13
2.71
.17
4.16
.10
3.55
.13
Ohio
105
2.95
.15
3.29
.15
4.09
.12
3.74
.13
Penn
100
2.38
.13
2.49
.14
3.76
.14
3.05
.15
S.Carolina
36
2.89
.27
3.31
.36
4.60
.15
3.93
.27
Tenn
68
3J8
.20
3.39
.21
4.16
./5
3.35
.21
Texas
146
2.82
.11
2.78
.15
3.78
.12
3.22
.13
-------
7-3
Additional
Respondents who said they found the EPA materials incomplete were asked to comment
about what else would have been useful. About 12 percent of the sample made one or
more comments in response to this question in each version of the questionnaire (Table 7-
2). For the lead in drinking water and the radon gas manuals, the primary comment was
that the schools would have liked to have had the information before it was announced to
the public. This complaint relates more to the program in general than to the manuals
themselves. For asbestos, some respondents would have preferred more detailed
information, particularly on expected costs and selection of qualified contractors.
After the questions asking respondents to evaluate the EPA materials for each program,
respondents were asked if they had any additional comments about the EPA requirements
or materials and technical assistance for that program. About 20 percent of the sample
made one or more comments about each of the programs in response to this question
(Table 7-3). The most frequent comment was that the districts would like financial
assistance with regard to these programs. Comments on the materials and technical
assistance focused primarily on requests for clearer guidelines and better response to
questions.
At the end of each version of the questionnaire, respondents were asked open-ended
questions about whether the EPA is currently helping them deal with environmental risks
and what else EPA might do to help them. About 65 percent of the sample answered the
first question and about one-third of the responses indicated either that the EPA is not
helping or that the respondent did not know if EPA was helping (Table 7-4). About another
third of the comments indicated that EPA has been helpful, especially with publications;
however, some of these comments were qualified with requests for less technical
information. The frequencies of these comments were fairly similar for the two survey
versions.
About 60 percent of the sample made one or more comments about what more EPA could
be doing to help school districts deal with environmental risks (Table 7-5). The most
frequent comments were EPA should provide more financial support and other direct
assistance, such as on-site testing, for these programs. Requests for simpler information and
clearer guidelines were also fairly frequent, especially for the lead/radon version of the
questionnaire. Several different comments also suggested that a portion of respondents felt
that these health risks are not as serious as the EPA programs seem to indicate.
-------
Table 7-2
Most Frequent Comments About What Else Would Have Been Useful,
If Respondent Found EPA Materials Incomplete*
Comment Frequencies Specific Comment (Paraphrased)
By Survey Version
Asbestos Lead Radon
48 47 43 Total number of comments given."
174 436 436 Total number of respondents for each version.
0
17
11
9
7
33
8
1
0
2
34
3
0
0
1
Get information to schools before announcing to public.
Provide more detail/more facts.
Provide more workshops/trainings/public meetings.
Provide information on how much it will cost.
Provide information on how to get help, such as a list c
qualified contractors or consumer product information.
Asbestos Q27, Lead Q18 and Radon Q34. This list includes all comments
(paraphrased) given by at least 5 respondents in one or both of the surveys.
About 12 percent of the sample gave one or more comments in response to this
question in each version of the questionnaire.
-------
Table 7-3
Most Frequent Additional Comments About EPA Requirements or
Materials and Technical Assistance for This Program*
Comment Frequencies
By Survey Version
Asbestos Lead Radon
Specific Comment (Paraphrased)
99 126 106
374 436 436
Total number of comments given."
Total number of respondents for each version.
14
10
5
12
10
6
I
2
13
12
8
3
3
7
5
5
16
8
12
3
0
4
3
3
Need money. This program is diverting money from
education.
Clarify guidelines for this program.
Need more technical assistance, response to question, etc.
The problem is exaggerated, regulations are too
demanding.
Need better communication between EPA and related
state agencies.
Don't mandate without providing funds.
This environmental risk is not a problem/not as bad as
other things.
We have done nothing on this program.
Asbestos Q32, Lead Q24 and Radon Q39. This list includes all comments
(paraphrased) given by at least 5 respondents in one or both of the surveys.
About 20 percent of the sample gave one or more comments in response to this
question in each version of the questionnaire.
-------
Table 1-4
Most Frequent Comments About How EPA Is Helping School Districts
Deal with Potential Environmental Risks*
Comment Frequencies
By Survey Version
Asbestos Lead/Radon
Specific Comment (Paraphrased)
266
374
109
59
31
34
1
8
0
7
305
436
126
48
42
38
9
8
9
7
Total number of comments given.
Total number of respondents for each version.
None/very little or don't know how EPA is helping.
EPA is very helpful and there when needed.
EPA is a little helpful, primarily with publications.
EPA is somewhat helpful, but need clearer, less technical
information.
Information/materials/telephone assistance by EPA h;
been helpful.
General negative comment about EPA.
Good radon program.
General comment about lack of funding resources.
Asbestos Q34 and Lead/Radon Q41. This list includes all comments (paraphrased)
given by at least 5 respondents in one or both of the surveys.
About 65, percent of the sample gave one or more comments in response to this
question in each version of the questionnaire.
-------
Table 7-5
Most Frequent Comments About What More the EPA Could Be Doing
to Help School Districts Deal With Possible Environmental Risks*
Comment Frequency Specific Comment (Paraphrased)
By Survey Version
Asbestos Lead/Radon
395 448 Total number of comments given"
374 436 Total number of respondents for each version
I. EPA should provide more financial support
81 112 EPA should provide financial support for these
programs; they are taking funds away from education.
24 33 EPA should do/pay for the work required.
15 17 EPA should provide more on-site help, testing, or
other direct assistance.
5 4 EPA should provide more training and more funding.
II. Complaints about the requirements and/or guidelines
24 50 EPA should provide better/simpler information and
establish clearer guidelines.
18 16 Abolish EPA, etc.
12 15 Don't keep changing requirements/guidelines.
9 12 EPA should coordinate guidelines with state and local
agencies.
7 11 EPA should do less enforcement and give more help.
7 7 Make less/easier regulations.
3 8 EPA should do less/has not helped.
4 5 Asbestos drained/wasted funds.
3 5 Need more muscle in the regulations.
-------
Table 7-5 (continued)
m. EPA's programs/actions exaggerate the risks
23 23 EPA should take a more realistic/common sense
approach.
21 13 EPA should provide information about the true health
risks; problem not that serious.
19 4 These programs are not needed; there is no real risk;
EPA has overreacted.
S 4 EPA should do more/better publicity and stop scaring
people
rv. EPA should provide better or different information
21 16 EPA should provide a newsletter or other periodic
updates on programs and requirements.
14 7 EPA should provide more/better training.
10 5 EPA should provide more information about who is
qualified to do the work and what it should cost.
V. EPA should improve communication with the schools and with the public
20 13 More regional meetings/workshops/public meetings
would be helpful.
17 10 EPA should conduct better public relations with the
schools and Listen to feedback from the schools.
9 12 EPA should be more responsive and supportive.
VI. EPA is doing a good job,
8 3 General positive comments about EPA.
2 9 EPA has really helped.
2 8 EPA has provided good materials and information.
Asbestos Q3S and Q36; Lead /Radon Q42 and Q43. Indu ies all comments (paraphrased) given by at
least S respondents in one or both of the surveys.
** About 60% of the sample in each survey gave one or more comments in response to these questions.
-------
7-9
7.2 COMPARISONS OF LOCAL SCHOOL DISTRICT SURVEY RESPONSES ACROSS
PROGRAMS
Table 7-6 provides a comparison of similar program elements and evaluation ratings used
in the local school district surveys of the asbestos, lead in drinking water and radon program
evaluations.1 Most prominent is the effect of a program's age. The familiarity with
regulations and recommendations, receipt of EPA materials, the effect of the materials, and
the percent testing for the identified potential problem all uniformly increase with the age
of the program. Enhancing this effect are the regulations mandating specific actions with
regard to asbestos as compared to interim recommendations for lead and radon that do not
require any specific actions. As a result, there has been extensive penetration of EPA
materials and extensive testing for asbestos but only limited penetration of EPA materials
and limited testing for radon.
When we compare the percentages of districts that have tested for lead and radon to the
reported receipt of specific EPA manuals, we see that a large share of districts are at least
testing once they have the information. This seems to be a fairly high response to programs
that are voluntary.
