Environmental Health and Safety Blog | EHSWire

Dale Wilson, CIH, LEED AP, Sr. Project Manager

Summer vacation is what every student dreams of...no school!  While this may be true for the educational calendar, summer is the time of year when schools generally address their big asbestos issues.  So instead of students and teachers filling the classrooms, they are replaced by a range of very specific professionals that are required to get the job done:  the Local Education Agency (LEA), Designated Person, Inspectors, Management Planners, Remediation Contractors, and Asbestos Safety Technicians/Project Monitors.

Regulations for Asbestos in Schools

Asbestos in schools is regulated by the Asbestos Hazard Emergency Response Act (AHERA), promulgated by the US Environmental Protection Agency (EPA) in 1986. AHERA applies to all public and private elementary and secondary schools in the United States and requires LEA’s to identify, evaluate and control Asbestos Containing Building Materials (ACBM).  At each school a “Designated Person” is given the responsibility to be in charge of the school's asbestos control program.  The regulation is meant to protect children, as health issues from asbestos are not immediate, but can take decades to appear. The EPA explains on their website:

“ Although asbestos is hazardous when inhaled, the risk of exposure to airborne fibers is very low. Therefore, removal of asbestos from schools is often not the best course of action. It may even create a dangerous situation when none previously existed. The Environmental Protection Agency (EPA) only requires removal of asbestos to prevent significant public exposure during demolition or renovation. EPA does, however, require an in-place, pro-active asbestos management program for all LEAs in order to ensure ACBM remains in good condition and is undisturbed by students, faculty, and staff.”

Identifying the Problem

The first task of managing asbestos correctly is identifying the location, quantity, and condition of ACBM.  This responsibility is assigned to an AHERA-accredited Building Inspector.  In addition to conducting the initial inspection, Building Inspectors must also re-inspect ACBM every three years. Six- month periodic surveillances are also conducted by a Building Inspector or other individual familiar with the inspection results, such as a member of the custodial staff.  Collectively, the inspections and surveillances help maintain the accuracy of the inventory and identify any damage that requires a response action.

Developing a Plan

The inspection and surveillance results are used by AHERA-accredited Management Planners to develop an Asbestos Management Plan specific to each school.  The Asbestos Management Plan uses the inventory to assess the likelihood of disturbance and recommend appropriate response actions. 

Plan Implementation

Because children are not occupying the school in summer, it is the perfect time to implement response actions that would otherwise disrupt the educational process and present risk. Response Actions include the following activities:

• Removal

• Repair

• Encapsulation

• Enclosure

• Operations & Maintenance (O&M)

Response actions are undertaken by licensed firms who employ AHERA-accredited supervisors and abatement workers.  Many states also require the companies to have a state-issued license for asbestos abatement work and supervisors and workers must carry performance identification permits. In many states, oversight of the work is done by a trained professional such as NJ’s Asbestos Safety Technician (AST)/Project Monitor who works for an independent firm (not the abatement company) to ensure that proper procedures are followed, and performs on-going air sampling and final clearance sampling to document that the response action does not release asbestos particles into the school.  After all, the goal of the response action is to make conditions inside of the school safe!

The AHERA Regulations turned 25 this year. I f you want to find out more about asbestos and the regulations that control its presence in your local schools, visit the EPA website or review this list of FAQ.  Asbestos Management Plans are required to be available to the public, and you can receive a copy from your school district just by asking.

Parents, have you heard about an asbestos removal or management plan in your school district?  To learn more about Asbestos management in schools, the EPA publishes an informative “The ABCs about Asbestos in Schools” If you are part of an asbestos management team, do you have some reassuring information to share with concerned parents?

Dale Wilson, CIH, LEED AP

The US Environmental Protection Agency (EPA) ended 2010 with two announcements that impact Indoor Environmental Quality (IEQ).   The first of these announcements involves polychlorinated biphenyls (PCBs) in school environments. In their press release and guidance document , the EPA is recommending the removal of all PCB-containing fluorescent light ballasts from school buildings.  The focus is on school buildings built prior to 1979 which have not undergone a complete lighting retrofit since that time.  (Note:  In 1979, the EPA banned the use and processing of PCB.)  The EPA makes these recommendations following the detection of elevated PCB concentration in indoor air at several schools where damaged PCB -containing light fixtures were present.  According to the EPA , “PCBs have been demonstrated to cause cancer, as well as a variety of other adverse health effects on the immune system, reproductive system, nervous system, and endocrine system.”

While this announcement is directed at schools, commercial and/or residential buildings with pre-1979 fluorescent light fixtures should also consider following this guidance to prevent exposure to their building occupants.  While replacing such fixtures will improve indoor environmental quality, there is another likely benefit:  energy costs are reduced when replacing these older light fixtures with modern, energy-efficient models.   The costs of installing lighting equipment upgrades may also be offset if there is an active incentive program offered by your state government and/or local utility such as these Clean Energy programs offered by the state of New Jersey.  This type of office or plant upgrade is a quadruple “win” opportunity for companies who qualify: 

• Improve employee work conditions by enhancing their IEQ


• Reduce your operating costs


• Participate in an environmental or “green” program


• And, best of all, have some or all of the equipment paid for by an outside resource!

EPA’s second end-of-2010 announcement recommends testing for radon, as January is National Radon Action Month.   Radon is a naturally-occurring, colorless, odorless gas that can impact your building’s IEQ if mitigation measures are not in place.  Radon exposure is the leading cause of non-smoking lung cancer.  Winter months such as January are the perfect times to test for radon as doors and windows generally remain closed for extended periods of time and heating equipment is in operation potentially creating a pressure differential between the soil and the building’s interior that would promote the migration of radon into the building’s indoor air. 

To find out if your building is located in an area prone to elevated indoor radon concentrations you can view the EPA Radon Map.  Buildings located in Zone 1 counties (red colored) have the greatest potential for elevated radon, followed by Zone 2 (orange) and, finally, Zone 3 in yellow. 

Two easy ways to start 2011 off on the right foot -- follow the EPA’s recommendation by eliminating two significant and relatively easy IEQ concerns, PCBs and radon, from your building.

Have you participated in a state or federal lighting retrofit program? Did the electrical contractor find anything suspicious? How easy was the process? And, have you tested your home or office building for radon? What were the results?