The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
1
of
3
Proposed
Priority:
Asbestos
Hazard
Emergency
Response
Act/
Asbestos
in
Schools
Many
schools
contain
asbestos,
which
if
disturbed
or
damaged,
can
release
fibers
into
the
environment
which
may
cause
severe
health
problems
15­
30
years
after
exposure.
As
renovation,
regular
or
special
maintenance
occurs
at
schools,
the
disturbance
activity
can
release
asbestos
fibers
into
the
school's
indoor
environment.
Without
adequate
safeguards
in
place,
friable
asbestos
fibers
can
circulate
through
the
school's
heating,
ventilation
and
air
conditioning
(
HVAC)
system
­
causing
severe
respiratory
illness
and
cancer.

In
1986,
the
Asbestos
Hazard
Emergency
Response
Act
[
AHERA;
Asbestos
Containing
Materials
in
Schools,
40
Code
of
Federal
Regulations
(
CFR)
Part
763,
Subpart
E]
was
signed
into
law.
The
law
requires
the
local
education
agency,
usually
the
local
school
district
or
non­
profit
private
school,
to
designate
and
train
a
person
to
oversee
asbestos­
related
activities
in
the
school
system,
inspect
every
school
building
for
friable
and
non­
friable
asbestos,
prepare
a
management
plan
that
outlines
where
and
how
asbestos
is
to
be
managed
in
each
school,
consult
with
accredited
professionals
to
identify
and
carry
out
appropriate
asbestos
control
measures,
notify
the
public
about
the
management
plan
and
their
opportunity
to
inspect
the
plan,
and
keep
records
of
all
asbestos
activities.
Many
schools
are
unaware
of
these
regulatory
requirements.

Some
examples
of
asbestos­
containing
materials
found
in
schools:

Taping
Compounds
(
thermal)
Laboratory
Hoods/
Table
Tops
Electric
Wiring
Insulation
Cement
Wallboard
Laboratory
Gloves
HVAC
Duct
Insulation
Heating
and
Electrical
Ducts
Acoustical
Plaster
Boiler
Insulation
Asphalt
Floor
Tile
Decorative
Plaster
Caulking/
Putties
Vinyl
Floor
Tile
Joint/
Spackling
Compounds
Textured
Paints
&
Coatings
Vinyl
Sheet
Flooring
Fire
Doors
Electrical
Panel
Partitions
Wallboard
Chalkboards
Spray­
Applied
Insulation
Ceiling
Tiles
&
Lay­
in
Panels
Vinyl
Wall
Coverings
Blown­
in
Insulation
Adhesives
Pipe
Insulation
(
corrugated
air­
cell,
block,
etc.)

Universe
and
Types
of
Facilities:
The
number
and
type
of
schools
operating
in
the
United
States
potentially
subject
to
the
Toxic
Substance
Control
Act
(
TSCA)
AHERA
program:

Table
1:
Type
and
Total
Number
of
Schools
in
United
States
Table
2:
Pupil
Enrollment
Totals
by
Type
of
School
PUBLIC
SCHOOLS
91,06
2
PUBLIC
SCHOOLS
46,534,687
PRIVATE
SCHOOLS
27,40
2
PRIVATE
SCHOOLS
5,076,120
The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
2
of
3
CATHOLIC
SCHOOLS
8,144
CATHOLIC
SCHOOLS
2,500,416
CHARTER
SCHOOLS
2,357
CHARTER
SCHOOL
579,880
Table
3:
Number
of
Teachers
by
Type
of
School
PUBLIC
SCHOOLS
2,887,000
PRIVATE
SCHOOLS
397,000
CATHOLIC
SCHOOLS
144,642
CHARTER
SCHOOLS
36,019
Geographic
Range
Nationwide.

Key
Pollutants
and
Risk
Factors
Asbestos
is
a
generic
name
given
to
six
minerals
that
contain
separable,
long,
and
thin
fibers.
These
processed
fibers
are
quite
small
(
1,200x
smaller
than
a
human
hair)
and
light
weight.
When
released
from
asbestos­
containing
material,
the
fibers
have
the
ability
to
remain
aloft
for
many
hours,
increasing
the
chance
that
someone
will
inhale
the
fibers.
The
properties
of
asbestos
fibers
make
it
a
versatile
and
cost­
effective
material.
It
is
used
where
high
tensile
strength
is
required,
has
chemical
and
thermal
stability,
high
flexibility,
and
low
electrical
conductivity.

