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Office of Inspector General
Mid-Atlantic Audit Division
Final Audit Report
Final Report on Region IIFs
Children's Health Initiative on the
Asbestos Hazard Emergency Response Act
(AHERA)
Report Number 2000-P-00024
September 28, 2000
Aa Bb Cc Dd Ee Ff Gg Hh li Jj Kk LI Mm Nn Oo Pp Qq Rr Ss Tt Uu Vv Ww Xx Yy Zz
Asbestos in Schools
DANGER
iASBESTOS I
1986
1987
1997
| crayon

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Inspector General Division
Conducting the Audit:
Mid-Atlantic Audit Division
Philadelphia, PA
Program Offices Involved:
Region Covered:
States Covered:
Audit Team:
Waste and Chemicals
Management Division
Philadelphia, PA
Office of Enforcement and
Compliance Assurance
Washington, D.C.
Region III
Maryland Department of the
Environment
West Virginia Department of
Health and Human Resources
Victoria Rawle, Michael Wall,
Karen Wodarczyk, Teri
Woodcock
We would also like to
acknowledge Garry Sherman,
Former Regional Asbestos
Coordinator, for his
contributions to this report.

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.
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ACTION REQUIRED
This report makes recommendations to the Assistant Administrator for the
Office of Enforcement and Compliance Assurance (OECA) and the EPA Region III
Administrator. In accordance with EPA Order 2750, the action official is required
to provide a written response to the audit report within 90 days of the date of this
report.
In responding to the draft report and during the exit conference, Region III
officials provided corrective actions and milestone dates for the recommendations
applicable to Region III. Therefore, no further response to this report is required by
the Regional Administrator.
We have no objections to the further release of this report to the public.
Should your staff have any questions about this report, please have them contact
Michael Wall or Teri Woodcock at (215) 814-5800.
Attachment
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EXECUTIVE SUMMARY
Purpose	The purpose of our audit was to determine the:
(1)	Status of the Region III Children's Health Initiative
on the Asbestos Hazard Emergency Response Act
(AHERA) inspection program.
(2)	Adequacy of EPA's stewardship over the various State
AHERA inspection programs within Region III.
(3)	Human resources necessary to maintain a viable
AHERA inspection program.
Results-in-Brief Our audit disclosed several areas needing improvement with
respect to the AHERA inspection program.
Region III Needs to Increase Inspections
At current staffing levels, the Region is unable to perform an
adequate number of asbestos compliance inspections. For
the most part, the Region inspects only an infinitesimal
number of schools because it can only respond to tips and
complaints it receives about possible asbestos problems in
schools. This situation arose, in part, because the number of
Region III inspectors has decreased over the past two years.
As a result, the Region is unable to provide the coverage
necessary to assure that school districts are complying with
AHERA, which in turn places school children and school
employees at risk. Moreover, at the time of our audit, EPA
Headquarters was suggesting a "disinvestment" from the
Agency's asbestos inspection program.
EPA Must Inform Charter Schools About Asbestos
AHERA applies to all public and non-profit private schools,
kindergarten through grade 12. However, as of April 2000,
EPA has had very limited contact with "charter schools,"
apparently because of resource constraints. As a result, an
unknown but possibly large percentage of the 1,605 charter
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schools attended by 250,000 students nationwide have never
been inspected for asbestos. This lack of inspections is a
consequence of the schools not knowing they are mandated
by AHERA to do so. The lack of knowledge occurred in part
because EPA did not inform the schools of this mandate.
Consequently, school students and employees may be
unknowingly exposed to the dangers of asbestos.
Recommendations We recommended that the Region III Administrator devote
the resources necessary to operate a viable asbestos
inspection, outreach, and enforcement program. Region III
officials advised that although the AHERA program would
receive no additional inspectors, an inspector from another
program would also conduct asbestos inspections. The
Region's response is noted. At a future date, we will perform
a follow-up review to determine the adequacy of the corrective
actions.
We recommended that the Assistant Administrator for the
Office of Enforcement and Compliance Assurance (OECA)
notify all charter schools of AHERA mandates, and develop a
strategy to ensure that the charter schools comply with
AHERA.
OECA agreed with our recommendation to notify charter
schools of AHERA mandates. With respect to the
recommendation that OECA develop a strategy to ensure that
charter schools comply with AHERA, OECA advised that due
to severe budget constraints, it will not direct the Regions to
invest additional resources in compliance assistance or
monitoring in the AHERA program. However, during the exit
conference, OECA said it will notify the Regions to include
charter schools in the universe of schools inspected.
OECA's agreement to disseminate information regarding
AHERA requirements is a good step. While we recognize that
the Agency has budget constraints, we believe that OECA
should, at a minimum, advise the Regions to include charter
schools in their current compliance and monitoring strategies.
During the exit conference, OECA agreed to do so.
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TABLE OF CONTENTS
CHAPTER 1	 1
INTRODUCTION	 1
Purpose	 1
Background 	 1
Noteworthy Accomplishments	 5
Scope and Methodology	 5
Prior Audit Coverage	 6
CHAPTER 2	 7
REGION III NEEDS TO INCREASE INSPECTIONS	 7
District of Columbia Public Schools	 8
Region III Program 	 10
Disinvestment of Small Federal Programs	 12
Core Minimum Program	 13
Conclusion 	 14
Recommendation	 14
Region Ill's Response	 15
OIG's Evaluation	 15
CHAPTER 3		17
EPA MUST INFORM CHARTER SCHOOLS ABOUT ASBESTOS 		17
Conclusion 		21
Recommendations 		21
OECA's Response		21
OIG's Evaluation		22
Region Ill's Response		22
OIG's Evaluation		22
CHAPTER 4		23
EFFECTIVENESS OF INSPECTIONS UNDERSTATED		23
Recommendation		25
Region Ill's Response		25
OIG's Evaluation		25
APPENDIX 1	 27
Region Ill's Response to Draft Report	 27
APPENDIX 2	 33
OECA's Response to Draft Report	 33
APPENDIX 3	 37
Distribution 	 37
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CHAPTER 1
INTRODUCTION
Purpose	The purpose of our audit was to determine the:
(1)	Status of the Region III Children's Health Initiative
on the AHERA inspection program.
(2)	Adequacy of EPA's stewardship over the various State
AHERA inspection programs within Region III.
