I. The Issue:
Asbestos is an inorganic mineral that was routinely used in building construction in the United States until approximately 1980. Common uses included insulation, fire proofing, sound proofing, ceiling and floor tiles, the lining of heating and ventilation ductwork, window glazing, and adhesives. In a solid and undisturbed state, asbestos poses minimal hazards and is very resilient. However, asbestos is a significant respiratory hazard and carcinogen when damaged and transformed into a dry friable (crumbly) material capable of generating small fibers that may be inhaled.
Due to the widespread use of asbestos and the frequent discovery of damaged and friable asbestos containing materials (ACM) in schools, the federal government adopted the Asbestos Hazard Emergency Response Act (AHERA - 40 CFR 763) in 1987. This regulation required that all schools be surveyed for asbestos by a licensed inspector. In addition, each school system was required to label and identify all ACM present in each school and to prepare and implement a routine inspection and maintenance program to ensure the long term monitoring and maintenance of all ACM. The intent of AHERA was to control or eliminate the respiratory hazard posed by damaged asbestos in schools by promoting the prompt discovery and removal or encapsulation of these materials. Also, AHERA required the labeling of all ACM and mandated worker notification for all activities occurring in areas where ACM is present. The federal government hoped that these steps would minimize future disturbances of asbestos as the result of site construction, renovation or utility installation.
The following is a general outline of the basic requirements that each school system must implement in order to comply with AHERA.
1. Arrange for the school to be inspected by a licensed asbestos inspector.
2. Identify the location, type and condition of all ACM present in the school.
3. Establish an asbestos management plan or strategy.
4. Warning labels should be posted in all routine maintenance areas to advise maintenance personnel that ACM is present in the school.
5. Prepare a blueprint or schematic indicating the type and location of all ACM present in the school for reference by maintenance and utility workers, construction workers, and emergency responders.
6. Train and designate someone to supervise the implementation of the asbestos management plan.
7. Train auxiliary staff (usually custodial) to assist with the required self inspection and monitoring portion of the management plan.
8. Notify in writing and retain a copy of the notification of all utility workers and other personnel working in areas where ACM is present.
9. The school department must self inspect the ACM at each school at least once every six months. Any damaged asbestos noted at this time should be remediated or removed upon discovery. The school department is also required to maintain a written record of these activities for further reference.
10. The school department is required to have a licensed asbestos inspector survey each school where ACM is present every three years as a means to review and monitor the self inspection program implemented by the school system.
11. The school department must ensure that all custodial, maintenance, and utility workers who may work in an area where ACM are present have received at least a basic level of asbestos awareness training prior to working in areas that may contain ACM.
12. The school system is required to provide notification to building occupants and users at least once per year that ACM is present in the building. This notification should also provide a brief description of the asbestos maintenance program or where this information is available for review.
13. The school system is also required to retain accurate records which describe all asbestos monitoring, maintenance and abatement activities. This includes all activities involving cleaning, monitoring, repair or abatement.
II. The approach taken:
In response to the adoption of AHERA, the Burlington School Department had all local schools surveyed by a licensed asbestos inspector for ACM in 1988. Various types of asbestos were found to be present in all local schools. In response to this investigation, the School Department sought and obtained additional funding to reportedly remove the asbestos detected in the schools. It is unclear how this proposal was presented and the full extent of the abatement effort that was planned or implied at this time, however the consensus opinion was that all ACM was to be removed at this time. Based on available records, it appears that the School Department discontinued monitoring asbestos in the schools upon completion of this abatement effort.
In May 1995, the Board of Health became actively involved with asbestos management in the schools after the School Department sought assistance in disposing of asbestos waste generated by their staff. An investigation of the origin of this material determined that the untrained custodial staff had removed damaged boiler insulation at two schools and relocated the material to a third school for storage. These activities were conducted without the use of containment, decontamination, or protective equipment. In addition, the ACM was removed in a dry state with hand tools and packed in two cardboard boxes and five plastic trash bags. None of these containers were sealed or labeled to indicate their contents during transport or initial storage. Also, when I first inspected the containers, I noted that the general area around the open containers was visibly contaminated with a fine gray dust presumed to be asbestos. Based on this discovery, I contacted the Massachusetts Department of Environmental Protection (DEP) and Department of Labor and Industry (DLI) for assistance. Since all abatement activities had concluded the sole regulatory question remaining at the state level was the authorization to dispose of the asbestos waste. DEP readily granted the School Department a waiver to dispose of the material and encouraged the staff not to do this again. The Board of Health and DLI acted jointly to order the School Department to have an asbestos abatement firm collect wipe samples at each school to assess the extent of the remaining asbestos contamination and to have each contaminated area decontaminated.