The penetration of EPA materials is highly correlated with familiarity with regulations and
recommendations, the perception of risk and testing for the given environmental concern.
The ratings of the EPA materials vary little across the programs, although the materials on
asbestos are rated somewhat lower than the others. However, the effect of the EPA
asbestos materials is rated higher than the effect of materials for the other programs. This
probably reflects the required, versus recommended, status of testing and remediation
actions, which force school districts to rely on EPA materials. Overall, EPA materials and
assistance are seen as moderately important in motivating and helping local school districts
for each program and inadequate information from the EPA is not seen as a serious
impediment to local school districts in taking action on these programs. These tendencies
are less pronounced for the newer radon program.
1 Cross program comparisons should be taken as broadly indicative of program differences, rather than as
exact statistical comparisons due to lead and radon data being collided in a different survey version from the
asbestos results. Nevertheless, the results for identical questions (such as Q4 and Q5) are quite similar across
the survcv versions.
-------
Table 7-6
Comparison Across the Programs
Age of Program
Concern by Parents. Staff, etc
(1-none ... 4 » great)
Perceived Health Risk
(1-none ... 5 -great)
Reported Use of EPA Materials
Reported Use of State Materials
Familiarity with the Regulations/Guidelines.
(1-none ... S-very)
Recall Receiving Specific EPA Manuals
Rating of EPA Materials:
(1 - not ... 5 -very) Clear
Instructive
Complete
Materials Affect Action?
(1-none .. 2 "somewhat .. 3 definitely)
Overall Ease or Difficulty of Compliance
(1-easy ... 5 'difficult)
Have Tested for Problem
Asbestos: Submitted Plan
Asbestos
8 yrs.
12
1.8
85%
77%
4.2
80%
3.5
3.6
3.7
11
4.0
NA
98%
Lead in
Drinking Water
lyr.
1.8
1.6
70%
64%
3.1
49%
3.8
3.9
3.9
10
17
46%
NA
Radon
less than 1 yr.
1.7
1.6
52%
41%
2.6
27%
3.8
3.8
3.8
1.9
19
18%
NA
Need for Retesting and/or Remediation
(of those who have tested) 97% 43% 42%
-------
7-11
7.3 SUMMARY CONCLUSIONS
School Receptivity
Overall, public school districts are a concerned and receptive audience to the messages from
the U.S. EPA about potential health risks facing school children. This is evidenced by the
fairly substantial response to EPA's relatively new, and voluntary, lead in school drinking
water and radon programs. Nonetheless, uncertainty does seem to exist with respect to the
issues or the evidence of risk to students. These uncertainties are compounded by lack of
training on environmental issues and risk management strategies, as well as concerns about
program costs vis-a-vis educational budgets. This sometimes leads to cautious approaches
and an apparent desire to turn to state, regional and federal officials, in that order, for
guidance and assistance. A primary question, then, is: "How can EPA enhance its efforts
to support entities like public schools in identifying and reducing environmental health
risks?"
EPA Materials
The initial research question concerned one of EPA's primary efforts: program materials
development. These materials typically have been in the form of informational pamphlets
and instructional manuals. Overall, these materials are well received. They are seen as
fairly clear, informative and complete. The materials seem to be helping local school
districts understand the problems and the regulations or recommendations for dealing with
them. However, these results are also highly correlated with strong state programs for
information dissemination, training and assistance.
Several thoughts about improving the EPA materials consistently arose through both the
state interviews and the local school district surveys. These included:
1. The need for more follow-up training to help school administrators decide how to
implement the guidelines in the EPA materials (See Overall Strategy comments
below); and
2 The need for a simpler "model program" that both states and local school districts can
use for guidance. Because the lead and radon programs are largely voluntary, EPA
has chosen not to suggest preferred approaches and instead has provided several
acceptable alternatives for testing and remediation. However, some local school
district officials complain of having insufficient expertise and of being unable to
adequately choose among the alternatives. In other words, the unintended result of
this strategy is to sometimes exacerbate the confusion and frustration at the state and
local levels. This is consistent with findings of Johnson and Fisher (1989) who report
-------
7-12
fewer demands for additional information when information is presented in a
"command" mode (do this), rather than as a discussion of options with pros and con.
We encountered a number of individuals, at both the state and school district levels,
who would urge EPA to consider giving more directed guidance, while still retaining
some flexibility. This might come in the form of providing, or clearly identifying, one
model (or even preferred) approach, followed by other acceptable alternatives.
While the EPA materials on these environmental risks appear to be fairly well received and
their receipt is correlated with action to at least test for the problem, the response at the
school district level is not uniform. With the radon program in particular we see a
significant variation in response across the states that appears to be correlated with the
availability of risk information in addition to that included in the EPA manuals on radon
in schools. In a few states, such as Pennsylvania and Colorado, where radon levels in the
states have been measured and are perceived as a concern, more activity is occurring at both
the state and the school district level. In states where little information is available
regarding radon levels, schools are no more responsive than in states where measured levels
have been found to be relatively low. It appears that, whenever it is possible to do so, EPA
needs to communicate more specific information on items such as the expected risk level
in the area, types of buildings at greatest risk, etc. More information of this type is likely
to provide increased motivation for action, especially for circumstances when the expected
risks are relatively higher.
EPA Materials Dissemination
The EPA materials are useful, but only when received in a timely manner by the intended
audience. EPA's approach has varied from direct mailings to all school districts (asbestos)
to sending the materials to state agencies to distribute (lead and radon). The most effective
approach, and most expensive for EPA, is mailing program manuals directly to all school
districts. The least effective was the lead in drinking water flyer and order form which was
mailed to local school districts. This proved to be so ineffective (less than 10 percent of the
sampled school districts obtained the manual in this manner) that EPA may wish to consider
dropping this method of dissemination.
Where EPA wishes to conserve resources, and is willing to take some time in the materials
distribution process, providing materials to state agencies to distribute to local school
districts can be a relatively effective approach. However, it must be noted that the time
period for state dissemination has varied from a few months to over a year and some states
may take even longer. If reliance on state dissemination is to be truly effective, EPA should
consider providing more support and motivation to the appropriate state agencies. This issue
is discusseu in greater detail below.
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7-13
Overall Risk Communication/Risk Manaeement Strateov
The development and distribution of high quality information materials is an integral
component of an overall successful risk management strategy, but it appears that the EPA
materials for these programs are reasonably adequate for their intended purposes. The
results of this study suggest other additional areas of the overall strategy where
improvements might significantly enhance the response of the target population. The form
of the program requirements/recommendations, the technical follow-up in terms of
workshops and response to questions, financial support, and the administrative structure to
implement the program might also be considered. The following observations and
recommendations to improve the overall program strategy are presented, based upon the
findings for the three programs analyzed.
1. Regulations obviously have more motivational impact than recommendations. When
EPA makes recommendations, as opposed to promulgating regulations, there is more
room for posturing and conflicts among key individuals in state legislatures and state
agencies. These individual behaviors can significantly delay program implementation
at the state level. Recommendations also leave room for local districts to rate the
issue as a low priority among conflicting demands for limited resources.
The intended goals of the program, as well as the legislative mandate, will determine
whether regulations or recommendations are more appropriate. If the goal is to
stimulate specific action to reduce exposures to an environmental risk, then regulations
will be more effective. If, on the other hand, the goal is primarily to provide accurate
information about potential environmental risks and what the schools can do to reduce
these risks then recommendations may be preferred. The advantage of
recommendations in this case is that they offer each school the flexibility to make their
own informed choices about how to allocate their budgets according to their own
circumstances.
2. In a well intended approach to initiate the process of information flow, testing and
remediation as soon as possible, EPA has begun each of the three study programs with
"interim guidance." In some respects, this is having a backlash effect. Due to costly
experiences with changing guidance in the asbestos program, the term "interim" has
become a signal to some states and local school districts to defer any substantive or
costly actions, or at least to move slowly. Combined with controversies about how
much really should be done about some of these environmental issues, changing
guidance has engendered some ill-will toward the EPA. All of this makes it difficult
for EPA to positively initiate a program before final guidance can be provided. When
EPA firmly believes that states and local school districts should move ahead on
interim programs, one way to minimize the potential double jeopardy would be to
-------
7-14
grandfather actions taken under the interim guidance as acceptable under any fina.
regulations (and indicate this clearly in the interim guidance materials).