(3)	Human resources necessary to maintain a viable
AHERA inspection program.
Background
Asbestos I
Asbestos was most commonly used in
schools as insulation and in building
materials. But it has also been found in
floor and ceiling tile, cement pipe,
corrugated-paper pipe wrap, acoustical and decorative
insulation, and pipe and boiler insulation. Substantial
amounts of asbestos, particularly in sprayed form, were used
in school buildings during the period 1940 through 1973. In
1973, EPA banned most uses of spray-on asbestos materials.
Health Risks
Asbestos tends to break down into a dust
of microscopic size fibers. Because of their
size and shape, these tiny fibers remain
suspended in the air for long periods of
time and can easily penetrate body tissues after being
inhaled or ingested. If inhaled, asbestos fibers can cause
mesothelioma (cancer of the chest and abdominal linings),
lung cancer, and asbestosis (irreversible lung scarring).
Symptoms of these diseases generally do not appear for 10 to
30 years after exposure. Thus, exposure to asbestos early on
in childhood can significantly increase health risks because
these diseases may not show up until many years afterward.
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And, according to EPA, there is no safe level of asbestos
exposure.
The potential for an asbestos-containing material to release
fibers depends primarily on its condition. If the material
crumbles by hand pressure, it is known as "friable" and
friable asbestos often flakes off as a fine dust that settles on
surfaces. Fibers can then be stirred up into the air as
children walk through school buildings.
According to the U.S. Department of Education, there are
currently 53.2 million children enrolled in the Nation's
public and private elementary and secondary schools. EPA
estimates that there is asbestos in approximately 107,000 of
these schools.
Because the average public school in America is 42 years old,
and because asbestos has a useful life span of 30 years, some
of the asbestos material is releasing asbestos fibers into the
air of the schools. Consequently, schools spend a lot of
money on asbestos projects. According to a 1995 General
Accounting Office report, public schools spent $1.7 billion
over a three-year period to fulfill Federal asbestos
requirements (i.e. inspections, response actions including
encapsulation, repair, enclosure, and removal) and would
need an additional $2.4 billion over the next three years to
fulfill these requirements.
Concerned about the health of school children, in 1986,
Congress passed AHERA. The Act required EPA to
promulgate regulations requiring: (1) inspections of asbestos-
containing material in the Nation's schools; (2) development
of asbestos management plans for such schools; and, (3)
implementation of appropriate response actions to remedy
any asbestos-related problems in a safe and complete
manner.
In 1987, EPA issued the "Asbestos-
Containing Materials in Schools
Rule," under the authority of the
AHERA enacted by Congress.
The "Rule" requires each "Local Education Agency," e.g.,
school district, to designate either a consultant or a school
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Report No. 2000-P-00024
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employee, as the single point of contact for public
information about asbestos-related activities. This designee
is to be trained and is responsible for ensuring that:
(h All schools within the district are inspected for
asbestos.
(h All schools are reinspected every three years
thereafter.
(h Surveillance activities are performed by qualified
personnel on a semiannual basis.
Each school district is also to be aware of any local asbestos
control requirements, and must inform parents, teachers,
and other school workers annually about the "asbestos
management plan."
tThe "Rule" requires school districts
to develop and implement an
asbestos management plan for each
of its schools. The purpose of such a
plan is to control exposure by assuring that all asbestos-
containing materials are kept in good condition. Specifically,
the plan indicates the location and condition of any asbestos
within a school building, as well as any information
regarding sampling, analyses, or assessments that have been
performed. These plans were to have been submitted by
October 1988 to the appropriate state agencies for review
and approval. School districts are required to maintain an
updated asbestos management plan in their main offices as
well as in each school. In addition, the plans are to be made
available to the public for review.
I The "Rule" requires a three-year
reinspection of each school by a
certified inspector, and the
inclusion of the inspection results
into the asbestos management
plan. Also, the school districts are to perform surveillance
every six months thereafter, of any school building found to
contain asbestos. Although the person conducting such
surveillance does not have to be an accredited inspector, this
Report No. 2000-P-00024
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individual should be familiar with the school building in
order to accurately report any changes in the condition of the
asbestos, and to include this information in the asbestos
management plan.
Since 1995, EPA has considered the environmental health
risks of children in all risk assessments, risk
characterizations, and public health standards set for the
United States. In September 1996, the Administrator of EPA
announced a national agenda to protect children's health
from environmental threats.
In April 1997, the President signed an Executive Order
requiring all Federal agencies to: (1) assign a high priority to
addressing health and safety risks to children; (2) coordinate
research priorities on children's health; and, (3) ensure that
their standards take into account special risks to children.
In May 1997, the Administrator of EPA established the
Office of Children's Health Protection, whose mission is to
make the protection of children's health a fundamental goal
of public health, and to facilitate EPA efforts to protect
children from environmental threats.
In March 1998, Region III established a project to increase
the number of inspections of school asbestos management
plans and abatement activities at schools. Some of the
specific goals listed in the Waste & Chemicals Management
Division's 1999-2000 Implementation Plan were to:
(h Increase compliance monitoring of schools to ensure
compliance with AHERA regulations to minimize risk
of asbestos exposure to children and workers in
schools.
C) Improve public awareness of asbestos hazards in
schools by monitoring compliance with public
notification requirements of AHERA school asbestos
management plans.
It is EPA's role to determine if the Local
Education Agencies comply with AHERA
and to take enforcement action if needed.
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(h Implement an outreach program to facilitate
compliance.
C) Conduct at least 50 percent of compliance inspections
at high risk or disproportionately exposed
communities and other priority areas of non-
compliance.
Noteworthy	We believe that Region III has performed commendably,
Accomplishments considering the limited number of people assigned to
inspecting schools. This is why we recommended that the
Region consider increasing the number of people it has
inspecting schools.
Scope and	We performed this audit according to the Government
Methodology	Auditing Standards (1994 Revision) issued by the
Comptroller General of the United States as they apply to
program audits. The audit included tests of program records
and other auditing procedures we considered necessary.
We began our review with a survey on March 9, 1999. As a
result of the survey, we began an in-depth review on
December 1, 1999. Because of personnel constraints, this
review was suspended several times between March 1999
and September 1999. We completed our audit fieldwork on
April 18, 2000.