This incident also prompted the Board of Health to review all existing records regarding the assessment and management of ACM within the school system. This investigation determined that contrary to popular belief significant quantities of ACM still existed at all the public schools. Some of these materials were found to be damaged and friable. In addition, no records could be located to indicate if any asbestos management activities or training had occurred at the local schools between 1989 and May 1995. In response, the Board of Health ordered the School Department to have all the public schools inspected by a licensed asbestos inspector and to re-institute the asbestos management plan required by AHERA. The Board of Health now also requires the School Department to submit a copy of all semiannual self inspection reports, asbestos abatement reports, and training records.
III. Observations made:
The most significant observation I have noted to date is the continuing lack of an accurate and complete outline of where all asbestos containing material is present in each school. Even though each public school has been inspected by at least two different state licensed asbestos inspectors, we continue to discover new ACM at the schools. This suggests to me that the inspectors may need additional training to improve the quality of their reviews, and that each school system should realize that these reviews may not locate and identify all ACM present at the school. Furthermore, each school system may also wish to assume a more assertive and proactive approach when monitoring or abating these problems to compensate for this degree of uncertainty.
I have also detected a pervasive belief among the maintenance staff and school administration that the asbestos hazard has been severely exaggerated by the media and governmental agencies. Much of the staff approach asbestos management as more of a bureaucratic paper shuffle than a step toward protecting public health. This attitude and approach has a major impact in how the school system implements and complies with AHERA. This also impacts whether the required worker notifications are made prior to utility work or renovations, or whether contingency planning is conducted prior to initiating renovations. Failure to pre-plan in both cases can easily result in the uncontrolled release of asbestos. I also believe the low level of concern expressed by state personnel during the investigation of improper asbestos abatement activities conducted during the spring of 1995 re-enforced the belief that the asbestos hazard has been overblown.
Another noteworthy observation is that ACM is present in a number of high traffic areas where accidental damage or vandalism could easily occur. I am not talking about floor tiles but instead asbestos pipe insulation. The concrete or grouted joint insulation is usually fairly durable but the paper type insulation is fairly fragile. I have found this type of material on exposed pipe runs located in locker rooms, offices, restrooms and workshops. In one workshop, I found that students and staff had severely damaged the pipe insulation by placing wood and other materials on the pipes to create storage shelves. This modified storage arrangement most likely resulted in the release of some asbestos into this area. A phased removal and replacement of these materials appears to be the wisest approach for eliminating the hazard created by pipe insulation in high traffic areas.
I have noted that even with renewed interest in asbestos management much of the ACM within the local schools has not been identified and labeled as required by AHERA. Due to the amount of computer cable installation and renovation occurring in the schools, there is a major concern that these activities could easily result in the release of asbestos if the workers are uncertain of where the ACM is or what is ACM. This may pose a greater health risk to the individual workers, but it also represents a significant regulatory and civil liability for the school department as well.
A troubling and problematic discovery was the detection of asbestos insulation (transite) on the heating and ventilation ductwork in one school. Our research has determined that in the late 1960's and early 1970's it was common to line underground ductwork with transite to make it more durable. Our discovery was made by a heating and ventilation specialist, and not by an asbestos inspector. I encourage all schools to review their heating and ventilation plans to see if this hazard exists at their school. This can be of critical importance for maintaining indoor air quality. Many schools consider ductwork cleaning to be a first step to maintaining indoor air quality but if you apply abrasive chemicals, a wire brush or vacuum system to a transite lined ductwork then you may be releasing asbestos fibers into the school, and as a result, your efforts will result in a significant degradation of indoor air quality. I encourage you to have both a heating and ventilation specialist and an asbestos inspector review this issue for your school system.
Finally, I have also noted a number of areas in the local schools where ACM may be routinely exposed to water damage. This causes concern because the repetitive exposure of ACM to water increases its rate of degradation and increases the likelihood of a release. The following types of ACM are susceptible to water damage: acoustical tiles, ceiling tiles, pipe insulation, certain types of fire proofing and insulation, boiler insulation and joint insulation. I recommend that you a)identify where your ACM is present, b) determine if water damage is present or likely, c) take steps to control or prevent water damage, and d) if water damage cannot be prevented or the damage is beyond repair - remove the ACM.
IV. Problems or concerns noted:
- The variable quality and diligence of the in-house asbestos monitoring program.
- The continued discovery of additional ACM at local schools increases the level of uncertainty associated with asbestos management while also decreasing the likelihood that we have identified all potential risks.
- Several persistent roof leaks in local schools may result in damage to nearby ACM.