3. EPA is frequently not in control of funding support for these programs; nonetheless,
it is a critical concern. School districts are well intended but school budgets are
limited and trained staff are in short supply. Therefore, when difficult tradeoffs must
be made, an unfunded recommendation is very likely to have a lower priority. Some
districts have also cited instances of moving ahead when no funding is available and
then finding funds were appropriated later. This situation has created another reason
for districts to delay actions while awaiting potential funding from Congress, EPA or
state agencies.
4. An important component of a successful risk communication program is working with
key program personnel. In this case the significant link between the federal EPA and
local school districts is the state agencies. The local school district survey results
clearly indicate that districts first turn to their state health, environment and education
agencies (in many cases there are several agencies that are involved) for technical
assistance rather than the regional or federal EPA, The success of the program at the
state level depends upon both the EPA program and the state environment. The state
environment appears to be the most dominant program element and is accountable
for the most significant differences across the states in responses at the school district
level.
EPA can enhance its influence through the states in several ways. Observations and
suggestions include:
Some of the differences across states can be attributed simply to differences in
the people involved in the state legislatures and assigned agencies. For example,
New York has one of the most active asbestos and lead in school drinking water
programs, while the radon program is held up by disagreements among a few key
individuals on program design. Working with multiple individuals in one or
more state agencies and legislatures in SO states can be a formidable task. The
EPA regional offices seem to have been under-utilized to break down the task
into manageable pieces and to help facilitate local state processes. In cases such
as New York's radon program, more directed model programs from EPA might
also have helped.
Distribution of EPA materials alone is generally insufficient guidance. Training
and workshops seem to be key elements in those states that have been relatively
more successful in motivating testing for and remediation of environmental
problems. For example, for the lead in school drinking water program, compare
-------
7-15
the successful programs in New York, Texas and South Carolina, all of whom are
using extensive training programs, to the limited success in Illinois and
Pennsylvania, where such training has not been conducted.
As noted above, local school districts do not feel sufficiently informed to take on
these programs without additional training. Further, state personnel repeatedly
indicated that they felt the EPA training was not sufficient for them to then
conduct their own training of local school districts. In other cases, state
personnel simply could not attend EPA training due to funding limitations. A
key for EPA, then, may be to provide and extend training and prototype training
materials for state agency and support personnel (including university and
consulting staff personnel) so that the state can then can conduct successful and
cost-effective training for its school districts. EPA might also consider funding
for state personnel to attend to training sessions. While more expensive, these
up-front efforts may pay off in terms of faster and more efficient program
implementation requiring less EPA follow-up.
Program design and materials could benefit from more model programs and
program implementation suggestions from which states can take ideas and run.
Examples from this evaluation include suggestions on how to set up bulk
contracts to cut costs to local school districts, or providing estimated costs per
square foot of building, or other program costs.
Working with states and local school districts can be enhanced by working more
closely with state agencies to understand the problem and program before full
media attention is focused upon the program. With a free press this is a difficult
problem for the EPA, but we repeatedly heard complaints of being unprepared
for public questions when the media received information prior to, or at the
same time as, state agencies and local school districts. As a result, the public
without adequate information or response from public school officials may be
unduly alarmed about the risk, or about the competence of school officials.
While public attention and concerns are acknowledged by school officials to have
some impact they are perceived to have a much smaller impact than many other
program components.
Summary
Recognizing the age of the programs, the EPA asbestos, lead in school drinking water and
radon programs have experienced considerable success in motivating and assisting states and
local school districts to understand, test for and remedy situations leading to potential health
-------
7-16
risks to students and staff at public schools. EPA's role in these programs primarily has
been the development of the overall program design, including, informational materials,
which has then been turned over to individual states to implement. The most critical
program element appears to be the handing off of the program to states and what individual
states do thereafter. EPA has-assisted with the development and distribution of written
materials, workshops and training for state personnel, and has provided other technical
support. While this support is good for what it does, it may be insufficient. Many states
have difficulty implementing the programs, and many local school districts simply feel they
are getting insufficient support from their state agencies. This causes confusion, delays,
wasted monies and resentment To reduce these problems may require EPA to enhance the
level of information and technical support, especially in the form of training and workshops
for state personnel, and to take a more active partnership role with the states.
-------
8-1
8.0 BIBLIOGRAPHY
Chess, C. and BJ. Hance. 1989. "Opening Doors: Making Risk Communication Agency
Reality." Environment 31 (5): 11-39.
Colorado Department of Health. 1989. Rules and Regulations Governing School*} jn, the.
State of Colorado. Denver, Colorado.
Covello, V. T. and Frederick W. Allen. 1988. Seven Cardinal Rules of Risk
Communication. U.S. EPA OPA-87-020. Washington, D.C.
Dillman, D.A. 1978. Mail and Telephone Surveys: The Total Design Method. New York:
John Wiley & Sons.
Fisher, A., G.H. McClelland and W. D. Schulze. 1989. "Communicating Risk Under Title
III of SARA: Strategies for Explaining Very Small Risks in a Community Context." Journal
of the Air and Waste Management Association 39 (3): 271-275
Fumento, M. 1989. "Stirring up a Sleeping Dog." In Rockv Mountain News November 12,
1989, page 69. Denver, Colorado.
Gough, M. 1989. "Uncle Sam Flunks Asbestos Controls in Schools." Issues in Science and
Technology. Spring. Taken from a Resources for the Future, Center for Risk Management
report and written up in Environment Fall/Winter, 1988-1989.
Harvard University. 1990. Proceedings of the International Symposium on the Health
Aspects of Exposure to Asbestos in Buildings. Harvard Energy and Environmental Policy
Center. Cambridge University, (summarized as "Let Sleeping Asbestos Lie" in Health and
Environmental Digest. 1990.)
Johnson, F.R., and A Fisher. 1989. "Conventional Wisdom on Risk Communication and
Evidence from a Field Experiment." Risk Analysis 9.
Johnson, F. R., A. Fisher, V.K. Fisher and W. H. Desvousges. 1988. "Informed Choice or
Regulated Risk? Lessons From a Study in Radon Risk Communication." Environment
30:4.
McNally. R.C. 1990. Letter to Science editor concerning asbestos issues (February).
Abatement Programs Development Branch, Office of Toxic Substances, U.S. Environmental
Protection Agency, Washington, D.C.
-------
8-2
Simmons, Carl M. 1989. CAty of Raleigh's Experience in the Pilot Public Education Program
for Leatj in PrJP^ng Water. Raleigh, North Carolina.
Synstelien, Donna. 1990. The Inside Story: A Guide to Indoor Air Quality- How Well Is
It Working. EPA 230-01-90-073. Washington, D.C
United States Environmental Protection Agency, Office of Pesticides and Toxic Substances.
1989. The ABCs of Asbestos in Schools. Washington, D. C.
United States Environmental Protection Agency, Office of Pesticides and Toxic Substances.
1988. Asbestos-in-Schools: A Guide to New Federal Requirements for Local Education
Agencies. Washington, D.C.
United States Environmental Protection Agency, Office of Water. 1989. Lead in School's
Drinking Water. Washington, D.C.
United States Environmental Protection Agency, Office of Water. 1989. Lead in School
Drinking Water: A Training Aid. Washington, D.C.
United States Environmental Protection Agency, Office of Pesticides and Toxic Substances.
1988. 100 Commonly Asked Questions about the New AHERA Asbestos-in-Schools Rule.
Washington, D.C.
United States Environmental Protection Agency, Office of Radiation Programs. 1989.
Radon Measurements in Schools: An Interim Report. Washington, D.C.
United States Environmental Protection Agency, Offices of Radiation Programs and
Research and Development. 1989. Radon Reduction Techniques in Schools: Interim
Technical Guidance. Washington, D.C.
-------
APPENDIX A
1. Sample Correspondences:
Advance Letter
First Mailing Cover Letter
Follow-up Postcard
Second Mailing Cover Letter
2. Mail Survey Instruments:
Asbestos Containing Materials Survey Version
Lead in Drinking Water and Radon Survey Version
3. Telephone Survey Instrument and Instructions
RCC/Haftcr. Bully. Inc
-------
SCHOOL BOARD
ASSOCIATION
LETTERHEAD
September 5, 1989
Dear Superintendent:
The purpose of this letter is to inform you of a research project being done in our state in
conjunction with the U.S. Environmental Protection agency. This project will evaluate and
improve EPA's programs to help public school officials understand and respond to
environmental pollutant risks and regulations.
