are not the same as exposure levels in schools, then risk should
be calculated from first principles using the lifetable approach
and incorporating the change of exposure level at age 18.
However, for the purposes of this analysis, an estimate relying
on the approximate additivity of risk is adequate.

The approximation is introduced by assuming that the new total
risk (due to exposure in schools plus exposure in public and
commercial buildings) will be this number plus the portion of the
old total risk (i.e., total risk when exposure levels are the
same) contributed by schools.

Proportional risk, for purposes of illustrating the
sensitivity of the model, is calculated for several arbitrarily
selected airborne asbestos levels for public and commercial
buildings: twice, the same, one half, one sixth and one tenth of
those in schools. It is not possible to determine with any
certainty which, if any, of these scenarios is most
appropriate. The levels are provided merely to indicate the
relative contributions to total risk of exposure in public and
commercial buildings and in schools, as computed by the model.

EXAMPLE

Consider an individual who spends 13 years from age 5 to age
18 in school buildings containing asbestos followed by 10 years
of exposure in asbestos-containing public and commercial
buildings. If airborne asbestos levels are the same in schools
and in public and commercial buildings, the exposure experience
is 23 years starting at age 5. The total mesothelioma risk (117)
can be read directly from Table 1. (Note that the absolute risk
value has no significance here; only relative values are of
interest. The numbers are based on an exposure level of 0.01
f/cc to maximize accuracy, since in the Health Assessment Update,
these values have the highest number of significant digits. If
another exposure level were chosen, the results would be the
same.)

Now consider an individual who is not exposed at school, but
who is exposed for 10 years in public and commercial buildings
beginning at age 18. The mesothelioma risk read from Table 1 is
36. Expressing this risk as a percentage of the total risk
(36/117 = 31%) provides a measure of the contribution of exposure
in public and commercial buildings.

For scenarios in which exposure levels in public and
commercial buildings are not the same as those in schools, a new
total risk must be calculated by separating the original total
risk of 117 into its two components, and modifying the public and
commercial building component. For example, if exposure levels
in public and commercial buildings were one half those in
schools, the new total risk would be approximately 99 (81 from
schools plus 36/2 from public and commercial buildings). The

4-3


Policy Considerations

Targeted technical assistance would allow the EPA to help
shape and guide the activities of the private sector by improving
key private sector and State capabilities. This scenario would
not impose regulation, which might be burdensome, and, given
current knowledge of exposure and risk, premature. As EPA
provides better information on exposure and risks (and their
uncertainties), private sector judgments should result in more
appropriate risk management decisions. In addition, States may
continue regulatory programs at levels they deem appropriate
under this option.

As the AHERA schools rule program advances, it should
provide a better context for assessing the real impacts of future
regulatory steps, if these are deemed necessary, for public and
commercial buildings. AHERA accreditation in the States should
also increase the availability of trained experts to improve the
prospects for risk reduction in public and commercial
buildings. In addition, voluntary standards could be
established, which would benefit contractors, building investors
and lenders, and worker groups, without imposing Federal
regulations on building owners and managers.

On the other hand, this option would leave decisions
regarding whether and how to address the asbestos problem in
buildings to unknown market forces, private initiative, and State
and local regulation which may not result in consistent risk
reduction.

2. FEDERAL BUILDINGS AS A MANAGEMENT MODEL

This scenario would establish Federal buildings as a model
management program that could be used voluntarily in other public
and commercial buildings. It could also provide a laboratory to
test policies, programs and schedules for their appropriateness
and to improve EPA's information on exposure and risk in
buildings. The program could consist of one or more of the
following activities: inspection, management plannina,
operations and maintenance (O&M) programs, and identifying,
selecting, implementing, and completing appropriate response
actions in Federal buildings.

A variety of analytical and evaluative activities could be
instituted as part of the model program. Relocation and
reoccupancy practices could be tested, as well as occupant
awareness and notification policies. Additional research might
be conducted on the effect of abatement activities on exposure,
particularly in highrise buildings or near occupied space.
Alternative hazard assessment schemes and emerging technologies
for hazard abatement and respiratory protection could be
evaluated. Results would be available to the public and guidance
developed and distributed as appropriate for voluntary public and
commercial building use. The Federal buildings program could

-27-


Il.

Ill.

Iv.

TABLE OF CONTENTS

Page

INTRODUCTION

A. BACKGLOUNG. cece cece cece rece eee r nese eect eeeeeeed
B. Report OrganiZatiOn.... sees cece ec ce cece eee reee ed
RISK ASSESSMENT

yn = Co -2-0 6 a ee
B.  EXPOSULC. . cece ce eee eet eee eee eee were eee nee
Cr RUSK cee eee eee cee ee ee cence eee eee eee ence rene el

RISK MANAGEMENT

A.

B.

Framework for Risk Reduction.......eee eee eee eee lT

Scenarios: Feasibility, Risks and Costs,.......24
and Policy Considerations

RECOMMENDATIONS... 1... eee ccc ce eee eee eee eee eee ne 0 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

References


The number of project areas per model building is dependent
on the total quantity of ACM, the type of ACM, and the location
and configuration of ACM in a building. Average amounts of
asbestos-containing surfacing materials (SM) per model building
were calculated by dividing the total amount of SM in each
building class by the number of buildings in the class. The AIBS
provided estimates of the surfacing ACM found in each building
class. The estimated TSI amount per building was, as noted
above, derived from the matched model schools. Once average ACFM
amounts per building were established, a range of model projects
was used to develop a building project mix that best approximated
each model building's ACFM amount. The model projects are shown
in Figure Three.

Figure Three
Model Buildings and Their ACM Projects

Type of Model # of Project Project
Building Projects Description Sq. Feet

Surfacing Materials:

Federal 8 3 4,000 sra/ spray-on

5 400 SF spray-on 14,000
Residential 3 2 4,000 SF spray-on

1 400 SF spray-on 8,400
Commercial 3 1 4000 SF spray~on

2 400 SF spray-on 4,800
Thermal Systems Insulation:
Federal 4 1 900 SF boiler wrap

3 100 LF pipe wrap b/ 1,254
Residential 4 4 100 LF pipe wrap b/ 472
Commercial 4 4 100 LF pipe wrap b/ 472

al Square feet.
b/ 100 LF (linear feet) pipe wrap = about 118 SF pipe wrap.


Pigure Eight

Costs for Inspections, Management Plans and O&M Programs

All Bldqs.
Hospitals Fed Res Comm Total
Bldg w/ ACFM
* Sinsp/Bldg $1,592 $1,959 $1,297 $1,239
$Mngmt Plan/Dev $1,200 $1,350 $1,080 $1,080
$OaM/Yr. 1 $12,537 $13,191 $11,650 $11,228
S$O&M, each yr $4,186 $4,612 $3,792 $3,333
$Mngmt Plan Imp. $2,900 $2,083 $1,714 $1,714
$Per. Surv. $45 $45 $45 $45
$Reinsp. $80 $80 $48 $48
#Bldg. 9,675 14,000 208,000 511,000 733,000
**Subtotal $463 $1,359 $11,015 $24,550 $35,255
Bldg w/ NFACM
* Sinsp/Bldg $540 $583 $359 $359
$Mngmt Plan/Dev $640 $720 $540 $540
SosM/Yr. 1 $0 $0 $0 $0
$Mngmt Plan Imp. $1,525 $1,649 $1,408 $1,408
$Per. Surv. $45 $45 $45 $45
$Reinsp. $80 $80 $48 $48
#Bldg. 25,816 14,802 98,804 1,363,023 1,476,629
**Subtotal $222 $132 $755 $11,763 $12,650
Bldg w/ no ACM
**Insp Subtotal $4.6 $1.4 $5.8 $181.8 $189.0
**Total $689.8 $1,492 $11,776 $36,495 $49,763

* Includes Inspection and Notification

** In Millions


III. RISK MANAGEMENT
A. FRAMEWORK FOR RISK REDUCTION

EPA has identified and analyzed a variety of major scenarios
across the spectrum of possible private and public response to
asbestos risks in public and commercial buildings. These
scenarios range from supporting current private, State and local
action to enacting a full regulatory control program, similar to
the Asbestos-Containing Materials in Schools Rule ("schools
rule") promulgated on October 17, 1987, under AHERA. They are
listed and examined in greater detail in Section B, generally in
order of increasing Federal government intervention. To discuss
these scenarios meaningfully it is necessary to identify common
assumptions, including a baseline against which any additional
risk reduction can be judged.