- The common belief that most or all ACM has been totally removed from the schools has hampered the efforts to reinvigorate asbestos management at the schools.
- The haphazard notification that ACM is present in the schools increases the possibility that ACM could be damaged and released during utility installation or site renovation.
V. Actions taken:
A. Re-inspected all local schools.
In 1995, all local schools were re-inspected by a state licensed asbestos inspector. The purpose of this inspection was to identify the type, location and condition of all ACM present in each school. As required by AHERA, this step will be repeated in 1998.
B. Prepared a schematic for each school which outlines the type and location of ACM present in the building.
A blueprint has been prepared for each local school which outlines the location and type of all ACM known to exist within the building. It is the responsibility of the School Facilities Maintenance Director, as the plan manager, to use this document to notify all workers prior to allowing them to work in an area where ACM is present. The Maintenance Director is also responsible for updating the schematic as more ACM is discovered or removed.
C. The school department has designated the Facilities Director to manage the plan.
The School Department Director of Facilities Maintenance has been designated the individual responsible for supervising the implementation of the local AHERA plan. In this capacity, he is responsible for directing all local asbestos management activities at the local schools as required by AHERA. In order to fulfill the responsibilities of this role, this individual has been required to complete the the 16 hour asbestos management training specified by AHERA.
D. Additional staff training.
All members of the custodial staff have completed at least two hours of asbestos awareness training to enable the staff to identify ACM and to inform them of pertinent asbestos management protocols. The roll of these staff members is to simply report the discovery of new ACM or a change in existing ACM to the coordinator. In addition, two members of the custodial staff have also completed additional asbestos training to enable these staff members to conduct small asbestos abatement or repair activities involving less than 3 linear feet of material. All repair and abatement activities must be supervised by the Director of Facilities Maintenance and conducted in accordance with all applicable state and federal safety standards. All larger abatement or repair activities must be completed by a state licensed asbestos abatement firm.
E. The asbestos management plan required by AHERA has been re-instituted.
Efforts have been implemented to reinvigorate the local asbestos management plan. As a result, staff training has occurred, self monitoring and inspection is now taking place, and some notification is being provided.
The following is a summary of significant lessons I noted during my investigation of asbestos management at the Burlington public school system.
1. Identify common types of ACM used in your area and make sure your school was surveyed for all of these materials. This approach will enhance your ability to accurately locate and identify all ACM present at your school.
2. Review all inspection reports and abatement records to verify what ACM remains. There is no substitute to verification when attempting to determine what ACM exists at your schools. All inspection and abatement reports should be carefully reviewed and compared to the building schematic.
3. Learn about the types of ACM and attempt to quantify hazards. Developing a better understanding about the uses, types, and durability of ACM will improve your ability to manage the ACM present at your school. This basic knowledge will enhance your ability to estimate the maintenance issues or hazards associated with various types of ACM. You should be able to begin to recognize some of the differences associated with the different types of ACM (e.g. asbestos pipe insulation - fragile, potentially friable asbestos with a higher risk of release when damaged versus floor tiles - durable, non-friable asbestos with a lower risk of release).
Tips and suggestions:
1. Seek assistance from local community. Tap the knowledge and expertise of the local community. They have a vested interest as parents and taxpayers. This interest may also bring more dedicated assistance. Also, this assistance is usually free. Also, local builders and contractors frequently have a detailed knowledge of past and current building and maintenance practices which may not be well documented in existing schematics or construction records. It was a local volunteer who informed us of the use of transite asbestos in the construction of heating and ventilation ductwork after numerous consultants had reviewed the same material.
2. Use a phased approach based on risk of release, location, and to a certain extent on cost to plan abatement activities. Due to the widespread use of ACM, it is usually not economically feasible to remove all ACM from a school. In addition, abatement activities may create more of a hazard than would normally exist if the ACM were simply protected and maintained in good condition as is the case for ceramic floor tiles. Therefore, a balanced approach based on the hazard posed by the ACM, its location, and to a lesser extent the cost of abatement should be used when planning asbestos repair or removal activities.
During this investigation, I utilized the resources available via the U.S. Environmental Protection Agency and the Massachusetts Departments of Environmental Protection, Health , Labor and Industries. I also reviewed guidance information prepared by the U.S. Department of Labor Occupational Safety and Health Administration. Due to regional differences with regard to the management and handling of asbestos and asbestos waste, I recommend that you consult with your state environmental, health, and occupational hygiene offices, and the regional EPA and OSHA offices prior to initiating asbestos abatement and management activities.
prepared by Todd H. Dresser, Environmental Engineer
Burlington Board of Health, 29 Center Street, Burlington, MA 01803