Evaluation of the Implementation of Asbestos Operations and Maintenance Programs in NJ Schools

Donald R. Gerber, Gary J. Centifonti, Richard M. Ritota, James A. Brownlee
   New Jersey Department of Health
   Consumer and Environmental Health Services
 

John R. Kominsky, Ronald W. Freyberg
   Environmental Quality Management, Inc.
 

Roger C. Wilmoth, Bruce A. Hollett
   National Risk Management Research Laboratory
   U.S. Environmental Protection Agency
 

Abstract

The 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.

The 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.

Overall, 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.