1. IDENTIFICATION OF A BASELINE

For purposes of this report, the baseline will be defined as
the composite of all actions or programs, voluntary or mandated
by law, that are currently underway, with the abatement of risk
from exposure to asbestos as their objective. Actions that are
taken as a result of current market forces, or by individuals in
the private sector, are already addressing risk from asbestos
exposures in public and commercial buildings, in conjunction with
existing State and local government activities. However, the
extent and effect of this activity on actual risk is not clear.
Private sector actions have increased asbestos control and
abatement in public and commercial buildings in the last several
years, motivated in part by public perceptions of hazard,
liability, tenant pressures, lenders’ concerns about property
value, and Federal and State regulation, technical assistance and
guidance.

State and local supervision and control programs have
expanded rapidly in recent years. At least 39 States now have
some type of abatement contractor certification program -- an
increase from only five in early 1985. Some State and local
governments, Rhode Island and New York City, for example, have
comprehensive asbestos management regulations; others are now
considering regulatory steps beyond certification and training
programs.

Several Federal asbestos regulatory programs presently
exist. (Summaries of existing Federal regulations are provided
in Appendix 3.) Two Occupational Safety and Health
Administration (OSHA) asbestos standards address protection for
manufacturing, abatement and service workers and other private
sector employees, while EPA's worker protection rule affords
essentially the same protections to abatement workers in the
public sector where OSHA standards do not apply. Asbestos
emissions during building demolition or renovation and the
transport and disposal of asbestos waste are regulated under

-17-


EPA received between $100,000 and $200,000 at its inception. The
total cost for this approach was not estimated because the
required number of courses, training centers, and training
programs is unknown.

D. Cost Estimation For Requlatory Scenarios

This section presents the steps followed in estimating the
costs of regulatory risk management scenarios. The economic
analysis addressed a series of successively more comprehensive
regulatory environments involving greater levels of response to
the risk posed by ACM in buildings. This approach provides a set
of cost estimates that can be combined to illustrate the likely
total cost of any of a variety of regulatory approaches. The
first section to follow describes the general cost estimating
scheme. The next six sections present the estimated costs of the
six regulatory risk management scenarios discussed in the report.

1. General Cost Estimating Scheme

The economic analysis was structured in such a way that the
costs associated with performing different types of asbestos
activities could be estimated for each of the three building
types (Federal, residential, commercial) identified in the
AIBS. The analysis developed costs sequentially using an
activity scheme identical to that identified in section 203 of
the Asbestos Hazard Emergency Response Act. That is, the
analysis estimated costs for: (1) inspections; (2) inspections
and the development of management plans; (3) the preceding item
plus operations and maintenance (O&M); and (4) item (3) plus a
range of appropriate abatement actions.

Costs for the first activity, building inspections and
notifications, were estimated via the following steps. First,
the count of 733,000 public buildings with friable ACM was
obtained from the AIBS. The initial estimate of buildings with
nonfriable ACM derived from AIBS data was then adjusted. EPA's
technical asbestos consultants provided the analysts with their
latest estimate of the proportion of all public buildings that
contained nonfriable ACM (NFACM). Applying this proportion to
the AIBS data resulted in an estimate of just under 1.5 million
buildings with NFACM.


EPA's cost analysis for this scenario indicates that an
AHERA-type regulatory program for one public and commercial
building category, hospitals, would cost an estimated $674
million. (Costs for hospitals are provided purely for
illustrative purposes.)

Policy Considerations

The sequential approach, much like the selective approach,
would allow EPA to focus and scale its regulatory activity to a
more manageable level than would be the case under an immediate,
comprehensive AHERA-type rule. Under this scenario FPA would
extend standards to reduce exposure first in the buildings with
greatest exposure and risk, as determined by research studies.

On the other hand, EPA currently lacks information on key
building selection, ranking and scheduling criteria, including
exposure and risk, which would be necessary for the Agency to
properly identify categories of public and commercial buildings
for regulation.

6. IMMEDIATE, COMPREHENSIVE AHERA-TYPE REGULATION

This scenario would have EPA promulgate a full regulatory
standard for all public and commercial buildings with major
components similar to those of the AHERA schools rule.

The rule would include standards for building owner
responsibilities, inspection and reinspection, sampling and
analysis, hazard assessment, response actions, operations and
maintenance, training and periodic surveillance, management
planning, recordkeeping, warning labels, compliance and
enforcement activities, waivers and exclusions, and use of
accredited personnel.

It would allow building owners to select, within an
acceptable range of alternatives, appropriate response actions to
address particular asbestos hazards. Least burdensome methods of
response could be selected by the building owner among those
actions which adequately protect human health and the
environment.

The regulation would be applied to the full range of public
and commercial buildings, which are considerably more diverse
than schools and outnumber schools by approximately 20 times.

Similar regulatory standards for schools were recently
developed, primarily through the AHERA schools rule regulatory
negotiation, but the appropriateness of these standards in a
public and commercial buildings context cannot be very well
assessed due to a lack of exposure and risk data on these
buildings.

~34-


The results of Studies 2 and 3 would serve in part as the basis
for guidance to building owners on the efficacy and

implementation of O&M programs and the need for continued O&M
after removal.

APPROACH:

Phase 1: Forty buildings would be selected for air
monitoring before and after removal actions.
Special cleaning procedures (wet mopping, HEPA
vacuuming, etc.) would be implemented in half the
buildings. Normal cleaning procedures would be
followed in the remaining half. Airborne asbestos
levels will be measured 3, 6 and 12 months after
removal. Standard asbestos sampling and analysis
methods would be employed.

Phase 2: A second set of buildings would be selected for
air monitoring before and during the
implementation of a special O&M program over an
extended period of time.

COST ESTIMATE:
Phase l: $8,000,000
Phase 2; $8,000,000
TIME ESTIMATE: 2-3 years

LIMITATIONS/DISADVANTAGES: This study does not directly
determine whether or not there are significant asbestos levels
without removal and O&M, but rather looks at potential for
reducing levels in certain buildings.

STUDY 4a: PROBLEM CHARACTERIZATION STUDY 1: "PEAK" EXPOSURE
LEVELS

STUDY OBJECTIVE: To characterize "peak" asbestos fiber releases
from specific disturbances of ACM.

RATIONALE: The Agency has long been concerned about building
occupants and service workers receiving "peak" exposures to
airborne asbestos fibers during incidents that disturb the ACM.
Many of these disturbances occur in the course of routine
maintenance and repair activities. There are virtually no data
on “peak" exposures. These incidents occur as a result of
routine maintenance and repair activities as well as through
vandalism and inadvertent damage to the material (e.g., a leaking
roof). This study would provide the Agency with estimates of
"peak" exposures and will provide the Agency with information to
consider in regulatory decisions about the utility of special
operations and maintenance programs for preventing "peak"
exposures.


5

little is actually known, as this report indicates. Some of these
studies could cost many millions of dollars to conduct on a
scientifically credible basis. Yet their impact on future
abatement programs which carry cost estimates in the tens of
billions of dollars could be profound. Perhaps a cooperative
effort between industry and the government for these studies
should be explored with principal funding by the private sector.

I could envision the actual studies being conducted by a third

party.