Documents reviewed included: the Asbestos Hazard
Emergency Response Act and corresponding Federal
regulations found in 40 CFR 763 entitled Asbestos-
Containing Materials in Schools; asbestos compliance
inspection reports and enforcement documents issued by
Region III; grant agreements issued for fiscal years 1996
through 1999 to the Maryland Department of the
Environment and to the West Virginia Department of Health
and Human Resources; and, asbestos compliance inspection
reports completed by these two State Agencies.
We also verified that compliance and enforcement data was
maintained in a national database; however, we did not
review the internal controls associated with the input and
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processing of information into the database. Review of the
Region's fiscal years 1997 through 1999 Assurance Letters,
prepared under the Federal Manager's Integrity Act, noted
no weaknesses pertaining to the issues raised in this audit.
We conducted our fieldwork in EPA Region III and at the
Maryland Department of the Environment. For Region III,
we randomly selected for review 98 of the 201 inspections
conducted by regional inspectors for fiscal years 1997
through 1999, including 38 inspections with violations and
60 inspections with no violations. The bulk of these
inspections were of schools in the District of Columbia. For
Maryland, we reviewed 120 of the 127 inspections conducted
by State inspectors during fiscal years 1996 through 1999.
For West Virginia, we reviewed the 79 inspections conducted
by State inspectors during fiscal year 1999.
For simplicity purposes, we refer to the District of Columbia
as a "State," because under AHERA, it has the same
responsibilities, and is subject to the same requirements as a
State.
We issued the draft report on June 15, 2000. We received
responses from Region III on July 25, 2000, and the Office of
Enforcement and Compliance Assurance on July 26, 2000.
For the most part, they agreed with our recommendations.
The responses and our evaluation are summarized at the end
of Chapters 2 through 4, and are provided in their entirety in
Appendices 1 and 2. We held an exit conference with
Region III on September 13, 2000, and with the Office of
Enforcement and Compliance Assurance on September 20,
2000.
Prior Audit	There has been no prior OIG audit coverage in this area.
Coverage
6
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CHAPTER 2
REGION III NEEDS TO INCREASE INSPECTIONS
At current staffing levels, the Region is unable to perform an
adequate number of asbestos compliance inspections. For the
most part, the Region inspects only an infinitesimal number
of schools because it can only respond to tips and complaints
it receives about possible asbestos problems in schools. This
situation arose, in part, because the number of Region III
inspectors has decreased over the past two years.
Specifically, the funding for Senior Environmental Employees
who perform inspections under the Toxic Substances Control
Act was reduced from $157,000 in fiscal year 1998 to $57,000
in fiscal year 2000. Thus, the amount of money actually
available for AHERA inspections is substantially less. As a
result, the Region is unable to provide the coverage necessary
to assure that school districts are complying with AHERA,
which in turn places school children and school employees at
risk. Moreover, at the time of our audit, EPA Headquarters
was suggesting a "disinvestment" from the Agency's asbestos
inspection program.
We believe that Region III should consider expanding rather
than curtailing this program. Accordingly, in partnership
with regional personnel, we designed a core minimum
asbestos program, i.e., we determined the minimum number
of inspectors required to maintain a viable inspection
presence within the Region.
. ,, .	L The AHERA Law requires
Al IKKA Kcquircmcnls ¦ , , ,. . ^ „
school districts to perform a
variety of tasks regarding the
detection of asbestos. EPA's
enforcement responsibilities require that the Agency monitor
to ensure that school districts are actually performing these
tasks. In Region III, a large part of this monitoring is to be
accomplished via asbestos compliance inspections, i.e., an
inspector visits schools to verify that they are complying with
the Law. For the States of Maryland and West Virginia, such
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inspections are performed by State agencies funded by EPA
grants. For the District of Columbia, Pennsylvania,
Delaware, and Virginia, the inspections are performed by
EPA.
Some educators lack knowledge about the
hazards of asbestos. As will be explained in
Chapter 3 of this report, the current levels of
personnel assigned to the asbestos program
affects the Region's ability to make newly
schools" aware of these hazards.
Inspections are important because we also noted one case
where a School District evidently ignored asbestos hazards.
In 1996, about 12,239 square feet of damaged asbestos floor
tile was removed from a school building and disposed of by
school employees, school students, and other volunteers. As a
result of a referral from EPA's Criminal Investigation
Division, in 1997, Region III conducted several inspections of
the school and determined that: (1) the School District failed
to maintain adequate asbestos management plans for three of
its schools; and, (2) asbestos had been removed and disposed
of without the proper safety precautions being taken. In a
newspaper article following the inspections, the
superintendent of the School District was quoted as stating:
"This is a big joke. They can suck on asbestos the rest of their
lives and never get cancer ...." In 1998, the superintendent
was indicted in Federal District Court and later, after a jury
trial, was found guilty of failing to follow procedures for
properly removing and disposing of asbestos-containing
material. In February 1999, Region III issued a Complaint
against the School District for Worker Protection and AHERA
violations. This Complaint was settled in July 1999, with the
School District paying a cash penalty and agreeing to correct
the violations.
Need loi
Iducal ion
created "charter
District of	The asbestos problems of the District of Columbia Public
Columbia Public Schools (DCPS) perhaps best support the need to increase
Schools	EPA's compliance inspection coverage. This School District,
which includes 175 schools, had been last inspected for
asbestos hazards in 1994 by a contractor. In September
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1998, students refused to attend a high school that was
undergoing asbestos abatement activities. After inspecting
the building, the Region III inspector concluded that the
abatement action was proper. However, the inspector also
noted that the school was out of compliance because it lacked
any of the AHERA-required documentation, including an
asbestos management plan.
Upon learning that DCPS's main office also did not have
copies of the documents required by AHERA, the Region III
inspector expanded the inspection to include all 175 of the
schools within the School District. As a result, the Region
determined that none of the 175 schools had any of the
documentation required by the Law, i.e., asbestos
management plans, training records, response action
records, reinspection records, and records of periodic
surveillance.
According to DCPS officials, the asbestos management plans
at the schools disappeared during a dispute between the
School District and the contractor hired in 1994 to conduct
the inspections. Moreover, the officials explained that the
copies of the documents stored in the main office were
destroyed after having been contaminated by asbestos.