We are joining with the EPA to ask for your help on this project. You will soon receive
a brief, mailed questionnaire that the appropriate individual in your district should complete
and return. The survey covers awareness of environmental risks and regulations, what
actions have been taken to conform with regulations and how EPA can improve it's
programs to inform schools about these issues.
Because not every school district can be surveyed, your district's response is very important.
We have been assured that the reported results will in no way identify individual school
districts. We urge you to respond promptly.
The research is being conducted by Research Triangle Institute of North Carolina and
RCG/Hagler, Bailly, Inc. of Colorado. You will receive your surveys from RCG/Hagier,
Bailly, Inc. If you have any questions please feel free to contact me at (add your phone
number).
Sincerely,
NAME
Tit.e
State Association of School Boards
Address
-------
RCG/Hagler, Bailly, Inc.
PO On
Boulder Colorado 80306-1908
303/449-5518 ?« 303/443-9664
Name November 14, 1989
District
Address
City, State, Zip
Salutation:
Recently your State Association of School Boards wrote you about a survey
research project to evaluate and improve the U.S. Environmental Protection
Agency's efforts to help local school districts manage environmental risks.
Enclosed is your survey form. We ask that you, or the most appropriate
individual in your district complete this survey and return it to us in the enclosed
postage paid envelope by December 1.
Your district's response is very important to the success of this project. Because
we cannot send a questionnaire to all school districts, your district has been
scientifically selected to help represent the variety of school districts across the
state. All responses are strictly confidential. Survey results will be reported as
aggregate data and will not identify individuals or individual school districts.
The identification number on the survey form is there so we can check your
district off the mailing list when the form is returned, and avoid sending you a
reminder.
This research is being conducted in conjunction with the U.S. EPA, by the
Research Triangle Institute of North Carolina and by RCG/Hagler, Bailly. Inc.
of Colorado. We will be happy to answer any questions you might have. Please
wnte, or call, me or Ruth Chapman at (303) 449-5515.
Thank you for your assistance.
Sincerely,
Robert D. Rowe, Ph.D.
Project Manager
/enclosures
Economic 4nd Ttehmeal Count* 5, , WMHingion.Nwr Yort C*mOndfl«'Bouidar .8ru»»ti»
-------
Dear Superintendent November 22. 1989
Last week a questionnaire was mailed to you as part of a project to evaluate
and improve the U S EPA's communication with local school districts, if you
or someone m your district has already completed the questionnaire and
returned it to us. please accept our sincere thanks. If not. please be sure that
the questionnaire is completed and returned this week This questionnaire has
been sent to a representative, random sample of school districts m your state.
it is very important that every questionnaire be returned.
if by some chance, you did not recerve the questionnaire, or if it has been
misplaced, please call RCG/Hagler. Badly today. cojiflfl. at 303-449-5515 We
will put another one m the mail to you immediately Thank you for your help.
Sincerely.
Robert 0 Rowe
Project Director
-------
RCG/Hagler, Bailly, Inc.
PO On
Bouldtf Colorado 80306-1906
303.449-5515 Qfn 303/443-9644
Name December 12, 1989
District
Address
City, State, Zip
Salutation:
Nearly a month ago I mailed a questionnaire to you as pan of a project to help
the U.S. Environmental Protection Agency evaluate and improve its
communication with local school districts. The questionnaire was to be
completed by either you or the most appropriate individual in your district. As
of today, we have not received a completed questionnaire for your district.
I am writing to you again because your district is part of a small but
representative sample of school districts selected to help evaluate the US.
Environmental Protection Agency's programs. Therefore, the information that
your district supplies is very important to the success of this project. As I
indicated in my first letter, all responses are strictly confidential. Data will be
reported only in aggregate form.
I realize this is a busy time of year for school personnel, so we have extended the
survey receipt date to December 29, 1989. In case your district's questionnaire
was misplaced, I have enclosed a replacement If you have any questions, please
call me. Ruth Chapman or Dale Willingham at (303) 449-5515. We look forward
to receiving your completed questionnaire within the next two weeks.
Thank you for your assistance.
Sincerely,
Robert D. Rowe, Ph.D.
Project Director
/enclosures
Economic and f»eftnie«j Covjn** \ WMMntfo* N«w *«* «C»mbndg« .9ouid«f
-------
MANAGING ENVIRONMENTAL RISKS:
A SURVEY OF LOCAL SCHOOL DISTRICTS
Research conduced by RCG/HagJer, Baiy, Inc. for Research Triangle Institute.
Please return survty to:
RCG/Hagler, Ballly, Inc.
P.O. Drawer 0
Boulder, CO 10306
L. R
-------
By ccrr.aietmg this questionnaire you will help us to evaluate and improve federal and state
programs that provide information and assistance to local scnool districts for the 'educrcn
cf student and staff exposure to environmental HSKS Your response will ce s:r-c:iy
confidential
form should be completed by the Superintendent of Schools or by the individual wro
'S -esoonsibie for determining or supervising the actions your district takes to aaaress
cc'en: 31 environmental problems. The questions that follow are for your entire distnct
0" What is your position with this school district? (Circle the number of the best answer)
1 SUPERINTENDENT
2 OTHER (please specify)
Position title
02 HCW 'ong have you been employed m this distnct and how long have you been m ycur
:-rrent position'
YEARS IN THIS DISTRICT YEARS IN CURRENT
vvo s primarily responsible for directly supervising any actions tnis d'Stnct ta^es acc
rr. rcr.mental
Position or Department
-------
- r cast year wnat ras ceen ve ccrrcmea 'e-.e1 cf ccncen exc-essec cy zs'S'-s
= -:e":3 (2C- :y ana staff acc_: eac- c: :re :c .c.vi.-g? ;Grc:e nurrce' cf ces: -escc^se
: esc" .:eni
5-.;5r: >se cf drugs ana aiconoi
S-.-en; use of :ocacco
Asces:cs .n scncci cuiangs
==::- n SC.-CCI CuiC.ngs
C'"Sr ncccr air cclluticn
C-'rccr air "ear scn.cds
_=.= - - c.--^.-g .vater
I -= ;.-n*g .-.a:er :c-:e'.-s
1-e' scec^/i .._
NCNE '-.T71.E ;Cf.'E j = E^"
1234
1234
1234
1234
1234
1234
1 2 3 *
1234
' 2 3 4
;-c-"
3
a
3
3
a
5
3
3
a
= :r ,Cu « TS = =: ve -ea s< s 'cr s:«cs'"3 ana emoiovees ..-. >/C'_- ^ s:- : s
:es 'cr eacn c? :re -c'cv.-g' we 'eccgn.ze -t $ aiff.cuit tc wrcw e: es:" ss-e
-
:
-
=
^
~
_
"
-
~-~-i~' _3a ~( aiccnci ana arugs
_:e-: -=e ci :ccaczc
:Cf3"5 - scrcct C- cmgs
3--*" - - -"^i r» *«^-.^
^ ' ' . w WW'MM^M'^S
-5r -cccr 3:r cciiu: en
T?Z - :---.rg wa'.er
'-.- z?-->r~ .-.ater concerns
-= 'scecM
j .-JO
I f ~><
1 2
i 2
2
1 2
2
1 2
1
1 2
i 2
r ?
SCC'E
RISK
3
w
3
3
3
3
3
w
3
3
3
G
a
-
-
i
4
j
a
a
= = i*
="SK
.
f
5
5 .
5
3
5
5
:*. -
^ i *
_
**
2
a
=
;
q
J
5
2
a
j ::~n-ent /vcuid c:arfy yc-r -esrc-se ; G-es:.on.s 4 ana 5. pease acz -e'e
-------
ABOUT LEAD IN DRINKING WATER
Q7 F-orn wnere does your school district ootam its supply of drinking water"7 (C.rc:e
of ail tnat apply)
' SCHOOL OWNED WATER SUPPLIES
2 PURCHASE FROM LOCAL COMMUNITY
3 PURCHASE FROM PRIVATE SUPPLIER
7 OTHER (please specify)
OS Is there a regular program for testing your district's drinking water for contaminants rreta'S
or otner problems? (Circle number of best response)
1 NO
2 YES
3 DON T KNOW
How often does your district test
water supplies?
