R. Gerber, Gary J. Centifonti, Richard M. Ritota, James A. Brownlee
New Jersey Department of Health
Consumer and Environmental Health Services
R. Kominsky, Ronald W. Freyberg
Environmental Quality Management, Inc.
C. Wilmoth, Bruce A. Hollett
National Risk Management Research Laboratory
U.S. Environmental Protection Agency
Asbestos Hazard Emergency Response Act (AHERA) requires all schools
to develop and implement an asbestos management plan (AMP). The
U.S. Environmental Protection Agency (EPA) has also published guidance
regarding the in-place management of asbestos- containing materials
(ACM). The key component of the AMP is the operations and maintenance
(O&M) program. An O&M program is an administrative framework
that prescribes specific activities and work procedures to control
activities that may disturb ACM and respond to any uncontrolled release
of asbestos fibers. A well-developed O&M program is ineffective
unless it is implemented properly. The O&M program's success
is contingent upon the commitment of all personnel involved in conscientiously
implementing O&M program elements and conducting O&M activities.
New Jersey Department Of Health and Senior Services - Consumer
and Environmental Health Services (NJDOH) and the U.S. Environmental
Protection Agency's National Risk Management Research Laboratory
(EPA-NRMRL) conducted a study to evaluate the implementation of
asbestos O&M programs at ten sites representing eight New Jersey schools.
The evaluation included aspects required by AHERA as well as those
recommended in EPA guidance. Each school's O&M program and compliance
with their program during past O&M activities were documented.
In addition, ten ongoing O&M activities were documented to determine
the impact of the activities on airborne asbestos levels and to determine
compliance with the O&M program during these activities. Airborne
asbestos levels were measured by using transmission electron microscopy
(TEM) before and during each activity. Personal breathing zone
exposures to total fibers were measured by using phase contrast
microscopy (PCM) during each activity for comparison with the Occupational
Safety and Health Administration (OSHA) Permissible Exposure Limit
(PEL) of 0.1 f/cm3, 8-hour time-weighted average.
the schools were not completely implementing all the elements of
the asbestos O&M program as outlined in AHERA or in EPA guidance.
A decrease in performance of program elements was noted going from
the AMP to previous O&M activities, and to the observed O&M
activity. Schools performed more O&M program elements required
by AHERA than those given in EPA guidance. The percentage of performance
responses given by the schools indicating that the elements of
the O&M program were performed (52.5%) was higher than those
provided by the worker or contractor performing the activity (35% & 22.5%
respectively). Elements of the O&M program were not performed
or they were not communicated to the worker or contractor. Significant
increases in area airborne asbestos levels (determined by TEM)
were observed during five of the ten activities. None of the total
fiber levels measured using phase contrast microscopy (PCM), however,
exceeded the OSHA PEL. This study underscores the importance of
a thorough O&M program and the effective communication and
implementation of all program elements.