Document x1onwRezBYDY7yZDeX0Gqkw5G

-v- j/j? ; j^rvofca1 _j*a0 National OPlKacfeA, CSuulittea A91l1l * 1331 Pennsylvania Avenue, N.W. Washington, D.C. 20004 202-737-6330 Organization Resources Counselor^ Inc. May 19, 1988 Memorandum To: From: ORC Occupational Safety and Health Group ORC Western Occupational Safety and Health Group ORC Asbestos Task Force Darrell K. Mattheis Subject: EPA Study of Asbestos Containing Materials In Public Buildings In February of 1988 the U.S. Environmental Protection Agency released a Report to Congress on the problems and risk repre sented by the presence of asbestos in many buildings owned or occupied by the Federal government. This report is the result of requirements of the Asbestos Hazard Emergency Response Act (AHERA) of 1986. The report first discusses the scientific facts and unknowns in its risk assessment section, and then moves on to risk management and finally recommendations. For your interest we have attached a copy of the table of contents, background and report organiza tion. Copies of this report may be obtained from the EPA by calling 202-554-1404 and asking for an information specialist. Give the title of the report as above, and ask for a copy. If you are informed that they do not have copies, insist on receiving one -- this number is for a contractor paid by EPA to supply copies to the requesting public. DKM3:lgs Attachment EPA STUDY OF ASBESTOS-CONTAINING MATERIALS IN PUBLIC BUILDINGS A Report To Congress iunnu Eu!;uu imasi Iiiiu-.tl hm ........i ..! I'-'-'-'f.......................ivi'i'i1 IWIWI liilillij tei'iij liiiiWI liiiiisii |!|I iWlWiHW|SWJWIbawl_____________________IWiVi !]siliiijif ii'iiiisi ............................................................................... . aia| BWlWI k!i!i!;:i liiW!i; UHWI Mm_______bkuwtaiinwmaii!a!!! iiHuwmwiii liHWlliilWl}] IHSM!!<!!!)! iliiiiii ' Lnn awiaiwnawwawitniwiiigiiiiia^ "KWH!______ laawmwiwiwail iiliiijijiiiililiUii: U.S. Environmental Protection Agency Washington, D.C. February, 1988 BPA STUDY OF ASBESTOS-COHTAINING MATERIALS IN PDBLIC BUILDINGS A REPORT TO CONGRESS U.S. Environmental Protection Aqency Washington, D.C. February 1988 TABLE OP CONTENTS I. INTRODUCTION Paqe A. Background.................................................... ................................. l B. Report Organization...................................................... 3 II. RISK ASSESSMENT A. Hazard.................................................................................................4 B. Exposure............................................................................................ 6 C. Risk................................................................................................... 14 III. RISK MANAGEMENT A. Framework for RiskReduction...............................................17 B. Scenarios:Feasibility, Risks and Costs,.....................24 and Policy Considerations IV. RECOMMENDATIONS................................................................................... 36 APPENDIX 1. 1984 EPA Asbestos In Buildings National Survey 2. Summary of Other Major Support Studies 3. Existing Federal Regulations 4. Proportional Risk Assessment 5. Summary Economic Analysis 6. Absolute Risk Sensitivity Analysis ' 7. Possible Studies to Address Informational Deficiencies 8. References I. INTRODUCTION A. BACKGROUND The Asbestos Hazard Emergency Response Act (AHERA) was signed into law on October 22, 1986. AHERA requires the U.S. Environmental Protection Agency (EPA) to establish a comprehensive regulatory framework of inspection, management planning, operations and maintenance (O&M) activities iind appropriate abatement responses to control asbestos-containing materials (ACM) in schools. The AHERA schools rule was signed by the EPA Administrator on October 17, 1987. AHERA also requires that the EPA Administrator conduct a study to determine "... the extent of danger to human health posed by asbestos in public and commercial buildings and the means to respond to any such danger" (AHERA, Section 201(b)(3)). Section 213 of the Act sets forth the requirements for this study: "Within 360 days after the date of the enactment of this title, the Administrator shall conduct and submit to the Congress the results of a study which shall-- (1) assess the extent to which asbestos-containing materials are present in public and commercial buildings; (2) assess the condition of asbestos-containing material in commercial buildings and the likelihood that persons occupying such buildings, including service and maintenance personnel, are, or may be, exposed to asbestos fibers; (3) consider and report on whether public and commercial buildings should be subject to the same inspection and response action requirements that apply to school buildings; (4) assess whether existing Pederal regulations adequately protect the general public, particularly abatement personnel, from exposure to asbestos during renovation and demolition of such buildings; and (5) include recommendations that explicitly address whether there is a need to establish standards for, and regulate asbestos exposure in, public and commercial buildings." This report is EPA's response to that mandate. Public and commercial buildings are defined in AHERA as all buildings other than school buildings or residential apartment buildings of fewer than 10 units. This definition includes all buildings which the "public" may typically occupy or visit-- -1- office and apartment complexes* government facilities, museums, airports, hospitals, stores, and industrial buildings. ` - ' 1" .v* - , The EPA study consisted of a number of activities includinq a review and reanalysis of data previously collected by EPA during its 1984 national survey (OSEPA, 1984a), a review of information on asbestos in buildings available from sources outside EPA, and new data collection efforts initiated*by EPA during 1987. The activities in 1987 included a series of workshops with panelists (building owners, managers and investors, abatement contractors. State and local officials. Federal building managers) involved in asbestos management (Price, Price, 1987) and a study of airborne asbestos levels in Federal buildings (Hatfield et al., 1987). -2- B. REPORT ORGANISATION EPA has tried to make .this report as useful as possible to Congress and to others who want to know more about the nature of the problem of asbestos in public and commercial buildings. The Congressional mandate for this report directed the EPA Administrator to make recommendations based on his assessment of the problem. These recommendations are presented in Section IV of this report. In order to determine what the Agency's recommendations would be, the Administrator was presented with the entire report in its present format, except for the recommendation section. (This form is similar to the "decision memorandum" format which is routinely used inside EPA to arrive at major decisions involving the assessment and management of risk.) The Agency used this information to formulate a recommended course of action, which was incorporated into the last section of the report for submission to Congress. The "decision memorandum" format was retained to allow interested persons to follow the same analytic process used by EPA to reach its recommendations. The report first discusses the scientific facts and uncertainties which help the reader understand the degree to which risk associated with asbestos in public and commercial buildings can be estimated. First, this "risk assessment" section of the report (Section II) addresses the hazards of asbestos in general, then discusses the limited information concerning the possible exposure of people to airborne asbestos in public and commercial buildings. Next, it summarizes the range of possible risk to workers and occupants in these buildings, which results from the combination of the hazard associated with asbestos and possible exposure to it. Because of limited exposure data, the risk assessment should be viewed with caution. Section III of the report addresses the question of "risk management"--that is, how risk could be reduced. Several scenarios for future action to reduce the risk are examined. Attempts are made to characterize how much the risk would be reduced by these actions, and at what costs. Finally, the report presents in Section IV the Agency's recommendations regarding what further actions should be undertaken in the near future. As mentioned earlier. Congress directed that the Agency address five specific issues in this report. Issues 1 and 2 are addressed in Section II (Risk Assessment) of this report, issues 3 and 4 are addressed in Section III (Risk Management). Finally, the recommendations requested under issue 5 are provided in Section IV.