In acknowledgment of the serious
nature of the violations, DCPS funded
the U.S. Army Corps of Engineers
(USACE) with $2 million to hire
contractors to inspect its schools for asbestos and to develop
asbestos management plans. These inspections showed that
many of the schools had "major asbestos fiber releases"
requiring over $5 million to remediate. A major fiber release
is the dislodging of more than 3 square or linear feet of
friable asbestos; the inspectors of the DC schools found that
some schools had thousands of feet of friable asbestos
dislodged. Consequently, 55 of the 175 schools were
partially or fully closed during the Summer and/or Fall of
1999. In addition, DCPS employees worked with asbestos-
containing building materials without proper training and
personal protection equipment, a violation of EPA's Worker
Protection Standards.
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To further complicate matters, the
Region III inspector concluded that a
contractor hired by USACE performed
numerous inadequate inspections. When
the Region III inspector reinspected one of
the schools, he found that significant areas of the school had
been omitted. The inspector also learned that significant
areas had been improperly defined, thus resulting in invalid
sampling and assessments. A further evaluation by the
USACE indicated other inspections with similar problems.
This discovery necessitated reinspecting all the schools
inspected by three of the seven contractor inspection teams.
Region III notified the Department of
Justice that EPA would be referring a
multi-million dollar case to that
Agency for enforcement. As of
December 1999, EPA and DCPS were negotiating a Consent
Decree to stipulate the size of penalties for any future
violations. Also, the Region planned to issue a Complaint
against the contractor who had conducted the inadequate
inspections.
nadcquaU
nspcd ions
Status of DCPS
Region III	According to the 1998-1999 Quality Education Data Guide,
Program	there are 10,609 schools with 5,282,650 students and
teachers within Region III. Regional personnel affiliated
with the asbestos program can be called upon to perform a
variety of tasks under various laws and regulations. For
instance, under the Toxic Substances Control Act (TSCA),
they can respond to complaints pertaining to three sections:
AHERA, the Asbestos School Hazardous Abatement
Reauthorization Act, and the Worker Protection Rule. Under
the Clean Air Act, they focus on inspections of asbestos
abatement actions under the National Emissions Standards
for Hazardous Air Pollutants (NESHAP). And, under
normal circumstances, most NESHAP activities are also
regulated by one of the three TSCA sections. Consequently,
the renovation of a school by public school employees would
fall under all of the above. Moreover, in addition to
conducting the various types of inspections, regional asbestos
personnel provide compliance assistance to the schools, and
help develop enforcement cases when violations warrant
doing so.
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During fiscal year 1999, the AHERA and
NESHAP asbestos inspections for the
District of Columbia, Pennsylvania,
Delaware, and Virginia were performed by
two EPA employees and by two Senior
Environmental Employment Program1 employees. There are
7,684 schools with 3,910,471 students and teachers within
these four States. Under normal circumstances, the
inspectors conduct approximately a total of 35 inspections a
year, the bulk of which arise from tips or complaints reported
to EPA.
The AHERA inspections for the remaining States within
Region III, Maryland and West Virginia, were performed by
State inspectors under grant agreements with EPA. There
are 2,925 schools with 1,372,179 students and teachers
within these two States. During fiscal year 1999, Maryland
conducted 26 compliance inspections, for which EPA paid
$103,730, and West Virginia conducted 79 inspections (plus
13 Worker Protection inspections) for which it received
$124,570. Although the two States initiated some of these
inspections because of tips or complaints, many of them were
also "neutral" in origin, meaning the schools were randomly
selected for inspection.
Sixty-five percent of the Maryland schools inspected, and 33
percent of the West Virginia schools inspected, were in
violation of AHERA. However, Region III was unaware of
this situation because neither State reported any violations,
because the States' inspectors assisted the schools to remedy
said violations. As commendable as this may be, it
understated the problems found, as well as the
accomplishments of the compliance inspections. (Chapter 4
of this report provides more details concerning the under-
reporting of violations.)
While it appears that EPA will continue to fund the two
State grants, the resources available to the Region itself
have diminished. As recently as April 1998, there were four
Federal employees and four Senior Environmental
1 The Senior Environmental Employment Program was created by EPA to give workers 55 and older an
opportunity to use their skills, in this case, conducting asbestos inspections in schools.
11
lisped mil
I {('sources
Report No. 2000-P-00024
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Employment Program (SEE) employees working in the
asbestos program. These employees were funded under
TSCA and the Clean Air Act. However, one year later this
level had dropped to two Federal and two SEE employees.
Moreover, the TSCA funding of the SEE program has been
drastically reduced, both nationwide and within the Region,
from fiscal year 1998 to fiscal year 2000. Specifically, SEE
funding for TSCA inspections was cut from $1.4 million to
$500,000 overall, and from $157,000 to $57,000 for
Region III. Thus, the amount of money actually available for
AHERA inspections is substantially less. As a result of the
decrease in Federal inspectors and the $100,000 cut in SEE
funding, the Region's ability to adequately respond to tips
and complaints, to provide compliance assistance, and to
initiate outreach activities has considerably lessened.
Moreover, the oversight and management of the two State
asbestos grants, as well as the development of asbestos
enforcement cases, is now being handled by personnel on
loan from the Pesticides Program.
Disinvestment of
Small Federal
Programs
Small programs are vital to the Agency's
mission. They address a huge regulated
community that presents real environmental
problems, including at times substantial risks.
In many cases, the federal government provides
the only enforcement presence as there are no
authorized state programs.
These programs have very few resources to cope
with the enormous universe of regulated
entities and transactions they are responsible
for. In some cases, the programs are virtually
on life support and we have ceased to have any
real presence.
In May 1999, EPA's Office of Enforcement and Compliance
Assurance proposed disinvesting resources from four small
Federal programs, one of which was the AHERA program.
OECA recognized that:
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However, in light of budget restrictions OECA considered
whether it should obtain economies of scale by consolidating
programs and selectively increasing investment in areas
presenting high risk and high noncompliance. After a series
of meetings, issue papers, and comments by the Regions, in
November 1999, OECA issued a memorandum announcing
its decision regarding compliance and enforcement resources
for the small Federal programs. This decision, to be phased
in over fiscal year 2000 and fully implemented by fiscal year
2001, would allow each Region to propose resource shifts
between national priorities and small programs depending
on its specific and unique circumstances. Such shifts would
have to be negotiated and agreed upon with OECA. If a
Region chooses to disinvest in a particular program, the
Region is still required to maintain a core program including
activities to determine compliance problems and to develop
strategic approaches to solving those problems. However, we
believe that the Region III environmental situation justifies
investing rather than disinvesting in AHERA.