In conclusion, asbestos in commercial buildings, like
asbestos in schools, represents a potential health hazard that
deserves careful attention. However, we need to continue to
Place our primary focus on asbestos in schools. This report
highlights the wisdom of this priority attention. Children,
since they have the longest life expectancy would appear to incur
the greatest risk, particularly to contracting mesothelioma.
Children also spend a great deal of time in school where any
asbestos is especially susceptible to disturbance by the
occupants. We have only recently put in place the comprehensive
AHERA school regulations which call for inspections and the
development of management plans by October 1988. The
implementation of these plans must begin no later than July 1989.
The successful implementation of this school program should remain
our first concern, and we all have much to learn from it. In
addition, until the necessary national infrastructure to manage
asbestos problems on a much larger scale exists, I fear a major
initiative in other buildings could do more harm than good.

It has taken a great effort over six years to put the school
asbestos program in place. We should be very careful not to take
steps which undermine its completion. During the next several
years, AHERA school rule activities will stretch the resources of
this country, in terms of trained and accredited inspectors,
planners, removal contractors, and laboratories, as well as
compliance assistance and enforcement capabilities among Federal,
State, tribal and local governments. Although we expect the
supply of accredited professionals and laboratories to expand in
response to the demand for increased services, any significant
additional demand imposed by new and immediate regulation could
pose a serious obstacle to the success of the schools program.

This should not be interpreted as ruling out an inspection
rule or even greater Federal regulation of these public and
commercial buildings at some later time. This is a question we
should address in about three years after we have had more
experience with the AHERA school rule, have dealt with the large
surge of demand for trained professionals, and have completed the
important studies I have outlined above.


APPENDIX 5

SUMMARY ECONOMIC ANALYSIS

I. Introduction

This appendix contains a description of the economic analysis
conducted to estimate the costs of the various scenarios
considered with regard to the inspection for and abatement of
asbestos in public buildings. The cost estimates for a
particular scenario focus not only on the absolute magnitude of
those costs, but also on what group incurs those costs and how
those costs are distributed over time. Costs attributable to a
particular scenario are incremental from a baseline which assumes
that no abatement is currently taking place.

II. Methodology
A. Preliminary Steps

In most respects, the costs estimated for the scenarios
discussed below were developed with the same set of assumptions,
unit costs, and calculations used for the final AHERA schools
rule's Regulatory Impact Analysis (RIA).

Information on the three classes of public buildings
(Federal, residential, and commercial) was gathered from the
EPA's 1984 Asbestos In Buildings Study (AIBS). This information,
plus information gathered from the EPA's Regional Asbestos
Coordinators (RACS), was used to construct a "model" building
representing each building type. These models were developed in
the same manner as those developed for the schools rule RIA. The
models are not intended to describe any one specific building but
are rather intended to represent the similarities in the building
classes. The models established for this analysis were a Federal
building of 42,000 square feet, a residential building of
27,601 square feet, and a commercial building of 24,094 square
feet. An additional model for hospitals was 37,328 square feet.


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON DC = 20460

FEB 26 1988

THE ADMINISTRATOR

Honorable George Bush
President of the Senate
Washington, DC 26510

Honorable James C. Wright Jr.
Speaker of the House

of Representatives
Washington, DC 29515

Dear Mr. President and Mr. Speaker:

On October 22, 1986 the Congress passed the Asbestos Hazard
Emergency Response Act (AHERA) which required this Agency to
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." This letter transmits
that report and contains my recommendations.

The Congressional mandate for this report focused our
attention on two major lines of inquiry:

(1) The extent and condition of asbestos in public and
commercial buildings; and

(2) Whether public and commercial buildings should be
subject to the same inspection and response action
requirements that apply to school buildings under the
AHERA school rule.

To no one's surprise, our study determined that friable
asbestos-containing materials can be found in about one fifth of
the public and commercial buildings in this country. Two thirds
of these asbestos-containing buildings have at least some asbestos
which is already damaged.


Figure One

Response Action Timeline for Surfacing ACM

Response Category Year 1 2 3 4 5 10 20 30
Significant Damage
Option 1 Remove
Moderate Damage
Option 1 O&M Remove
Option 2 O&M. Encap Remove
Option 3 OSM. Enclose Remove
Option 4 O&M. Repair Remove
JGood_Condition
(Potential Signifi-
cant Damage)
Option 1 O&M. Remove
Option 2 OSM. Enclose’ Remove
Good Condition
(Potential Damage)
Option 1 O&M. OSM. OSM. O&M. OSM O&M O&M. Remove
Option 2 OSM OSM. OSM O&M Encap Remove
Figure Two
Response Action Timeline for Thermal ACM
Response Category Year 1 2 3 4 5 10 20 30
Significant and
Moderate Damage
Option 1 Remove
Option 2 Repair Remove
Good Condition
(Potential Signifi-
cant Damage)
Option 1 O&M. Remove
Option 2 O&M Enclose Remove
Good Condition
(Potential Damage)
Option 1 O&M. OSM. O&M OSM OSM O&M O&M. Remove
Option 2 O&M O&M O&M O&M. Encap Remove



APPROACH: To conserve funds, this study would be carried out
using an experimental design approach. Typical maintenance and
repair activities that involve disturbing in-place ACM would be
staged in selected buildings in order to simulate real world
activities. Air monitoring would be conducted during these
activities to characterize the fiber releases associated with
them. The cost estimate reflects the Agency bearing the expense
of the activities in order to ensure monitored activities are
conducted properly and so that expensive monitoring can be done
only at times that will yield the most information.

COST ESTIMATE: $5,000,000
TIME ESTIMATE: 1.5 years

STUDY 4b: PROBLEM CHARACTERIZATION STUDY 2: THE INCIDENCE OF
"PEAK" EXPOSURE LEVELS AND THEIR IMPACT ON AVERAGE BUILDING
LEVELS

STUDY OBJECTIVE: To estimate the incidence of "peak" fiber
releases and their contribution to overall asbestos levels in
buildings.

RATIONALE: EPA has no data on the contribution of incident-
related releases to overall building asbestos fiber levels. This
study will investigate fiber emissions from specific disturbances
and will provide an estimate of the frequency of occurrence of
these "peak" exposures. Measured airborne asbestos levels in
public and commercial buildings are generally low. The frequency
of "peak" exposures and their impact on overall building fiber
levels is unknown. This study would provide the Agency with
valid data upon which to base regulatory decisions about the
utility of special operations and maintenance programs for in-
place asbestos control.

APPROACH: In order to measure “peak" exposures, a large number
of air samples would need to be collected. Air monitoring would
be conducted daily and weekly over a six month period in a number
of buildings sufficient to ensure detection of "peak" incidents.
A subset of samples will be analyzed by transmission electron
microscopy.

COST ESTIMATE: $30,000,000

TIME ESTIMATE: 2-3 years


No significant differences in percent of asbestos content
were found by building height or construction type
(masonry, frame or steel beam).

An estimated 1,526,000 buildings, or 42 percent of
buildings in the survey, are estimated to have asbestos-
containing floor tile.


time required to perform these activities and the resultant
change in costs. It is expected that the revisions would yield
some increase in both hours and costs.

In total, the set of data limitations described above are
expected to result in a moderate underestimate of total costs.


NATIONAL ESTIMATES OF FRIABLE ACM IN BUILDINGS
BY TYPE OF BUILDING AND CONDITION OF MATERIAL

(Numbers in 1,000's)*

NON-RES. RESI-

PUB/COMM DENTIAL FEDERAL TOTAL
Total Number of 3,221 350 35 3,600
All Buildings**
Any ACM, 511 (16%)] 208 (598) 14 (39%) 733 (20%)
Damaged or Not
Any Damaged ACM 416 (13%) 80 (23%) 5 (14%) 501 (14%)
Any Damaged ACM, 310 (10%) 7 (2%) <5 (18) 317 (9%)
Some Significant

* Numbers are expressed in 1,000's. The percentages reflect
percentages of the total number of buildings within each building
type and are not additive (i.e., 416 (13%) is a subset of 511 (16%)
and 310 (10%) is a subset of the 416 (13%); if these were added,
double counting would occur).