OS HCW familiar are you with state ana federal regulations and guidelines fr restirg 'zr ar~
ccr'ec:mg lead m school drinking water? (Orae number of best answer or eacr.j
NOT AT ALL
FAMILIAR
SOMEV.nAT
FAMILIAR
5:a:e -eguiaticns and guidelines
-scerai regulations and guidelines
2
2
3
3
a
a
-------
:c'rsc:.ng :eac .n
as vc^.r ~3"c: -3e~ *c ~e-c cs'.er~re ac'c.^s z~ '9s: "9 '
water crcc.e'-s7 C.'C 8 ve .--rrcers cf g^ '"at 3CC"/;
: NO INFORMATION HAS SE5N OBTAINED
2 P3INTE3 MATERIALS F^OM THE U S ENVIRONMENTAL PPOTECTION AGENCY
3 == NTEO MATERIALS -^OM STATB -,EALTH OE'ARTMENT
5 \E//S?AP£R OTHER PRINTED MEjlA T; AND RADIO
o ACRKSHOPS OR SEMINARS SPONSORED SY (specfy)
7 OTHER (Sucn as state Scl^oci Board Association, contractors, naticrai ec
crganzation etc Please spec *y)
Q- Have your district's ouiidings been *es:ed for lead m :i-.e drinking water75 (C.rc'e
cf cest answer)
MO
!s your c:Stnct cijrrentty panning to test for lead leve'S -n dr r.KTg water
in tne next 12 rr.cntns'
i NO ~^ Please comment
2 YES
Skip to Question 14
r£S
Continue with Q12
.v^-en cia your district first test for lead in drinking water and when sid ycor sis:-c: ~:s:
ecertiy :est for iead m dnnkmg water^ (List date or approximate nurr.cer cf nncrrs :r
.ea.-s age)
i-st test
Most recent test
-------
013 What did these tests find? (Circle numbers of al! that apply)
1 NO RETESTING OR CORRECTIVE ACTIONS WERE NECESSARY
2 RETESTING NECESSARY AT SOME SITES.
3 CORRECTIVE ACTIONS WERE NECESSARY
Has this been scheduled or corrected''
1 YES 2 NO
a What types of problems, or potential problems, were found' (Circle numcers I
of all that apply)
1 WATER SUPPLY PROBLEMS
2 PLUMBING PROBLEMS
3 WATER COOLER PROBLEMS
7 OTHER (specify)
b Please describe the problem and any difficulties in taking corrective acfcn
c What is the status of corrective actions' (Circle numbers of aj that acciy)
i SOME CORRECTIVE ACTIONS HAVE BEEN COMPLETED
When?
2 SOME CORRECTIVE ACTIONS ARE PLANNED WITHIN
3 SOME OR ALL CORRECTIVE ACTIONS HAVE NOT BEEN SCHEDULED
Why not? _ _
-------
Q 4 when testing and correcting for any lead in drinking water problems in your district' (Circe
-.umbers of a!! that apply)
DISTRICT PRIVATE STATE DONT
STAFF CONTRACTORS STAFF KNOW
Who did, or will do, the testing?
Who did. or will do, any corrective actions?
2
2
3
3
8
8
0:5 Pom what sources were funds obtained, or where will funds be obtained, to implement
testing for and correcting lead m drinking water problems?
Q'S in the spring of 1989 the U S Environmental Protection Agency (EPA) sent a flyer to all
ocai scnool districts and state health and education agencies announcing a manual entitled
Lead m School Drinking water ' From where, if at all. have you obtained or will you obtain
TIS manual' (Circle numoers of all that apply)
1 NOT AWARE OF THIS MANUAL
2 NO CURRENT PLANS TO OBTAIN THIS MANUAL
3 GOVERNMENT PRINTING OFFICE USING ORDER FORM IN THE FLYER
4 STATE DEPARTMENT OF EDUCATION OR DEPARTMENT OF HEALTH
5 FROM THE REGIONAL EPA OR FEDERAL EPA OFFICES
7 OTHER (Specify)
9 DON T KNOW
0'7 Have you received the manual'7 (Circle number of best response)
I NO
3 OONT KNOW.
3 YES
Pleas* Skip to Q21
Continue with 018
-------
Q' 3 Using tne five oomt rating scales beside eacn item, please indicate if you trunk the
Clear and Understandable
Instructive and Informative
Complete
CCNT i
NOT VERY
-------
~^ -'-'' ~cc.':a>'-t if at ail co /cu -.-< eacn cf 'Me following nas ceen m rrc* va-r~ a.-g
"TP"3 /--r c.st-ic: to J3xe ac-.c- -^ -z:e"--a\ .-eaitn nsks cue :o eaa m scree: CT*.-~
..ater' C.-c'e r-urrcer c? ces:-esccrse'cr sacn'terr)
| .MPOPTANT
S'a:e r9Ci-i.'9merits and reccmrrercaiicns 1
F9C9ra! '9Ci.irerr.ents and recommencat.cns 1
S:a:9 :ecrn:cai assistance 1
S:a:e '.ranciai assistance 1
U S EPA cratera's ara technical ass stance 1
C;rcer-s exoressed &y the puoiic, rreoia
ca'=":3 arc staff 1
O-pr s.^a-'fy} 1
2
2
2
2
2
2
2
3
3
3
3
3
3
3
iMPCPTANT <\C'.
4
4
4
A
4
4
4
5
5
5
5
5
5
5
3
3
3
3
3
3
a
C2; -r.v serais .f at an. co you :".."'< each cf tre following has been .n imoeG'ng vour cistr ct
- -ak.ng action on 'ead m cr-r.King water' (dree numoer of oest answer fcr eacn item)
NOT
seaious SERIOUS v.c/
i-aceq'_a:e cistr.ct funds 12345 3
i-aceauate state funds 12345 3
.racecua'.e i^'crmation from tre U S
="/ rcrertai Prctecticn Agercy 12345 o
i-acequaie .nforrration from state agenc.es 12345 3
i-acea-a:e expertise m aistnct 12345 3
I'aceauate staH to handle extra work 12345 3
"2- =ease acd any other corrr-ens /ou ^ave aoout the 'ederat E^viron'-ertai P-c'erc-
Agency s requirements or accut :re "ater.a's aro tecnmcai assistance tney crz^csz ace'.'
ead ^ sinking water
-------
ABOUT RADON GAS IN YOUR SCHOOLS
O25 How familiar are you with state and federal regulations and guidelines for test rg for and
correcting me presence of radon gas7 (Circle number of best answer for eacnj
State regulations and guidelines
federal guidelines
NOT AT
ALL
1
1
SOMEWHAT
FAMILIAR
2
2
3
3
--y 1
FAMILAP j
A
4
5
5
C25 Which of the following has your district used to help determine actions on test.rg 'or arc
correcting radon gas prcoiems? (C.rcie me numbers of aj! that apply)
1 NO INFORMATION HAS BEEN OBTAINED
2 PRINTED MATERIALS FROM THE U S ENVIRONMENTAL PROTECTION AGENCY
3 PRINTED MATERIALS FROM STATE HEALTH DEPARTMENT
5 NEWSPAPER AND OTHER PRINTED MEDIA
6 WOF SHOPS OR SEMINARS SPONSORED BY (specify)
7 c~ £R (Such as state School Board Association, contractors, national ecucatc"
organization. etc. please specify)
Have your district's buildings oeen tested for radon gas"* (Circle numoer cf best 'escc
i NO
IS your district currently planning to test for radon gas prcfcierrs >n :-e
next 12 months7
i NO ~^ Please comment
2 YES
Skip to Question 30
3 YES
Continue with Q2B
-------
O22 When did your district first test for radon gas. and wr.en aid your district TIOSI recent'y test
fcr radon gas9 (Ust date, or approximate numoer of mcntns or years ago)
F.rst test
Most recent test
G29 What did these tests find9 (Circle numbers of aji that apply)
i NO RETESTING OR CORRECTIVE ACTIONS WERE NECESSARY
2 DETESTING NECESSARY AT SOME SITES .
3 CORRECTIVE ACTIONS WERE NECESSARY
Has this been scheduled or completed9
1 YES 2 NO
a What types of problems were found?
b What difficulties have you had addressing these problems'7
c What is the status of corrective actions9 (Circle numbers of ajj that apply)
i SOME CORRECTIVE ACTIONS HAVE BEEN COMPLETED
When?
2 SOME CORRECTIVE ACTIONS ARE PLANNED WITHIN
3 SOME OR ALL CORRECTIVE ACTIONS HAVE NOT BEEN SCHEDULED
Why nof (specify)
10
-------
Q3C When testing and correcting for any radon gas problems in your district: (Circle numbers
cf ill that apply)
Who did. or will do, the testing? . . .