Core Minimum
Program
This option entails restoring the program to
its April 1998 level, i.e., four Federal and four
SEE employees. Adopting this option would
allow the Region to improve inspection
coverage to the four States — Delaware, Pennsylvania,
Virginia, and the District of Columbia, that are within its
purview.
This option uses the logic that if Region III
devoted the same resources to the other four
States as is devoted to Maryland and West
Virginia, it could afford to increase its
inspections, enforcement capacity, and outreach services. For
example, in fiscal year 1999, EPA spent an average of
$ 114,150 each for Maryland and West Virginia grants. If the
Agency devoted similar resources to the four other States, the
13
In consultation with Region III personnel, we developed two
options for maintaining a core minimum program, i.e., the
minimum number of personnel necessary to run a viable
asbestos program.
Report No. 2000-P-00024
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Region could afford the services of two additional SEE
employees per State.
Conclusion	It appears that the EPA grants provided to Maryland and
West Virginia afford those States better asbestos inspection
programs than that of Region Ill's, which is "bare bones." The
Region can basically only respond to emergencies, rather than
conduct compliance inspections in Delaware, Pennsylvania,
Virginia, and the District of Columbia. The Region is also
challenged to take enforcement actions, which only EPA can
do, as enforcement cannot be delegated to the States. This
situation arose, in part, because the number of inspectors has
decreased. As a result, school children and employees are at
risk. For example, the District of Columbia was unaware that
major fiber releases had occurred, and that students and
employees may have been needlessly exposed to an
environmental hazard in the five years since the schools had
been last inspected. Accordingly, we believe that Region III
should consider expanding rather than curtailing this
program.
Recommendation 2.1 We recommend that the Region III Administrator
devote the resources necessary to operate a viable
asbestos inspection, outreach, and enforcement
program. This could be accomplished by adopting the
options we developed in partnership with regional
personnel, or by developing some other alternative.
Option 1 - Entails restoring the program to its April
1998 resource level (four Federal and four SEE
employees). Adoption of this option would allow the
Region to improve inspection coverage to the four states
that are within its purview.
Option 2 - Uses the logic that if the Region devoted the
same resources to the four States within its purview as
is devoted to Maryland and West Virginia, it could
afford to increase its inspections, enforcement capacity,
and outreach services. For example, in fiscal year
1999, EPA spent an average of $114,150 each for
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Report No. 2000-P-00024
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Maryland and West Virginia grants. If the Agency
devoted similar resources on the four other States, the
Region could afford the services of two additional SEE
employees per State.
Region Ill's	In its response, Region III initially agreed with our
Response	recommendation and advised that it is in the process of
requesting additional inspector resources for this important
program from the existing regional inspector pool. However,
during the exit conference, regional officials advised that the
AHERA program will not receive additional inspector
resources. Instead, an inspector from another TSCA program
will also be conducting asbestos inspections.
OIG's Evaluation The Region's response is noted. At a future date, we will
perform a follow-up review to determine the adequacy of the
corrective action. No further response to this report is
necessary.
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CHAPTER 3
EPA MUST INFORM CHARTER SCHOOLS ABOUT ASBESTOS
AHERA applies to all public and non-profit private schools,
kindergarten through grade 12. However, as of April 2000,
EPA has had very limited contact with "charter schools,"
apparently because of resource constraints. As a result, an
unknown but possibly large percentage of the 1,605 charter
schools attended by 250,000 students nationwide have never
been inspected for asbestos. This lack of inspections is a
consequence of the schools not knowing they are mandated by
AHERA to do so. The lack of knowledge occurred in part
because EPA did not inform the schools of this mandate.
Consequently, school students and employees may be
unknowingly exposed to the dangers of asbestos. We
recommend that the Agency inform the schools in the most
expedient manner possible. We also recommend that EPA
develop a strategy to ensure that the charter schools adhere
to the Law, as EPA is the only Agency, Federal or State, with
such enforcement authority.
Charter schools are public schools
that come into existence through a
contract with either a State agency or
a local school board. This charter, or
contract, establishes the framework
within which the school operates and provides public support
for the school for a specified period of time. But unlike
traditional school systems, charter schools are obligated to
obtain their own school buildings.
A charter gives a charter school autonomy over its operation
and frees it from some regulations that other public schools
must follow. In exchange for this flexibility, the charter
schools are held accountable for achieving specific goals, such
as improving student performance. However, this flexibility
does not exempt charter schools from complying with AHERA.
Thus, by Law, all charter schools must:
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Report No. 2000-P-00024
I lislory of
(Mku'Ici' Schools
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(h Inspect school buildings for asbestos-containing
materials;
C) Develop, implement, and update asbestos management
plans; and,
C) Take appropriate response actions to remedy any
asbestos-related problems.
Charter schools have spread rapidly since the first one opened
in 1992. According to a report funded by the U.S.
Department of Education issued in January 2000:
(h There were more than 1,600 charter schools in
operation, 421 of which opened in 1999.
(h These schools taught 250,000 students in the 1998-
1999 school year.
C) During 1999, three States passed charter legislation,
bringing the total number of jurisdictions with charter
laws to 37 States, including the District of Columbia.
Estimated Number of Operational Charter Schools,
by Year
1800
1600
1400
1200
1000
800
600
400
200
0
1992-93 1993-94 1994-95 1995-96 1996-97 1997-98 1998-99 Sept. 1999
Source: U.S. Department of Education,
The State of Charter Schools 2000
The number of students in charter schools increased in the
1998-99 school year by 90,000, bringing the total to more than
250,000 students. According to the Charter Friends National
Network web site, the number of students attending charter
schools will rise to 350,000 by the Fall of 2000.
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Since 1994, the U.S. Department of
Education has provided grants to support
charter schools. In fiscal year 1995, such
grants amounted to $6 million. In fiscal
year 1999, the grants reached $100
million. However, despite these expenditures, the topic of
asbestos in charter schools has been basically ignored. In a
review of various web sites, we found only one instance
(Florida Department of Education) where this issue was
addressed. On the other hand, there was no mention of
asbestos or AHERA on the internet web sites for the U.S.