Asbestos
fibers
can
cause
serious
health
problems.
If
inhaled,
they
can
disrupt
the
normal
functioning
of
the
lungs.
Three
specific
diseases
­
asbestosis,
lung
cancer
and
mesothelioma
have
been
linked
to
asbestos
exposure.
The
danger
is
not
knowing
what
level
of
exposure
to
asbestos
fibers
will
cause
these
diseases
to
occur
years
later.
The
best
protection
is
to
minimize
human
exposure
to
asbestos
fibers,
thereby
reducing
the
risk
of
future
adverse
health
effects.
EPA
has
concluded
that
there
is
no
safe
level
of
exposure
to
asbestos
fibers.

Noncompliance
Information
Compliance
and
enforcement
activities
undertaken
by
EPA
and
the
States
in
the
early
1990s
have
given
way
to
various
stages
of
non­
compliance
today.
These
stages
of
noncompliance
can
be
attributable
to
the
minimal
compliance
and
enforcement
presence
in
the
school
community
these
past
several
years
and
the
failure
of
school
management
to
maintain
the
Designated
Person
position.
One
school
group
of
special
concern
is
charter
schools.
Beginning
in
the
early
1990s
charter
schools
have
become
an
education
alternative
to
regular
public
schools.
Many
charter
schools
operate
from
previous
used
school
buildings,
office
buildings
or
any
other
building
available
at
low
or
no
cost
to
the
charter
school.
These
buildings
often
contain
environmental
hazards,
such
as
asbestos.
Many
of
these
charter
schools
were
started
long
after
EPA's
original
The
background
papers
on
the
candidate
national
program
priorities
are
intended
to
initiate
further
discussion.
When
priorities
are
selected
more
detailed
strategies
with
in­
depth
background
information,
numerical
targets,
schedules,
milestones
and
performance
measures
will
be
developed.
______________________________________________________________________________

December,
2003
Page
3
of
3
compliance
assessment
and
enforcement
were
reduced.

As
an
example
of
charter
school
noncompliance,
EPA
Region
V
developed
a
two­
prong
compliance
strategy
for
charter
schools
within
their
Region.
In
2001,
the
Region
sent
letters
to
359
charter
schools
operating
in
the
Region
alerting
the
school
administrators
of
their
responsibility
to
comply
with
the
AHERA
program.
Additional
information
was
sent
to
several
state
charter
associations
as
well
as
state
education
departments
as
a
means
of
reaching
the
charter
school
audience.
With
each
contact,
regional
staff
offered
to
make
a
presentation
at
any
meeting
that
would
reach
charter
school
officials.
In
mid­
2002,
the
region
moved
on
to
phase
two,
compliance
monitoring
and
assessment.
Nine
charter
schools
were
evaluated
and
all
nine
were
in
noncompliance.
The
violations
ranged
from
failure
to
have
a
management
plan,
identify
a
Designated
Person,
monitoring
and
training.

In
October
2003,
Region
2
filed
a
complaint
with
Puerto
Rico
education
officials
for
violations
of
AHERA.
The
Region
conducted
inspections
at
five
schools.
At
each
school,
EPA
determined
that
there
was
a
release
of
fibers
from
already
damaged
asbestos­
containing
materials,
asbestoscontaining
materials
made
friable
by
inadequately
trained
personnel,
or
removed
asbestos
for
which
documentation
could
not
verify
the
asbestos
was
properly
removed.
In
addition,
Region
2
and
Puerto
Rico
Dept.
of
Education
staff
did
an
additional
170
follow­
up
inspections
and
spotchecks
During
these
inspections
it
was
revealed
that
required
inspection,
training
and
awareness
programs
were
not
being
implemented.

The
Inspector
General
has
reviewed
the
AHERA
program
in
Region
III
(
2000)
and
Region
IV
(
2002)
and
reported
that
current
resources
are
inadequate
to
perform
a
reasonable
number
of
compliance
inspections
to
determine
whether
school
districts
are
complying
with
the
AHERA
regulations.