** These numbers reflect the numbers of buildings in the survey target
population, which included nonresidential public and commercial
buildings, residential apartment buildings of 10 units of more,
and Federal buildings.

4. AIRBORNE ASBESTOS LEVELS
a. Data Sources

There are relatively few data available in the public
literature for estimating ambient levels of airborne asbestos
inside buildings. The data assessed in this report were obtained
from a variety of studies (see citations below) conducted in
different types of buildings for various research purposes, and
involving different types and conditions of asbestos-containing
Materials. As such, these airborne asbestos measurements are not
based on a statistical sample of school and public buildings. To
quantify these differences for the general population of
buildings and schools, more extensive surveys would be needed.
Therefore, comparisons using this information are limited to
indications of possible differences which can serve to generate
hypotheses for further research and data collection.

-10-


B. REPORT ORGANIZATION

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.


APPENDIX 1

1984 EPA
ASBESTOS IN BUILDINGS NATIONAL SURVEY OF
ASBESTOS-CONTAINING FRIABLE MATERIALS

A. Initial Analysis

oO USEPA, 1984a. U.S. Environmental Protection Agency.
Asbestos in buildings: a national survey of asbestos-
containing friable materials. Washington, DC: Office of
Toxic Substances, USEPA. EPA 560/5-84-006.

The U.S. Environmental Protection Agency's Office of Toxic
Substances (OTS) has an ongoing program concerning asbestos in
buildings. As part of this program, a national survey of
materials in buildings was conducted. The survey was an effort
to deal with the broad problem of public exposure to asbestos-
containing friable materials (ACFM). Previous estimates of the
number of buildings that contain asbestos ranged from 5 to 45
percent with an unknown degree of accuracy because they were
based on anecdotal information or expert opinion. No valid
national estimates had been generated and this wide range did not
satisfy the Agency's information needs. Thus, a national survey
was undertaken to produce more precise and statistically valid
estimates with a known degree of accuracy that can be used to
support OTS' technical assistance and regulatory programs.

The survey's primary objective was to determine the extent
of the use of friable asbestos-containing materials in buildings
and the amount of asbestos in them. A secondary objective was to
determine how many buildings have asbestos~containing floor and
ceiling tiles and the approximate square footage of each. To
accomplish these objectives, the survey was designed to:

(1) estimate the number and percent of buildings with asbestos-
containing friable material; (2) estimate the square footage of
such material; and (3) estimate the percent asbestos content of
the material. The estimates were to be made at specified levels
of accuracy, and estimates of their precision were also to be
made. These estimates were made for three types of buildings:
Federal government (owned or operated by a civilian agency);
residential (with 10 or more rental units); and private
nonresidential (largely commercial~-office, retail and other).
Additional information was gathered including data on ceiling
tile, pipe or boiler insulation, floor tile and building
characteristics.

The survey involved five major areas of work: the
development of a survey design, the design and implementation of
a quality assurance program, the execution of a field survey, the
laboratory analysis of field samples, and the statistical
analysis and interpretation of the data.

1-1


A second assistance category involves the development and
publication of voluntary standards for asbestos activities (such
as inspections). Such standards would be intended for use by
building owners and managers. Current experience with similar
activities yields an estimated cost of about $250,000 to develop
each standard, including testing and peer review. Costs were not
estimated for the grants EPA might provide to states for
inspection and management planning programs.

A third assistance category would attempt to improve public
understanding of the presence of asbestos in buildings.
Developing and publishing a citizen's guide to the hazards and
risks associated with asbestos could cost about $100,000.
Sponsoring a symposium on this subject would cost about
$50,000. Costs were not estimated for other forms of information
dissemination.

As a fourth form of assistance, EPA could develop, distribute
and encourage State and local use of such model asbestos
administration programs as a contractor certification program or
a management planning program. Past Agency experience with such
programs indicates that the development and distribution of each
new model would cost from $50,000 to $100,000. Costs were not
estimated for asbestos management assistance programs ‘stablished
with states using such existing mechanisms as tax credits.

A fifth form of assistance would have EPA promote the
development and public release of new asbestos-related
information and technology. The types of surveys required to
address the information deficiencies listed in the report would
cost an estimated $33 million to $61 million. Additional detail
on the costs of these studies is provided in Appendix 7. Further
EPA action to serve as an information clearinghouse would cost up
to $5 million on an annual basis. Costs were not estimated for
attempts to accelerate research in key areas or to perform a
formal cost-benefit analysis of the leading regulatory scenarios.

A sixth and final form of assistance would have EPA expand
the set of abatement training and accreditation programs around
the nation. That would cost the Agency an estimated $50,000 per
course. It would also likely involve an expansion of the number
of asbestos information and training centers (AITCs) and
satellite training centers. Each AITC receives a total of
$550,000 from the Agency over its first three years. Likewise,
each satellite training center receives $125,000 from the Agency
over its first two and a half years of operation. Most of the
states that house AITCs and satellite training centers provide
cost sharing support equivalent to 5% to 7.5% of annual operating
budgets. Some states also provide free office space for the
centers. Each of the 25 state training programs assisted by the

5-10


Figure
Costs of Full (AHERA) Regulatory Approach

Ten

All Bldgs.
Hospitals Fed Res comm Total

Bldg w/ ACFM

$Insp/Bldg $1,592 $1,959 $1,297 $1,239

$Mngnt Plan/Bldg $4,100 $3,433 $2,794 $2,794

#B1dg 9,675 14,000 208, 000 511,000 733,000

S06M/Bldg $16,723 $36,295 $18,857 $16,176

#Bldg 9,675 8,800 142,852 149,860

$Repair/Bldg $4,125 $18,811 $1,892 $3,087

#Bldg 929 7,251 70,709 73,725

$ Removal/Bldg $87,471 $110,686 $15,147 $23,962

# Bldg 9,675 14,000 208,000 511,000

$Encaps/Bldg $58, 236 $101,892 $30,810 $35,147

#Bldg 2,416 4,650 35,713 37,465

$Enclosure/Bldg. $73,869 $145, 419 $44,827 $53,319

#Bldg 2,416 4,650 35,713 37,465
**subtotal $447.0 $3,471.6 $11,271.2  $23,631.2 $38, 361.0
Bldg w/ NFA

$Insp/Bldg $540 $583 $359 $359

$Mngnt. Plan/Bldg $2,165 $2,369 $1,948 $1,948

$SO8M $125 $125 $93 $93

#Blag 25,816 14,802 98,804 1,363,023 1,476,629
**Subtotal $222 $132 $755 $11,763 $12, 650.0
Bldg w/ no AM
**Insp Subtotal $4.6 $1.4 $5.8 $181.5 $189.0
**TDotal $673.6 $3,605.0 $12,032.0  $35,576.0 $51,200.0

* 08M costs include any required cleaning, periodic surveillance and reinspection.
** osts are in millions of dollars.


100988501

EPA STUDY OF
ASBESTOS-CONTAINING MATERIALS
IN PUBLIC BUILDINGS

A Report To Congress

U.S. Environmental Protection Agency
Washington, D.C.
February, 1988

EP 100/9
88-501

podfidid ANENC®


RATIONALE: The Agency would have better information to determine
if regulations or other program options governing activities and
exposure of service workers to airborne asbestos in public and
commercial buildings are necessary and justified in addition to
or in place of regulations or other programs that address
exposure levels experienced by other building occupants.

APPROACH: First, estimates of prevalent levels of airborne
asbestos would need to be obtained by conducting a national
survey of public and commercial buildings. Since it is estimated
that 20 percent of all buildings contain ACM (1984 EPA Survey),
approximately 1,250 buildings would be inspected for ACM in order
to select 250 buildings for air monitoring. An average of 10
indoor and 2 outdoor samples would be collected over a one-week
period in each building and analyzed using TEM. This would
establish background levels and complement Study 7a.