Department of Education, the U.S. Charter Schools, or the
National Parent and Teacher Association.
I In fiscal year 1999, Region III
inspected 23 charter schools, all of
which were in violation of AHERA.
Three of these schools are located in
the building complex that also
houses EPA Headquarters offices in Washington, DC.
However, due to a shortage of inspectors, Region III is
currently unable to inspect any additional charter schools.
Also, the Region does not provide "outreach" to charter
schools to make them aware of their responsibilities under
AHERA and the dangers of asbestos. Moreover, according to
regional personnel, such schools are unlikely to be aware of
these obligations, because none of the applications used to
obtain their charters even mention asbestos.
In order to determine the status of EPA's contact with charter
schools nationwide, we sent a questionnaire to the Regional
Asbestos Coordinators (RACs) in the other nine Regions. The
responses we received are as follows:
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REGION
RESPONSE
I
Although the Region has had no contact with charter schools, the
state agencies in Connecticut, Massachusetts and Rhode Island
are aware of these schools, and have conducted outreach efforts
and inspections. State agencies in Connecticut and Rhode Island
work with their State Department of Education in identifying
charter schools and advising them about AHERA. Results of
inspections conducted by State personnel in Massachusetts
indicates a pattern of noncompliance. Most of the schools failed
to: appoint a designated person, train the designated person,
provide annual notification, include a signed statement of the
designated person, conduct six-month surveillance, post warning
labels, and provide training to custodial and maintenance staff.
II
The Region has had no contact with any charter schools to date.
But the Region suspects that there are problems. Although
aware of the number of schools in New Jersey, the Region does
not yet know the number of charter schools in New York. The
New Jersey schools were inspected by the State, funded by an
EPA grant. None of the New Jersey schools submitted
management plans. The State will refer these schools to Region
II for enforcement action. Region II personnel will inspect a
small number of New York charter schools and notify the
remainder of the schools that they are subject to AHERA.
IV
The RAC was aware of the number of charter schools in the
Region and has inspected a number of them in Florida and
Georgia. Overall, the charter schools in Region IV are very much
aware of the AHERA requirements, and do not show a pattern of
non-compliance.
V
The RAC was aware of the charter schools in the Region, and over
the last two years, special efforts have been taken to advise
charter schools of AHERA requirements. Region V performed a
general mailing to the State Educational Associations which
represent the charter schools. However, problems still exist; 7 of
the 9 charter schools inspected in Minnesota and Michigan after
the general mailing had no asbestos program, while the programs
of the 2 other schools were deficient.
VI
The RAC was unaware of the number of charter schools within
the Region, but believed that the Region had processed some
enforcement actions in this area. He also believed that charter
schools were unaware of AHERA requirements and deemed their
non-compliance as a problem.
VII
No response received
VIII
No response received
IX
The Region has done little to date regarding charter schools, but
plans on inspecting a number of schools before the end of this
fiscal year.
X
The Region has had little experience with charter schools.
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The number of charter schools is growing at a rapid pace.
Charter schools fall under AHERA, whose enforcement
belongs to EPA and to EPA alone. By and large, most charter
schools are unaware of their responsibilities to inspect for
asbestos. The lack of knowledge occurred in part because
EPA did not inform the schools of this obligation. As a result,
students and employees within these schools may be
unwittingly exposed to asbestos hazards.
Recommendations We recommend that the Assistant Administrator for
Enforcement and Compliance Assurance:
3.1	Notify all charter schools of AHERA mandates. This
could be accomplished by contacting the U.S.
Department of Education and the National Parent and
Teacher Association, which in turn could disseminate
AHERA information over their internet web sites.
Through its own web site, EPA could also disseminate
AHERA information aimed specifically at charter
schools. Another option OECA could consider is to
award grants to provide outreach activities to charter
schools.
3.2	Develop a strategy to ensure that the charter schools
comply with AHERA.
OECA's Response OECA agreed with recommendation 3.1, and advised it is
willing to work with the U.S. Department of Education, State
Education Associations, the National Parent and Teacher
Association and other groups to disseminate AHERA
information, particularly aimed at charter schools. With
respect to recommendation 3.2., due to severe budget
constraints facing EPA's compliance monitoring and
enforcement programs, OECA will not direct the Regions to
invest additional resources in compliance assistance or
monitoring in the AHERA program. During the exit
conference, OECA advised that it will notify the Regions to
include charter schools in the universe of schools inspected.
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OIG's Evaluation OECA's agreement to disseminate information regarding
AHERA requirements is a good step. While we recognize that
the Agency has budget constraints, we believe that OECA
should, at a minimum, advise the Regions to include charter
schools in their current compliance and monitoring strategies.
OECA agreed to do so. In response to this report, OECA
should provide milestone dates for corrective actions planned
or taken. At a future date, we will perform a follow-up review
to determine the adequacy of the corrective actions.
Although the recommendations are addressed to the
Assistant Administrator for Enforcement and Compliance
Assurance, Region III agrees that greater levels of compliance
assurance should take place with regards to the AHERA
program and is already in the process of providing such to
charter schools and non-profit private schools. Region III will
send a letter to each public school district and every charter
and non-profit private school that can be identified to provide
information on how they can comply with the AHERA
requirements, and a strategy to ensure compliance will be
implemented.
OIG's Evaluation We commend Region III for its efforts in notifying charter and
non-profit private schools about AHERA mandates and for
attempting to ensure that these schools comply.
Region Ill's
Response
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CHAPTER 4
EFFECTIVENESS OF INSPECTIONS UNDERSTATED
Region III needs to improve its oversight of the TSCA grants
awarded to Maryland and West Virginia. As mentioned
previously in Chapter 2, State inspectors found violations
and assisted schools to return to compliance with AHERA,
but never reported into the Region's tracking system that
violations occurred. Although providing compliance
assistance may be praiseworthy, the lack of notification on
violations identified understates the value of the inspections.
By not informing the Region of violations, Maryland and
West Virginia have inadvertently misled EPA into believing
that no violations ever existed, when in fact they did.
Lacking any evidence to the contrary, EPA could logically
conclude that it should "disinvest" from funding these
inspections, because the States never report any violations.
