EPA Asbestos Management: The Approach

Read about the EPA Region 7’s analysis of approaching Asbestos Management for the Kansas, Missour, Nebraska and Tribal Regions.

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.

Courtesy of U.S. Environmental Protection Agency