The service worker exposures would be measured in public and
commercial buildings by collecting an average of 10 additional
air samples, both area and personal, to be analyzed by TEM. A
subset of these samples will be identified with episodic or peak
exposure based on the work activity involved.

COST ESTIMATE: $14,000,000 If prevalent levels have not been
established by a separate study
such as Study #7a.

$ 6,000,000 Worker exposures only, i.e., if
prevalent levels study is done
separately or not done at all
$20,000,000

TIME ESTIMATE: 2 to 3 years

LIMITATIONS/DISADVANTAGES: Again, although this study will help
determine whether or not there is a "problem" in the building
types (i.e., it will allow for risk estimates to be calculated),
it will not suggest specific regulatory or other program options
if a "problem" is found.

STUDY 7c: RESIDENTIAL APARTMENT BUILDING EXPOSURES

STUDY OBJECTIVE: To provide national estimates of prevalent
airborne asbestos levels in residential apartment buildings and
to characterize populations exposed.

RATIONALE: In the 1984 survey, EPA estimated that 59 percent of
all residential apartment buildings (of 10 units or more) contain
some type of ACM, 18 percent have sprayed- or trowelled-on ACM
and 44 percent contain asbestos TSI. Residential exposures may
be of particular concern due to relatively long times spent in
residential buildings and since much of indoor time during
childhood, outside of school, is spent in residential areas. The
risk model for mesothelioma depends on time from onset of
exposures and cumulative exposure. The risk model for lung

7-8


office and apartment complexes, government facilities, museums,
airports, hospitals, stores, and industrial buildings.

The EPA study consisted of a number of activities including
a review and reanalysis of data previously collected by EPA
during its 1984 national survey (USEPA, 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).


cancer depends on cumulative exposure and age. Prevalent
airborne asbestos levels and the numbers of people and age
distributions in residential apartment buildings would be
collected in order to determine appropriate action concerning
this building population.

APPROACH: Air monitoring and collection of data on occupant
characteristics would occur in 100 residential apartment
buildings. To identify a proper sample, approximately 500
residential apartment buildings would have to be inspected for
the presence of ACM. A small subset of the buildings would have
followup monitoring samples to assist in determining the
consistency of measured concentrations over time.

COST ESTIMATE: $6,000,000
TIME ESTIMATE: 2 years

LIMITATIONS/DISADVANTAGES: Again, although this study will help
determine whether or not there is a "problem" in the building
types (i.e., it will allow for risk estimates to be calculated),
it will not suggest specific regulatory or other program options
if a "problem" is found.

STUDY 7d: SURVEY OF FEDERALLY SUBSIDIZED PUBLIC HOUSING UNITS
FOR ASBESTOS EXTENT AND AIR LEVELS

STUDY OBJECTIVE: To determine exposures of occupants to ACM and
to airborne asbestos levels.

RATIONALE: There are approximately 1.2 million public housing
units supported by the Federal government. These buildings
contain asbestos materials, some in damaged condition, and there
is no asbestos control program in place. Typical public housing
units contain many children who spend much of their nonschool
time at home. Investigating these buildings would be consistent
with the current EPA/GSA effort to offer Federally owned and
operated buildings as a "model" asbestos management program.

APPROACH: To inspect and bulk sample in 250 additional buildings
in order to identify 50 additional buildings for air
Monitoring. The standard approach is described in Study 7a.

COST ESTIMATE: $2,000,000 (in addition to $14,000,000 of study
7a, for a total of $16,000,000)

TIME ESTIMATE: 2 years

LIMITATIONS/DISADVANTAGES: Same as Studies 7a, 7b, and 7c above.



Feasibility

Targeted regulation is appealing in theory, but the Aqency
currently lacks information on how it might choose the
appropriate blend of regulatory activities. For example, EPA
lacks the information to determine whether O&M is the next
logical or most effective regulatory step after inspection.
Further, this option, like other regulatory options, may draw
limited near-term resources away from activities already mandated
in the AHERA schools rule proqram.

Risks and Costs

The Agency lacks basic information on overall exposure, such
as the effect of O&M activities on airborne fiber levels, to make
estimates of the risk which would be reduced in each combination
of regulatory actions.

EPA'S cost analyses for several regulatory packages are
listed below.

- A rule that required inspection and development of
Management plans would cost an estimated $3 billion for
all public and commercial buildings.

- A rule that mandated inspection, management plans
(development and implementation) and an O&M program would
cost an estimated $50 billion (discounted at 10 percent
over 30 years).

- An inspection and O&M program regulation would cost an
estimated $31 billion (again discounted at 10 percent
over a 30-year period).

Policy Considerations

With additional information, this scenario would presumably
allow EPA to require only those planning, management or control
activities which are most effective in reducing exposure and risk
in public and commercial buildings.

However, the Agency lacks information necessary to make
these judgments and determine the most appropriate targeted
regulation. It is also uncertain whether one activity, such as
planning, could be determined to represent a generally preferable
approach to another, such as control, in all public and
commercial buildings. In addition, costs associated with the
alternatives are substantial and support capabilities (e.g.,
accredited experts, laboratories) may not be available in the
short run without jeopardizing compliance with the AHERA schools
rule.

~32-


II. INDIVIDUAL EXPOSURE ESTIMATION

Since the precision of the risk assessment is enhanced by the
analysis of exposure to various categories of populations,
separate estimates of exposure to asbestos are used for the
occupants of residential buildings of ten or more units, the
occupants of government buildings, and for the occupants of
nonresidential commercial buildings.

Unfortunately, data on air monitoring to determine asbestos
concentrations in buildings with friable, asbestos-containing
material (ACFM) before and after abatement action are limited to
those from a few studies only. These studies used different
methods of analysis and interpretation. The results from several
of these studies were compiled by EPA staff and are presented in
Appendix of "Cost and Effectiveness of Abatement of Asbestos in
Schools". The estimates from these studies are not used here
since they represent a wide variety of sampling methods, and it
would be extremely difficult to adjust data based on sampling
conditions and procedures that are unknown or were derived for
purposes other than the intent of this study.

An essential component of the risk analysis for asbestos
would be the actual fiber levels to which persons are exposed.
Unfortunately, EPA does not have fiber level estimates for either
schools or public buildings which can validly be extended to the
general population of buildings. In this analysis, the airborne
concentration is assumed to be the mean concentration found ina
1981 EPA study conducted in a single school district?, or 0.0021
optical fibers per cc. The weighted average concentration found
in that district of 70 ng/m3 (or 0.0021 optical f/cc) was derived
by assuming that approximately 15% of the building contains
asbestos. We do not know whether this number can be extended to
other schools, nor do we know whether it is representative of
fiber levels in public and commercial buildings.

We chose the figure of 0.0021 f/cc for the purpose of this
sensitivity analysis, as opposed to the figure of 0.03 f/cc used
in Section II.B. of the main report, for the following reason:
the figure of 0.03 f/cc and other exposure data which appear in

3 Government buildings are defined as those buildings either
owned by the U.S. Government or leased by the U.S. General
Services Administration (GSA), in which more than half of the
occupants are Federal workers.

4

U.S. EPA, Office of Toxic Substances. Cost and Effectiveness
of Abatement of Asbestos in Schools. August 1984.

5 op. Cit. USEPA 1983 (June).


in each public building class. The expected unit costs and
building counts are shown in Figure Ten. To illustrate, 14,000
Federal buildings estimated to have ACFM would incur an average
inspection expense of $1,959 for a total cost of roughly $27
million. The inspection of buildings with NFACM would cost under
$9 million, and the inspections performed on buildings with no
ACM would cost an estimated one and a half million dollars.