The grant agreements with both Maryland and West Virginia
required the States to notify the Region of any violations
found as soon as possible after the inspection, but in all
cases, prior to the end of each quarter in which the inspection
takes place. The grant agreements specified two methods of
notification: (1) completion of forms for the Region's tracking
system; and, (2) submission of inspection reports. Such data
is important because EPA can use it to make decisions such
as where to use resources and where to target areas for
enforcement.
We found that 78 of the 120 inspections conducted by
Maryland during fiscal years 1996 through 1999 detected
violations, the majority of which were for schools failing to:
(1) inspect their buildings for asbestos; (2) maintain asbestos
management plans; or, (3) conduct followup inspections every
three years. However, Region III was unaware that these
violations ever existed.
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A similar review of the 79 inspections conducted by West
Virginia during fiscal year 1999 disclosed that 26 schools had
violations (albeit mostly of a less serious "record keeping"
nature), yet the Region was unaware of these violations.
Further, there were a few instances where West Virginia
took informal enforcement action for serious violations such
as failing to use an accredited person to remove asbestos.
Although West Virginia advised the Region of these informal
actions, the data was not in the tracking system.
The violations identified by both States, particularly
Maryland, are considered crucial to managing asbestos in
schools. The Region should be aware of these violations
because EPA is the only authority that can take formal
enforcement action. Our review shows that the Region has
been unaware of these violations for as long as five years.
Furthermore, Region III staff advised us that some of the
violations it had identified also went unrecorded because,
like the States, the Region also provided compliance
assistance to schools. The lack of knowledge about violations
identified in Maryland and West Virginia, as well as its own
unrecorded violations, places the Region at a disadvantage
and thus a logical candidate for disinvestment from the
AHERA program.
In summary, violation data on the AHERA program is
deceptive. Lacking any evidence to the contrary, EPA
assumes the AHERA programs in Maryland and West
Virginia are experiencing a high compliance rate, when in
fact there are numerous violations. Moreover, Region III has
also understated the violations it discovered. As a result, the
Region's AHERA program inaccurately portrays a zero non-
compliance rate for both States, rather than the actual non-
compliance rates of 65 percent for Maryland and 33 percent
for West Virginia.
We also found that neither State submitted inspection
reports as per instructions received from Region III in 1995.
Regional personnel informed us that they made this decision
because they lacked staff to review and store the reports. In
acknowledgment of resource constraints, we suggested that
the Region delete the inspection report requirement from the
two grants. The Region agreed with this suggestion and
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deleted the inspection report requirement for fiscal year
2000. Instead, it plans to review a sample of inspection
reports twice a year at each State. However, we believe that
the Region must still record all violations detected by any
inspection in its tracking system.
Recommendation 4.1
We recommend that the Region III Administrator
ensure that any violation detected by either the Region
or by the States is recorded in the Region's tracking
system.
Region Ill's
Response
The Region agreed that it needs to have accurate data to
reflect the Region's compliance rates, and has taken
corrective measures to ensure this. The recommendation will
be implemented immediately.
OIG's Evaluation
Region Ill's response meets the intent of our
recommendation. At a future date, we will perform a follow-
up review to determine the adequacy of the corrective action.
No further response to this report is necessary.
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APPENDIX 1
Region Ill's Response to Draft Report
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
1650 Arch Street
Philadelphia, Pennsylvania 19103-2029
July 21, 2000
SUBJECT: Response to Draft Audit Report of Region Ill's Children's
Health Initiative on the Asbestos Hazard Emergency Act
(AHERA)
FROM: Bradley M. Campbell, Regional Administrator/(*
Office of the Regional Administrator (3RA0(W^{ >
TO:	Carl A. Jannetti, Divisional Inspector General for Audit
Office of Inspector General (3AI00)
Thank you for the opportunity to comment on the Draft Audit Report of Region Ill's
Children's Health Initiative on the Asbestos Hazard Emergency Act (AHERA). The objectives of
your audit were to determine the:
1.
status of the Region III Children's Health Initiative on the AHERA inspection
program;
2.	adequacy of EPA's stewardship over the various State inspection programs within
Region III; and
3.	human resources necessary to maintain a viable AHERA inspection program.
The Draft Report makes four recommendations, two which require a Regional response
(Chapter 2 and 4) and two which require a response from the Assistant Administrator for
Enforcement and Compliance Assurance (Chapter 3) since the latter concern your recommendations
for national program direction. In addition to any response at the national level, I will share with
you the Region's plans to notify charter schools in Region III about AHERA mandates and share
the Region's strategy to ensure compliance. Our comments are as follows:
Recommendation 2.1:
The Draft Report recommends that the Region devote the resources necessary to
operate a viable asbestos inspection, outreach and enforcement program.
Regional
Response: The Draft Report accurately states that Region Ill's extramural funds used to fund
Senior Environmental Employees in WCMD's Toxics Enforcement Programs have
decreased from $157,000 in FY 1998 to $57,000 in FY 2000, thereby reducing the
Region's inspection capability in AHERA to merely responding to tips and/or
complaints. However, the Draft Report incorrectly concludes that all of those
Cvlstomer Service Hotline: 1-800-438-2474
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funds are available to the AHERA program. In fact, those funds are compliance
monitoring/toxics funds, which are allocated to be used for a variety of programs: asbestos
(AHERA), PCBs, and Toxics (including EPCRA). Therefore, the amount of money
actually available for AHERA is substantially less than the Draft Report indicates.
Moreover, in light of the finite nature of these funds, if the Region were to increase the total
resources dedicated to the TSCA AHERA program as the report recommends, there would
have to be corresponding decreases in other Region III Enforcement programs.
While we agree that more resources would benefit this important program we are also
cognizant of the fact that all of our "small programs" are clearly directed at protecting
public health and the environment. Both FTE and contract dollars to support Senior
Environmental Employees have been declining in recent years as you note in your report.
It should also be noted that our present aggregate allocation to the AHERA and CAA
Asbestos programs is approximately 3.8 Federal FTE (includes management overhead) and
2.2 SEE employees. These Federal FTE Staffing levels actually slightly exceed our historical
Federal allocations for the two asbestos programs. The real decrease has been in the ability
to maintain our SEE inspector core because of drastically reduced contract
funds. We would also like to point out that WCMD is in the process of requesting
additional inspector resources for this important program from the existing Regional
inspector pool.