Who did, or will do. any corrective actions9
DISTRICT PRIVATE STAT= DONT
STAFF CONTRACTORS STAFF KNOW
1
1
2
2
3
3
8
8
Q3i From what sources were funds obtained, or where will funds be obtained, to implement
testing for and correcting radon gas problems?
O32 From where, if at all. have you obtained, or will you obtain, the report Radon
Measurements m Schools"9 (Circle numbers of all that apply)
i NOT AWARE OF THIS REPORT
2 NO CURRENT PLANS TO OBTAIN THIS REPORT
3 GOVERNMENT PRINTING OFFICE.
4 STATE DEPARTMENT OF EDUCATION OR DEPARTMENT OF HEALTH
5 FROM THE REGIONAL EPA OR FEDERAL EPA OFFICES
7 OTHER (Specify)
3 DONT KNOW
G23 Have you received the report "Radon Measurements m Schools?" (Circle numcer cf test
esponse)
3 OONT KNOW
Please Skip to Q37
3 YES,
Continue with Q34
11
-------
C3- J5 ng :re 'we pomi rating scales =esice eacr. nem. please indicate if you :nmk tne reccr
Saccn Measuremenis .n Scnoois is (C.rcie 8 if you den t know or aon i recall
dear and Understandable
instructive and Informative
Complete
if you did not find the report to be complete.
1
[ NOT
1 2
1 2
1 2
what else did
VERY
345
345
345
you require''
CONT |
KNOW |
3
8
8
G25 D'G the reoort affect your district's actions or plans regarding testing for radon'' (Circle
--.T.cer cf best response)
NO
2 YES SOMEWHAT
3 YES DEFINITELY
3 rCN T KNOW
Clf ' '~e 'epcrt Radon Measurements in Scnocis' had not oeen available where would yd.r
- sfict nave sought guidance on testing for and correcting radon gas prooiems'' (C.rce
-_-oers of aji that apply)
\=CRMATIQN MAY NOT HAVE BEEN SOUGHT
: 5-Af= HEALTH OB ENVIRONMENT CEPARTMENT
j REGIONAL EPA OFFICE
ENVIRONMENTAL CONSULTING FIRMS
OTHER (specify) _____
3 -ON T KNOW
12
-------
*-e'Ding your district to take action on potential
numoer of best response for each item)
NO
IMI
State requirements and recommendations 1
Federal recommendations . . 1
State technical assistance . 1
State financial assistance i
U S. EPA materials and tecnmcal assistance 1
Concerns expressed by the public, media
parents and staff . t
Othor (cponfy) 1
Q38 HOW serious, if at all. do you think each of the fol
m taking action on radon gas7 (Circie number c
inadequate district funds
inadequate state funds
Inadequate information from u S Environmental
Protection Agency
inadequate information from state
inadequate expertise in district
inadequate staff to handle extra work
health risks due to radon gas?
T VERY
'ORTANT IMPORTANT
2345
2345
2345
2345
2345
2345
2345
owing has been in impeding your
f best answer for each item)
NOT VERY
SERIOUS SERIOUS
12345
1 2 3 4 5
12345
.12345
.12345
12345
(Crce
DONT
KNOW
8
8
8
8
8
8
8
distrct
OON-
KNOV\
8
8
8
8
8
8
-------
Q39 Please add any other comments you have about the federal Environmental Pfoiecton
Agency's guidance or about the materials and technical assistance provided about radon
gas.
ALSO ABOUT THE EPA PROGRAMS
Q40 Overall, how easy or how difficult has it been for your district to comply with U.S.
Environmental Protection Agency regulations and/or guideline* for the following issues?
(Circle number of best answer for each issue).
Lead in dnnking water
Radon gas
Asbestos
Underground storage tanks
nthar («P-«»y)
nm.r r«n~-*v)
VERY VERY DONT j
EASY DIFFICULT KNOW j
.12345 8
. 1 2345 8
. 1 2345 8
12345 8
.12345 8
.12345 8
041 Does the U.S. Environmental Protection Agency currently provide any materials or
assistance, or take any actions that help you in your job of dealing with possible
environmental risks?
042 in general, what could the U.S. Environmental Protection Agency do, that it is not doing
now, to help you n your job of dealing with possible environmental nsks?
14
-------
Q*3 Please use this space for anything you would like to add about the U.S. Environmental
Protection Agency, the materials it provides, the assistance it offers, mandates.
recommendations, etc.
ABOUT YOUR DISTRICTS FACILITIES
Q44 Approximately how many of your district's buildings were built, or totally remoce'ed. m each
of the following time penods? (Circle number of best answer for each time period)
NUMBER OP
BUILDINGS
Since 1980 .
1960 1979
1940 1959
Before 1940
IF YOU DESIRE MORE INFORMATION
Check this box if you would like information how to obtain the U S. EPA Lead m School
Drinking Water manual and the name and number of the contact person in your state
government.
Check this box of you would like information how to obtain the U S. EPA report 'Radon
Measurements m Schools' manual ana the name and number of the contact person in your
state government.
Results of this survey will be aggregated so no school district can be identified, if you
would like a summary of the results ot this survey! check this box.
if you desire more information, please list your name and address here, (if it is different
from the mailing label)
Name:
Address:
Thank you for your assistance!
15
-------
MANAGING ENVIRONMENTAL RISKS:
A SURVEY OF LOCAL SCHOOL DISTRICTS
Research conducted by RCG/Hagier, Bally, Inc. for Research Triangle institute
Please return survey to:
RCG Hagler. Bailly, Inc.
P 0. Drawer 0
Boulder, CO 80306
ACM
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By completing this questionnaire you will help us to evaluate and improve federal and state
orcgrams that provide information ano assistance to locai school districts for the reduction
of student and staff exposure to environmental risks. Your response will ce strictly
confidential.
This form should be completed by the Superintendent of Schools or by the individual
j 'S -esoonsioie for determining or supervising the actions your district takes to aooress
i co;ential environmental problems The questions that follow are for your entire district
Qi what is your position with this school district7 (Circle the number of the best answer)
1 SUPERINTENDENT
2 OTHER (please specify)
Position title
Q2 HOW long have you been employed in this district and how long have you cesn ,n /cur
c-rrent position''
YEARS IN THIS DISTRICT YEARS IN CURRENT POSITION
13 Who is primarily responsible for directly supervising any actions this district takes acci-t
environmental issues9
Position or Department
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G- if tie past year, what has been the combined level of concern exoressed by care-is
-.cents, faculty and staff about eacn cf tne following'' (Circie numoer of oest resccr.se
'z~ sacn item)
Student use of drugs and alcohol
Student use of tobacco
Asoestos in school buildings
Radon m school buildings
Other indoor air pollution
Outdoor air near schools
Lead >n drinking water
Otner crmkmg water concerns
O-nor tepenfy)
MONE LITTLE SOME GREAT KN
1234
1234
1234
1234
1234
1234
1234
1234
1 2 3 J
C5 What do you think the relative health risk is for students and employees m your z sr
'aciiifes for each of the following' We recognize it is orficut to know exact'y
significant different risks are but please c.rcie tne number of the response tnat best re':
,c.r cpmion about eacn issue
St-2e~t use of alcohol and orugs
5:~aent use of tobacco
Ascestcs m school buildings
Padon in school buildings
Gt^er indoor air pollution
Outzccr air near schools
Leac n snnkmg water
Z'-S'-zr-nning water concerns
>~pr (sppnfy)
NO SOME GPEAT 3C
RISK RISK P!SK <\
12345
12345
12345
123*5
-.2345
12345
12345
12345
12345
j.:;
3
3
3
a
a
a
3
a
a
c:s
ects
k
=
a
=
3
3
3
e
a
a
.: a comment would clarify you response :c Questions 4 and 5 please ace t -ere
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ABOUT ASBESTOS IN SCHOOLS
HCW familiar are you with state and federal regulations and guiceiires 'or :--e mai-age'-:ei-t
ara aoatennent cf prooiems .-eiatea to asoestos containing materials m screes' ;Crce
--r-.cer cf cest answer for eacr)
State regulations and guidelines
Federal regulations and guicennes
NOT AT ALL SOMEAHAT
FAMILIAR FAMILIAR =i
1
1
2
2
3 4
3 4
VI. i =
5
^
n cf tne following nas /our c:sr c: jseo :o "eip determine acvcns en tre ~5"
and acatement of asoestcs ccn;a.r,,rg mater ais9 (C.rcie tne numcers of aj -a:
i NO INFORMATION HAS BEEN OBTAINED
2 PRINTED MATERIALS FROM Ti-iE U S ENVIRONMENTAL PROTECTION AGENCY
3 POINTED MATERIALS pROM STATE "E*LTH DEPARTMENT
5 NEWSPAPER OTHER PRiNTED MEDIA TV AND RADIO
5 AORKSHOPS OR SEMINARS SPONSORED 3Y (SCeC:fy)
OTHER (Sucn as state Scnoci Board Association contractors ra:c-ai
c.-ganization etc Please soec ?y)
'.Vl-c Cid or will do tne inspectors ar.c wr^rg cf /Cur SiStnct S Asces'.CS Mar3;e~=-
(C.rcie numoer of oest answer)
CL.TS.CE CONTRACTORS
DISTRICT PERSONNEL WHO T30*
MANAGEMENT PLANNERS
3 BOTH
OTHER (Specify)
SEMINAPS FOR ASSESTCS
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Has ycur aistnct submitted us Asbestos Management Plan to t.He state 'or review"* (C-r:'e
-_--cer of best answer)
1 N0 H Skip to Q22
2 YES W Continue With Q11
Q- -.v^en did your district submit .fs Asoestos Management Plan for state review?