The resulting total inspection cost for all Federal buildings
of $37 million is shown in Figure Eleven. Residential
inspections would cost an estimated $311 million. Finally,
commercial building inspections would cost an estimated
$1.3 billion. Costs are, again, discounted at 10% over 30 years.

Figure Eleven
Total Cost by Building Type and Activity
(in millions of dollars)

Building Type

Cost Item Federal Resident Commercial Total Cost
Inspection $36.9 $310.5 $1,303.9 $1,651.4
Mgmt Plan $388.0 $2,862.6 $15,013.7 $18,264.3
O&M $319.4 $2,693.7 $2,424.1 $5,437.2
Periodic

Surveillance $16.2 $134.0 $794.8 $945.0
Reinspect $8.6 $45.4 $252.9 $306.9
Repairs $136.4 $133.8 $227.6 $497.8
Encapsulation $473.8 $1,100.3 $1,316.8 $2,890.9
Enclosure $676.2 $1,600.9 $1,997.6 $4,274.7
Removal $1,549.6 $3,150.7 $12,244.6 $16,944.9
Total $3,605.3 $12,031.8 $35,576.1 $51,213.1

Note: Totals may not add exactly due to rounding.


c. RISK

1. INTRODUCTION

Risk associated with exposure to asbestos can be calculated
using mathematical models which translate cumulative exposure
(i.e., f/ec per years of exposure) into expected number of deaths
from mesothelioma and lung cancer. (Quantitative risk models for
other cancers are not as well developed and the risk from these
cancers is generally considered to be much lower. Asbestosis,
which has been a prevalent disease among workers in asbestos mining
and manufacturing, is not typically associated with nonoccupational
exposure levels.) The expected number of lung cancer cases depends
on cumulative exposure and age. The expected number of
mesothelioma cases depends on cumulative dose and time elapsed
since the onset of exposure (USEPA, 1986).

Two methods of analyzing risk are presented. Unfortunately,
data limitations associated with airborne asbestos fiber levels, as
discussed in the previous section, preclude any reliable estimates
of risk. Instead, arbitrarily selected levels have been chosen and
analyzed to demonstrate the sensitivity of the models under certain
scenarios. The numerical estimates of risk associated with these
arbitrary levels cannot be assumed to represent actual risk
experienced in public and commercial buildings.

The first method, a proportional risk assessment, compares the
percentage of total risk attributed to exposure in nonresidential
public and commercial buildings with the percentage attributed to
exposure in schools. The second method provides a discussion of
absolute risk based on a selected exposure level, assumptions on
length of exposure, and the number of people exposed.

2. PROPORTIONAL RISK

In this Section, a proportional risk assessment is used to
illustrate the percent of total risk attributed to exposure in
nonresidential public and commercial buildings as compared to the
percent attributed to exposure in schools. Since information on
exposure levels in these two populations of buildings is limited
and the relationship between the two is unknown, several
proportional risk scenarios are examined. It is likely that the
appropriate scenario for service workers will differ from the
scenario for general building occupants. In one scenario, it is
assumed that the level in nonschool buildings is twice the level
in schools. In another, the levels are assumed to be the same.
In a third scenario, air levels in public and commercial
buildings are assumed to be one-tenth those in schools. These
and other scenarios are analyzed in Appendix 4.

-14-


asbestos standard. The effects of occupational exposure are
clear and some high nonoccupational levels have been found.
Extrapolations of cancer risks from occupational circum-
stances can be made for nonoccupational exposure, but only
with great uncertainty.


was chosen to provide a reference point; since the risk of all
three types of cancers are directly proportional to the exposure
concentration, it is a simple matter to determine what the
expected cancer deaths might be in any other scenarios. It
should be stressed that the numbers generated by the model are
based on estimated fiber levels and estimated population
exposed. Since fiber levels are uncertain, the estimate of
deaths provided by the model is also uncertain. The number of
cases and deaths predicted by the model occur between 1988 and
2118 (130 years) and are the result of exposure to asbestos in
buildings between 1988 and 2048 (60 years).

As described earlier, the models used to estimate cancer
cases and deaths are Nicholson's absolute risk model (for
mesothelioma) and Nicholson's relative risk model (for lung
cancer). The model's results are directly proportional to fiber
concentrations so that determination of the statistical deaths
associated with higher- or lower-level asbestos concentrations is
a straightforward process. For example, if the fiber levels were
as low as one-tenth the mean of the school district study, we
would expect a total of 430 total deaths due to lung cancer, GI
cancer and mesothelioma. On the other hand, if the fiber levels
were as high as twice the mean of the school district study, we
would expect 8,540 deaths due to lung cancer, GI cancer and
mesothelioma.

TABLE 2

NON-CUSTODIAL OCCUPANTS

Residential
Buildings
Government Commercial (10 or more
Buildings Buildings units) Total*
CASES** (1988 - 2118) 70 2650 1850 4570
DEATHS (1988 - 2118)
Lung Cancer 30 1160 570 1750
G-I. Cancer 0 120 60 180
Mesothelioma 30 1190 1120 2340
TOTAL* 70 2460 1750 4280

*

Columns may not add exactly due to rounding. All numbers have
been rounded to the nearest ten.

** Assumes fiber exposure of 0.0021 optical f/cc.

Given this illustrative range of exposure for non-custodial
occupants of public and commercial buildings among 35.6 million
people exposed, the lifetime (30_years of exposure) risk to
individuals would range from 1075 to 1074. This is equivalent to
between 7 and 143 deaths per year of exposure over the up to

6-9


The second step was to estimate the likely inspection cost
for a building that had ACFM, NFACM, or no ACM at all. This was
accomplished by adjusting the inspection cost estimates developed
for the schools rule RIA to the sizes of the various model public
buildings. The inspection costs developed for the RIA were based
on estimates of the time needed to perform the different
inspection tasks: a building walkthrough and visual assessment,
bulk sampling and analysis, assessment, mapping, and reporting.

The time estimates were based primarily on the size of the
school; its ACM mix was a secondary factor. Inspection hours for
public buildings were established by comparing the size of the
model public buildings with the size of the model schools
developed for the schools rule RIA. If a public building model
reasonably matched a school model in terms of size measured in
square feet, the estimated school inspection time was applied to
the public building model. Thus, the Federal building model used
the time estimates developed for the public secondary school.

The residential and commercial building models, on the other
hand, used the time estimates from the public primary school.
Appendix F of the schools rule RIA presents details on the
development of the time estimates.

The time estimates were then slightly decreased to account
for the fact that the public building models were somewhat
smaller than the school models they were matched with. As an
illustration, the time estimate for a public secondary school (of
some 80,000 square feet) was 15.5 hours, exclusive of time spent
collecting bulk samples. The Federal building model, at
42,000 square feet, was slightly over half the size of the school
model. Reducing the Federal building's inspection time
requirements by a ratio of 42:80 (for thousands of square feet of
model size) did not seem appropriate given the increased
complexity of the Federal building's tenant mix and tenant
activities. Thus, it was decided that 9.5 hours was a reasonable
estimate of the time required for all inspection activities (save
collection of bulk samples) in the Federal building.

Once inspection hours were developed, the inspection cost was
calculated by simply multiplying hours by unit labor rates. The
estimated inspection cost for buildings with both types of ACFM
is from $1,904 to $3,354 per building, depending on building
type. The cost for buildings with NFACM ranges from $359 to
$583 per building. For buildings with no ACM, the cost ranges
from $135 to $224.


2

The asbestos present in approximately 730,008 of the public
and commercial buildings in this country represents a potential
health hazard which deserves our careful attention. However, it
is not the mere presence of asbestos which poses a health risk to
building occupants; the true hazard is presented by damage and
disturbance of that asbestos which releases fibers to the air that
are inhaled by people.