Recommendation 3.1
EPA Headquarters should notify all Charter schools of AHERA mandates.
Recommendation 3.2
EPA should develop a strategy to ensure that the Charter schools comply with
AHERA
Regional
Response: While these recommendations are addressed to the Assistant Administrator for
Enforcement and Compliance Assurance who will provide a response for the
national program, the Region agrees that greater levels of compliance assurance
activities should take place with regards to the AHERA program and is already in
the process of providing such. Increased compliance assistance will ensure that
schools, particularly charter or non-profit private schools, are aware of the
regulatory requirements with which they must comply. To this end, WCMD will
send a letter to each public school district and every charter and non-profit private
school that can be identified to provide information on how they can comply with
the AHERA requirements and a strategy to ensure compliance will be implemented
[Schools in the State of Delaware will receive this letter by the end of FY 2000;
schools in all other Region III states will receive a letter in FY 2001], We believe
that this outreach is necessary and will have a positive impact on the compliance
rates at schools. However, it must be understood that fewer inspections and
enforcement actions may result because the overall resource level provided to the
Region by EPA headquarters for AHERA compliance and enforcement has not
increased and could be subject to further disinvestments.
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Recommendation 4.1
The Draft Report recommends that the Region ensure that any violation detected by
either the Region or by the States is recorded in the Region's tracking system.
Regional
Response: The Region agrees that it needs to have accurate data to reflect the Region's
compliance rates. The Region will reinforce this issue with the States of Maryland
and West Virginia (the only two States with whom the Region has grant
agreements) and will reinstate the requirement that these States submit FTTS forms
for each inspection conducted as well as provide additional guidance to the States
on how they should document compliance monitoring and compliance assistance
activities. The Region will also examine the data input process for violations found
by the Region to ensure the violations are properly recorded. This recommendation
will be implemented immediately.
Cc: James J. Burke (3WC00)
James N. Webb (3WC30)
Harry T. Daw (3WC32)
John Bocelli (3PM70)
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APPENDIX 2
OECA's Response to Draft Report
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34
Report No. 2000-P-00024
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# %
i-
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

July 24, 2000
OFFICE OF
ENFORCEMENT AND
COMPLIANCE ASSURANCE
MEMORANDUM
SUBJECT: OECA Response to Draft IG Report on Region Ill's Children's Health Initiative
on the Asbestos Hazard Emergency Response Act (AHERA)
FROM:	Steven A. Herman	,
Assistant Admini^atiq^
TO:	Carl A. Jannetti, Divisional Inspector General for Audit
Mid-Atlantic Division
Thank you for offering the opportunity to review and comment on the Office of the
Inspector General's (OIG) draft audit report regarding EPA Region Ill's Children's Health
Initiative on the Asbestos Hazard Emergency Response Act (AHERA). With only a few
exceptions, OECA agrees with the draft report's findings. The draft report makes two
recommendations for OECA response: to notify all charter schools of AHERA mandates and to
develop a strategy to ensure that the charter schools comply with AHERA.
OECA is willing to work with the U.S. Department of Education, State Education
Associations, the National Parent and Teacher Association and other groups to disseminate
AHERA information, particularly aimed at charter schools. However, given the severe budget
constraints facing EPA's compliance monitoring and enforcement programs, OECA will not
direct the Regions to invest additional resources in compliance assistance or monitoring in the
AHERA program.
The audit, similar to other audits conducted by OIG of EPA's enforcement program, only
looked at an individual program component without accounting for resource limitations or how
enforcement priorities are determined. There is no analysis of the relative importance of this
particular component of our program as compared to other program components or of our
diminishing resources, which limit the value of the report.
Regarding OECA recent evaluation of Small Federal Programs, the Office has identified
national investment areas with critical resource needs and that are areas of high risk,
noncompliance and/or environmental impact: lead based paint; wetlands; and the Oil Pollution
Act and spills. OECA has asked the Regions to shift resources into these important areas in FY
2001. The draft report at page 11 inaccurately states that at the time of the audit, "EPA
Headquarters was suggesting a "disinvestment" from the Agency's asbestos inspection
program." The AHERA program was discussed as a "disinvestment" area, however, Regions
Internet Address (URL) • http://www.epa.gov
Recycled/Recyclable ~ Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 30% Postconsumer)
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have flexibility to strategically choose the amount of resources to be shifted in the investment
areas, as well as to choose "disinvestment" areas, based on the unique circumstances in the
Region. If a Region chooses to "disinvest" in a particular program, the Region is still required to
maintain a core program including activities to determine compliance problems and to develop
strategic approaches to solving those problems.
I agree that there are environmental problems that remain unaddressed in the AHERA
program and that resource constraints are a factor. However, given the already enormous
responsibility and workload shouldered by the compliance and enforcement program here in
OECA and in the Regional offices, I do not believe that the risks attributed to non-compliance
under AHERA outweigh Region Ill's local priorities or our national priorities, such as the risk
posed by petroleum refineries or coal fired power plants.
If you have questions please contact me at (202) 564-2440 or have your staff contact
Seth Heminway at (202) 564-7017.
cc: Michael Alushin, OC/ METD
Jesse Baskerville, ORE/TPED
Eric Schaeffer, ORE
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APPENDIX 3
Distribution
Office of Inspector General
Headquarters Office
Inspector General (2410)
Deputy Assistant Inspector General for Internal Audits (2421)
Divisional Office
Audit Follow-up File (Mid-Atlantic Audit Division)
Divisional Office of Inspectors General
EPA Region III
Regional Administrator (3RA00)
Director, Waste and Chemicals Management Division (3WC00)
Associate Director for Enforcement (3WC30)
Chief, Pesticides/Asbestos Programs and Enforcement Branch (3WC32)
Audit Follow-up Coordinator (3PM70)
Region III Library (3PM50)
EPA Headquarters
Comptroller (2731A)
Agency Follow-up Coordinator (2724A)
Agency Follow-up Official (2710A)
Agency Audit Liaison (2201A)
Assistant Administrator for Enforcement and Compliance Assurance (2201A)
Associate Administrator for Congressional and Intergovernmental Relations
(1301 A)
Associate Administrator for Communications, Education and Media Relations
(1101A)
Director, Office of Regional Operations (1108A)
Director, Office of Children's Health Protection (1107)
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