APPROXIMATE DATE
C' 2 has /ci-r aistnct rece-ved ccTin-e^ts en :r.e p'an '-cm tne state reviev/ers"*
' NO
wr.en Sid ysu receive tne state s ccmr-e-vs''
MONTH YEAR
.vas your pian' accepted as suommed c.' .vers
oranges reauired'
[ PL*N ACCEPTED AS SUBMITTED
2 M:\CB CHANGES ^ECUlRED
| 3 5lGNiF,CANT CHANGES ^E3U!
3 CCN*K\C.V
Z'~ T:-r3 .c^r Asoestos Managenert Psan caii 'cr fz-frai 'ciicw-up inspectcrs ty c-a
-s rectors'
-.0
4 HOW
TON T KNOW
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'-i Dees your Asbestos Managemert P'an can ?cr cenocic surveillance'
! NO
2 YES
3 DON T KNOW
HOW often7
By whom will this be conducted9
i DISTRICT STAFF
2 CONTRACTORS
7 OTHER
3 DON T KNOW
Q'5 What share of your district's buildings required repairing or replacement of oipes
rcvers. ouiidmg materials etc ' (C.rc:e ces: norr.oer)
10% 20%
50% 60% 70%
90%
What is the status of :rese act.ors''
1 ALL HAVE SEEN CCMP'.E-EO
2 IN PROGRESS
3 EFFORTS HAVE NOT 8E3UN
a DON T KNOW
I
When will these efforts Se ccr-c'etec9 !
MCNTM YEAR i
if 0% Continue with Q16
What share of your district's buildings <-eauired spraying asbestos containing ~='9' 25':
crevert fcer release (caiieo encaost afcn) cr oiacmg a carrier aroura the ^r.sf = 5 ~z e*
(Circle best rurrcerj
I
-.0% 20%
6Ca
80°
SCfl
i
What is the status of rese actions7
1 ALL HAVE BEEN CCMP'.S'EO r
2 IN PROGRESS -
3 EFFORTS HAVE NOT 3E3UN
8 DON T KNOW
When will these effcrs ce c
MONTH
if 0% Continue with O17
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Did any of your district's Buildings require removal of asbestos containing materials'
l NO
Skip to Q22
2 YES,
Continue With Q18
Q12 How many buildings required asbestos removal efforts?
BUILDINGS
Q'9 in how many of these buildings are the removal efforts now completed''
BUILDINGS
O20 When are all asbestos removal efforts scheduled to be completed''
i ALL REMOVAL EFFORTS HAVE BEEN COMPLETED
2 WITHIN 1 YEAR
3 WITHIN 2 YEARS
* LONGER THAN 2 YEARS
5 NO SCHEDULE HAS BEEN SET FOR COMPLETING ALL EFFORTS
3 DON T KNOW
O2* Please describe how many if any, buildings were, or will need to be. part.aiiy cr
closed for these removal efforts
CF BUILDINGS ,
.£NQTH OF CLOSURE _
*;LMBER OF STUDENTS AFFECTED .
V-VBER OF STAFF AFFECTED
--ES COMMENTS
abatement of asbestos containing materials'7
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12 Accrcmmately now mucn more "-crgy co you excec: ycur c strict *in f.eec tc- scenc tc 'u ./
~ ycur Ascesios Managerrert P'an' ;E"ter ,cur ces: estirr.a:e)
G2- Acout wnat percent of the 'unamg to ccnauct your inspections and cesign y
pian $ from (Enter your oest estimate for eacn funcmg scarce)
D'St-'Ct f
State funcs? _ ===C=M
U S EPA grants'7 __ ?E=C=NT
Cer sources'5 'Soecify) _ _ ?==:=\T
TOTAL -oo ?E=C=YT
er;entcf t.Ke 'urcirgtc f-cier-ert your Aseestos Marageme^t s>ar
;.-! ,E~te' /cur cest est.mate 'c.' eac-: r-"c rg source)
C Strct 'urcs7
5'3:9 'urcs7
'J S EPA grants7
Ct-er sources7 (Scecfy)
S5'.9rai rccviets ana manuals SV.G-as T.-e ABC sc' Ascsstcs n Screes *T"C:
is-ec Questons apout tne New AHESA Asces:cs-n-Scrcois Rue a-e Asce
5:-" 5 A Gu.ce to New Fecerai Recuiremerts na-.e eeen -revcea -c ::='
~ ~" rs c/ :-e U S EPA Oo >c- 'ecai -eceivrg a.-/ e: 'rese -^are'a s7 C-:?
: ces: ars.ver j
Skip to Q30
-' VSS ^ Continue With Q27
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Q27 Using the five point rating scale oeside eacr> item, please indicate if you think the U S EPA
^atenais on dealing with asbestos m scnoois were, m general. (Circle 8 if you con t "scan
cr sen t know!
NOT VERY
Clear and Understandable 12345 3
instructive and informative 12345 3
Complete 12345 3
,if ,-ou did not find the materials to be complete, what else did you require7
023 Did rese materials affect your district's actions or plans regarding asbestos m scCcc's7
,C.rcie numoer of oest response)
: NO
2 YES SOMEWHAT
? "ES OEFINITELV
2 :CN T
.' :-ese U S EPA materials nad net seen available. wnere would ycur cis:r:c: "avs sc_c":
:- =5rce an inspections ano correcting for ascestos prodems' (C.rcie rupee's of §1 '."a:
acpiyj
'.rOPMATlON MAY NOT HAVE 3EEN SOUGHT
: STATE HEALTH 0« ENVIRONMENT DEPARTMENT
. =iE jiCNAL EPA OFPICE
i ENVIRONMENTAL CONSULTING FIRMS
OTHER (specify)
3 DON T KNOW
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C" -: f-cc-a-; ' at ail cc /c_
as =
:ra 3~c
"g=.ir3 /->-'" c;strc: :o :afe ac: c- c.- cc:e-;ai ream ,-,SKS cue :o ascestcs7 'C.rce
"-~=er :'ces:-escc.-se'cr ear- =)
^.OT
1 VPCR7AN7
S'a:e 'ec'ji.-errerts arc rCC.T-e'-cs: c-s
' 2 3 4 5
2345
S'a-e -ecrr cal ass.s:arce '2345
3-a-e -arc ai ass.stance 12345
U5 E3A-raTe'^'s a'-c'ec--cai ass s:ance i 2 3 4 5
Cc~cer-s e^oressea cy re c-c c -eca
1
2 3
2 3
4 5
4 5
3
3
3
c
- 'a- -g ac:cn zr asces'cs7 C ; e
as ceer
--:=' c' ces: ars.ver 'cr eac" iterr
-2cec_3'e s:a:e ''--c
'~ = cec_?.:e excer se -cst.'c:
-3:ec-a:e sta't to narc e e«"a ..c*
==/
SE^CUS
2 3
1 2 3
3 4
3 4
3 4
3 4
0
5
- ease ace any ctfer cc""~e>"3
- ;e-c/ s -ecurements cr ace-: "
;ces:cs - 3c~cc'S
.C- ~a.e arc1-: *~e 'ecera'
-3'»' as arc-ec.-r.c
P-:-r" :-
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ALSO ABOUT THE EPA PROGRAMS
Q33 Overall, how easy or how difficult has it been for your district to comply with U S.