Removal of asbestos from buildings, although attractive in
concept, is not always the best alternative from a public health
perspective. In fact, improperly performed removal of asbestos
can result in a very high level of exposure for the occupants of
that building and perhaps others as well. Response actions short
of removal, such as encapsulation, and good housekeeping
procedures during the life of the building can be safer in some
circumstances. This is why the AHERA school regulations,
promulgated last October for asbestos in schools, established a
carefully structured process by which case-by-case determinations
are to be made by trained professionals about the proper solution
to the presence of asbestos in particular schools. Where removal
is deemed appropriate, careful procedures to prevent exposure to
the public both during and after the removal are mandated.

If we are not careful we will stimulate more asbestos
removal actions in public and commercial buildings during the
next few years than the infrastructure of accredited
professionals and governmental enforcement can effectively
handle. For example, as public and commercial buildings are
sold, investors are increasingly insisting that the asbestos in
the buildings be removed, as a condition of the purchase. Unless
such removals are done correctly, exposure of asbestos to the
public may actually be increased. We already have anecdotal
information which leads us to believe that irresponsible and
potentially dangerous removal action is taking place outside of
carefully monitored programs, and we do not want to exacerbate
this problem by our actions.

I therefore strongly recommend that we take steps now to
focus our attention on assessing and improving the QUALITY of the
asbestos-related actions that currently take place in public and
commercial buildings. I recommend that the following steps be
taken over a three-year period:

(1) Enhance the Nation's Technical Capability.

Ideally, owners of public and commercial buildings should
use trained and accredited professionals, just as the schools are
required to do for inspection and abatement activities. Under the
AHERA school rule, States are now establishing accreditation
programs for asbestos control professionals. Since we do not want


B. Additional Analysis

o Rogers, J. 1987. Final Report: Additional analysis of
data collected in the asbestos in buildings survey.
Westat: Rockville, MD. Prepared for the Office of Toxic
Substances, U.S. Environmental Protection Agency.

The data collection for the 1984 EPA National Survey
included a code describing the physical condition of the ACFM.
These condition codes have not been previously analyzed. The
Asbestos Hazard Emergency Response Act (AHERA) of 1986 requires
EPA to report to Congress on the condition of asbestos-containing
materials in commercial buildings and the likelihood that persons
occupying such buildings are, or might be, exposed to asbestos
fibers. An analysis of the asbestos in buildings survey data by
condition code can be used to support EPA's report to Congress in
response to AHERA.

The objective of the additional analysis of the survey data
was to provide estimates for the number of buildings, floor area
of buildings, and surface area of ACFM in buildings with either:
a) any ACFM, b) damaged ACFM, or c) significantly damaged ACFM.
These estimates are broken down into categories by type of
asbestos-containing material, type of building, and height of
building.

The condition codes from the survey are defined on a
relative scale from 1 (Best) to 5 (Worst), with the damaged ACFM
defined as having condition codes 3, 4, or 5, and significantly
damaged asbestos having condition code 5.

The major findings are summarized below. As used in this
report, the term asbestos-containing friable material refers
collectively to sprayed-on or trowelled-on friable material,
ceiling tile, and/or pipe and boiler insulation. Results
pertaining to one of these types of material specifically
reference the particular material type. The term "all buildings"
refers to estimates based on survey data appropriately weighted
to the defined target universe. There are several important
exclusions from this universe. One is primary and secondary
schools, which are studied and regulated under a separate EPA
program. Other excluded buildings are those owned or occupied
primarily by agencies of State and local governments or
residences with fewer than 10 units.

The figures given here are estimates and, as such, are
imperfect measures. In general, survey estimates are subject to
sampling error and non-sampling error. Ranges given in
parentheses following the estimates represent 95 percent
confidence intervals for the estimates based on the sampling
error. This means that there is only a five percent chance that
the actual values fall outside this range.

1-7


APPENDIX 2
SUMMARIES OF OTHER MAJOR SUPPORT STUDIES

Hatfield, J., Stockrahm, J., Chesson, J. 1987. Draft report
for task 2-31: Preliminary analysis of asbestos air
monitoring data. Washington, DC: Office of Toxic
Substances, U.S. Environmental Protection Agency.

Interim report of prevailing air levels in 43 Federal
buildings in six cities across the Nation found asbestos
levels to be very low (mean values between 0.00059 to 0.00073
f/cc as measured by TEM). Further, preliminary results
appeared to indicate no difference between levels found in
buildings with ACM and outdoor ambient levels, when compared
at the 0.05 level of statistical significance. EPA is now
completing its peer review of the interim report.

Dietz, S. 1987. Asbestos focus group: a report froma
focus group on asbestos in buildings with federal government
agency program managers. Westat: Rockville, MD. Prepared
for the Office of Toxic Substances, U.S. Environmental
Protection Agency.

Roundtable discussion of a seven Federal managers who
summarize their asbestos programs, identify the problems of
controlling asbestos in their facilities, assess existing
Federal regulations and guidance, and recommend activities to
EPA for appropriately addressing the asbestos hazard in
public buildings.

Price, A., Price, B. 1987. Report on workshops regarding
AHERA section 213: a study to assess the need for asbestos
regulations in public and commercial buildings. Price
Associates: Washington, DC. Prepared for the Office of
Toxic Substances, U.S. Environmental Protection Agency.

Proceedings of two workshops to examine current asbestos
Management practices, discuss control problems and identify
ways to reduce asbestos hazards in public buildings. The
first panel consisted of approximately 17 buildings owners,
investors and consultants, primarily contractors; the second,
about 19 State and local government officials, some with
experience in regulating public and commercial buildings.

USEPA. 1986. U.S. Environmental Protection Agency.
Airborne asbestos health assessment update. Washington,
DC: Office of Health and Environmental Assessment, USEPA
EPA/600/8-84/003F.

Health assessment summary, developed by the EPA Office of
Health and Environmental Assessment and reviewed by the EPA
Science Advisory Board, provides a scientific basis for
review and revision, as appropriate, of the Agency's NESHAP

2-1


SUMMARY OF MAJOR FINDINGS

Sprayed- or Trowelled-on ACFM

fe)

The percentage of buildings with asbestos~containing
sprayed- or trowelled-on friable material by condition of
material is:

All material 5% (0.5-10%)
Damaged material 2% (<4%)
Significantly damaged material 08 (<0.5%)

Most of the buildings with asbestos-containing sprayed- or
trowelled-on friable material have one or two floors or are
commercial/private nonresidential, reflecting the overall
distribution of buildings.

Most of the floor area associated with buildings with
asbestos-containing sprayed- or trowelled-on friable
material is in highrise buildings (8 or more floors).

For buildings with asbestos-containing sprayed- or
trowelled-on friable material the ratio of surface area of
Material to floor area of the buildings decreases with
building height.

Pipewrap or Boiler Insulation

°

ACFM

The percentage of buildings with asbestos-containing pipe
wrap and boiler insulation by condition of material is:

All material 16% (7-25%)
Damaged material 13% (3-22%)
Significantly damaged material 98 (<193%)

Asbestos-containing pipe wrap or boiler insulation was found
in the sample in almost all building categories and
conditions.

Fifty-eight percent of buildings with pipe wrap or boiler
insulation have asbestos-containing pipe wrap or boiler
insulation.

All highrise buildings (8 or more floors) in the sample had
asbestos-containing pipe wrap or boiler insulation.

in Public Areas

The percentage of buildings with ACFM in public areas by
condition of material is:

All material 13% (10-15%)
Damaged material 8% (4-118)
Significantly damaged material 2% (<7)

1-8


Figure Seven
Costs for Inspection and Management Plan Development

All Bldgs.
Hospitals Fed Res Comm Total

Bldg w/ ACFM
* Insp/Bldg $1,592 $1,959 $1,297 $1,239

$Mgmt Plan/Bldg. $1,200 $1,350 $1,080 $1,080

#Bldg 9,675 14,000 208,000 511,000 733,000
**subtotal $27.0 $46.3 $494.3 $1,184.8 $1,726.9
Bldg w/ NFACM
* $Insp/Bldg $540 $583 $359 $359

$Mgmt Plan/Bldg. $640 $720 $540 $540

#Bldg 25,816 14,802 98,804 1,363,023 1,476 ,629
**Subtotal $30.5 $19.3 $88.8 $1,225.4 $1,334.0
Bldg w/ no ACM
** Insp Subtotal $4.6 $1.4 $5.8 $181.8 $189.1
**Total $62.1 $67.0 $589.0 $2,592.0 $3,250.1

* Includes Inspection and Notification Costs. Costs for buildings with ACFM
are averages of costs for each possible ACM mix per building.
** In Millions. Totals may not equal due to rounding.