Environmental Protection Agency regulations and/or guidelines for the following issues?
(Circle number of best answer for each issue).
I VERY VERY CONT I
I EASY DIFFICULT KNOW |
Lead in dnnkmg water . .1 2 3 4 5 8
Radon gas 1 2 3 4 5 8
Asbestos .1 2 3 4 5 8
Underground storage tanks .... . . 1 2 3 4 5 8
Other (Specify) 12345 8
Other (Specify) 12345 8
C34 Does the U S. Environmental Protection Agency currently provide any materials or
assistance, or take any actions that neip you m your job of dealing with possible
environmental risks7
025 in general, what could the U S. Environmental Protection Agency do. that it is not doing
now, to help you in your job of dealing with possible environmental risks'7
C36 Please use this, space for anything you would like to add about the U S. Environmental
Protection Agency, the materials it provides, the assistance it offers, mandates.
recommendations, etc.
10
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ABOUT YOUR DISTRICT'S FACILITIES
Q37 Aoproximately how many of your district's buildings were built, or totally remodeled, m each
of the following time periods? (Circle number of best answer for each time period)
Since 1980
1960- 1979
1940- 1959
Before 1940
IF YOU DESIRE MORE INFORMATION
Check this box if you would like information on how to obtain the U S Environmental
Protection Agency's manuals and oampniets on asbestos in schools and the name and
number of the contact person m your state government
Results of this survey will be aggregated so no school district can be identified if you
would like a summary of the results of this survey, cnecfc this box
if you desire more information, please list your name and address here (if it is different
from the mailing label)
Name
Address:
Thank you for your assistance!
1
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MANAGING ENVIRONMENTAL RISKS:
A SURVEY OF LOCAL SCHOOL DISTRICTS
TELEPHONE FOLLOW-UP
School District ID #
Interviewer ID #
Date Of Contact /DAY /MONTH /YEAR
Date of Completion (if different from above)
ASK FOR THE OFFICE OF THE SUPERINTENDENT. CHECK TO BE SURE THAT THE
NAME THAT YOU HAVE IS THE CORRECT NAME OF THE CURRENT
SUPERINTENDENT IF NOT, OBTAIN THE NEW NAME AND CHECK SPELLING.
AFTER REACHING SUPERINTENDENTS OFFICE:
Hello, my name is . and I'm calling for the Research
Triangle institute of North Carolina. We are assisting the U.S. Environmental Protection
Agency in examining the ways m which local school districts manage some selected
environmental issues.
Last November, and again in December, we mailed a survey form to your Superintendent.
Or/Ms./Mr. . We had asked that either
(Superintendent's name) complete the survey or that he/she have the most appropriate
individual m your district complete it. We haven't received your district's completed survey
as yet and we're calling to see when the survey might be returned and to learn what has
prevented some districts from returning the survey.
May I speak either with (Superintendent's name) or with the person to whom
(Superintendent's name) might have directed the survey?
(IP APPPQPRIATE INDIVIDUAL IS NOT AVAILABLE. ARRANGE CALL BACK TIME)
FOLLOW-UP CONDUCTED WITH:
1 SUPERINTENDENT
2 ASSISTANT TO SUPERINTENDENT (secretary, administrative assistant, etc )
3 ASSISTANT SUPERINTENDENT. FINANCE DIRECTOR, BUSINESS MANAGER.
DIRECTOR OF CURRICULUM, etc.)
4 ENVIRONMENTAL COORDINATOR, DIRECTOR/SUPERINTENDENT OF
FACILITIES. DIRECTOR/SUPERINTENDENT OF GROUNDS, etc.
7 OTHER (specify).
9 UNABLE TO MAKE APPROPRIATE CONTACT
"9 "990
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AFTER REACHING CORRECT INDIVIDUAL:
Ms./Mr./Dr.
my name is
and
I'm calling for me Research rnangie Institute of North Carolina, we're assisting the U.S.
Environmental Protection Agency in examining the ways in which local school districts
manage some environmental issues. Last November, and again in December, we mailed
you a survey form. We haven't received your district's completed survey as yet and we're
calling to see when the survey might be returned and to learn what might have prevented
your district from returning the survey.
Q1. Can you tell me if you, or someone in your district, received this survey last
November or December?
YES
QO TO Q2
2
8
NO
DK.
This survey was sent to a small but representative sample
of local school districts so your district's response is very
important in helping EPA to clearly understand how
environmental regulations affect public schools. Tr
survey only takes about 20 minutes to complete and it can
be done by the individual who is most familiar with how
your district Candles environmental regulations, if we send
you another oy of the survey today, could you complete
and return it within a couple of weeks?
1 NO-
2 YES
8 DK
QO TO 03
To help with our analysis while
we wait for your survey to be
returned, I'd like to ask you four
brief questions.
(THEN QO TO Q4)
(Not my decision, etc.) Ask who
would make that decision and
atk to speak to that person.
3*iiiy me
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O2. The survey was mailed to a small but representative sample of local school districts
so your district's response if very important in helping EPA to dearly understand
how environmental regulations affect public schools. The survey only takes about
20 minutes to complete. Will your district be returning the survey within the next
couple of weeks?
1 NO
GO TO Q3
2 YES
To help with our analysis while we wait for your survey to
be returned, I'd like to ask you four brief questions.
(QO TO Q4.)
HAVE
MISPLACED
FORM
If we send you another copy of the survey today, could
you return it within a couple of weeks?
1 NO-
-» QO TO Q3
2 YES
To help with our analysis while
we wait for your survey to be
returned, we'd like to ask you 4
bnef questions.
QO TO Q4
8
DON'T
KNOW
Please explain
03. So that we don't rely solely on the information provided to us by school districts
that responded to the survey, I'd like to ask you just a few questions. Your
answers will help us understand the differences between the districts that did
respond and those that did not. First, can you tell me why your district is not
responding to the survey? (DO NOT READ UST UNLESS RESPONDENT HAS
DIFFICULTY ANSWERING.)
1 TOO BUSY
2 TOO MANY SURVEYS
3 WE'VE HAD NO PROBLEMS SO WE HAVE NOTHING TO SAY THAT WILL
HELP EITHER EPA OR THE STATE
4 NOT INTERESTED IN PARTICIPATING IN AN EPA SURVEY
(or any similar responses re: EPA or the government.)
7 OTHER (specify)
19 1990
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Q4. On a scale of 1 to 5, where 1 equals NC ^ISK and 5 equals GREAT RISK, how
would you rate the relative health risk to your district's students and employees
for each of the following?
Asbestos containing materials
Lead in the drinking water
Radon gas
05. And on a scale of 1 to 5, where 1 equa
DIFFICULT, how easy or how difficult has it
federal regulations and/or guidelines for ea<
Asbestos containing materials
Lead in the drinking water
Radon gas
06. On a scale of 1 to 5, where 1 equals NOT F
HELP, please rate how much help U.S. EPA
you m your job of dealing with environment
Asbestos containing materials
Lead in the drinking water
Radon gas
NO GREAT DONT
RISK RISK KNOW
12345 8
12345 8
12345 8
Is VERY EASY and 5 equals VERY
been for your district to comply with
:n of the following?
VERY VERY DONT
EASY DIFFICULT KNOW
12345 8
12345 8
12345 8
riUCH HELP and 5 equals A LOT OF
materials or assistance have been to
H risks
NOT A LOT OF DONT
MUCH HELP HELP KNOW
12345 8
12345 8
32345 8
, inc. .*nutry tg.
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Q7. The U.S. EPA made estimates of how much the asbestos containing matenals
program would cost local school districts. It would be useful for the agency to
have a clear picture of what actual costs are. Can you estimate about how much
your district has spent so far on management plans, inspections and abatement
activities for asbestos containing materials?
8 DK (Information not at hand)
08. Do you have any other comments you'd like to add?
IF RESPONDENT HAS AGREED TO OUR SENDING ANOTHER SURVEY FORM
TODAY, CHECK CORRECT NAME AND ADDRESS
THANK YOU VERY MUCH FOR YOUR TIME.
WE APPRECIATE YOUR ASSISTANCE!
. tolly, ine '-a/lul/> '* <98°
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