The cost of implementing an O&M program in the first year
ranges from $12,283 to $14,898 for buildings with ACFM. These
costs include expenditures for durable equipment such as HEPA
vacuums, a quantity of disposable dusting and mopping tools, and
labor costs associated with the actual cleaning effort. Annual
O&M costs are considerably lower in following years, from
$3,746 to $5,181 for cleaning procedures.

The estimated costs for this activity are presented in Figure
Eight. It was assumed that all buildings will be used for
30 more years, and O&M cleaning activities, training, periodic
surveillance and reinspection will continue throughout that
time. The resulting cost, discounted at 10% over 30 years, is
roughly $50 billion. The total cost breakdown is: Federal
buildings, over $1 billion; hospitals, $690 million; residential
buildings, just under $12 billion; and commercial buildings, over
$36 billion. (As noted above, hospital-related costs are
subsumed by the cost estimates for all commercial buildings.)


APPENDIX 6
ABSOLUTE RISK SENSITIVITY ANALYSIS

I. INTRODUCTION

This appendix will illustrate the relationship between fiber
levels and asbestos-related mortality which could be attributed
to the presence of asbestos-containing material in public and
commercial buildings. These scenarios cover deaths occurring
over the next 130 years as a result of exposure to asbestos-
containing material within the next 60 years.

As was discussed in the main report, many data which would
strengthen this risk sensitivity analysis do not exist. The
fiber levels which are prevalent in public and commercial
buildings comprise a major source of uncertainty in the
production of absolute risk numbers. In addition, EPA has
applied necessarily broad assumptions about the person-hours of
occupancy used in these scenarios, as well as the ages of their
exposed populations.

A further reason to examine the scenarios with caution is the
lack of any information on current abatement actions which are
occurring in the absence of specific Federal regulations. These
abatement actions, driven by considerations (inter alia) of legal
liability and State and local regulation, may reduce a
significant proportion of the risk from asbestos currently
located in public and commercial buildings.

The risks of lung cancer are estimated using Nicholson's
relative risk model, while those of mesothelioma are estimated
using Nicholson's absolute risk model.! ‘These models have been
used by both OSHA and CPSC in rulemakings, and are used by EPA in
proposed rules for other asbestos products. These are the
standard models for estimating risks resulting from asbestos
exposure. Although the models are standard, peer-reviewed,
models, the fiber level selected for use with the models is that
found in an EPA study of one school district.* This particular
level was selected to indicate the results of the model when a
specific fiber level is chosen, and is not meant to suggest which
fiber levels are actually present in public and commercial
buildings. The results of this analysis are, therefore, purely
illustrative.

1 U.S. EPA, Office of Health and Environmental Assessment.
Airborne Asbestos Health Assessment Update. June 1986.

2 Airborne Asbestos Levels in Schools, Office of Toxic
Substances, U.S.E.P.A., June 1983. EPA 560/5~83-003.

6-1


The study was conducted in 10 sites (cities or groups of
counties) chosen with probability sampling to represent the
continental U.S. A total of 231 buildings was inspected, with
about half being private nonresidential, one-quarter residential,
and one-quarter Federal government. A total of 1,514 bulk
samples was taken. The sample of buildings was chosen so that
separate estimates could be made for each type of building.
Although survey participation was not mandatory, a high rate of
cooperation was achieved ~-- 88 percent of initially sampled
eligible buildings were inspected. Replacements for those
buildings that did not participate were identified and
substituted.

Each sampled building was thoroughly inspected for the
presence of friable materials which might contain asbestos:
sprayed- or trowelled-on materials, ceiling tile, and pipe and
boiler insulation. A bulk sample was taken of any such material
found, and all bulk samples were analyzed for asbestos content.
Pipe wrap was sampled at elbows, pipe ends and damaged spots, to
estimate asbestos content of exposed material. Undamaged
Material not at elbows or valves may have lower percent asbestos
content. The chemical analysis was carried out using Polarized
Light Microscopy (PLM); the identity of the fibers was determined
by optical characteristics according to an established protocol.

Vinyl floor tile was also sampled whenever found. The
results of these analyses were presented in a separate
publication, "Use of Asbestos-Containing Friable Materials and
vinyl-Asbestos Floor Tiles in Public and Commercial Buildings,"
EPA/OTS Asbestos-in-Buildings Technical Bulletin Series, March
12, 1985.

The major study findings are summarized below. The term
"asbestos-containing friable material" (ACFM) refers collectively
to sprayed- or trowelled-on friable material, ceiling tile,
and/or pipe and boiler insulation. Results pertaining to one of
these types of material specifically reference the particular
material type. The term "all buildings" refers to estimates
based on survey data appropriately weighted to the defined target
universe. There are several important exclusions from this
universe. One consists of primary and secondary schools, which
are studied and regulated under a separate EPA program. Other
excluded buildings are those owned or occupied primarily by
agencies of State or local governments, which may be a sizable
number of buildings (there are no published estimates of the
exact number), and residential buildings with fewer than 10
units.

The figures given here are estimates and, as such, are
imperfect measures. In general, survey estimates are subject to
sampling error and nonsampling error. Ranges given in
parentheses following the estimates represent the 95 percent
confidence limits for the estimates due to sampling error. This

1-2


APPENDIX 8

REFERENCES

Berry, C., 1986. Chrysotile and mesothelioma. Accomplishments
in oncology. The biological effects of chrysotile. Ed. J.c.
Wagner. General Motors Cancer Research Foundation.

Burdett, G.J., Jaffrey, S.A.M.T., 1986. Airborne asbestos
concentrations in buildings. London: Occupational Medicine and
Hygiene Laboratory, Health and Safety Executive. 185-199.

Chatfield, E.J., 1985. Airborne asbestos levels in Canadian
public buildings. Ontario: Ontario Research Foundation.

CPSC, 1983. Consumer Product Safety Commission. Report to the
U.S. Consumer Product Safety Commission by the Chronic Hazard
Advisory Panel on Asbestos. Washington, DC.

Dietz, S., 1987. Asbestos focus group: a report from a focus
group on asbestos in buildings with federal government agency
program managers. Rockville, MD: Westat. Prepared for the
Office of Toxic Substances, U.S. Environmental Protection Agency.

Hatfield, J., Stockrahm, J., Chesson, J., 1987. Interim report
for task 2-31. Preliminary analysis of asbestos air monitoring
data. Washington, DC: Office of Toxic Substances, U.S.
Environmental Protection Agency.

Hammond, E.C., Selikoff, I.J., Seidman, H., 1979. Asbestos
exposure, cigarette smoking and death rates. Annals of the New
York Academy of Science, 330:473-90.

Lee, R.J., 1987. The Constant study; revisited: A comparison
of the airborne asbestos fiber concentrations in schools as
determined by direct and indirect sample preparation techni-
ques. Monroeville, PA: Energy Technology Consultants.

NRC, 1984. National Research Council. Asbestiform fibers:
nonoccupational health risks. Washington, DC: National Academy
of Sciences.

Pinchin, D.J., 1982. Asbestos in buildings. Study prepared for
the Royal Commission on Matters of Health and Safety Arising from
the Use of Asbestos in Ontario. Ontario: Ontario Research
Foundation.

Price, A.M., Price, B., 1987. Final report for task 2-27.
Report on workshops regarding AHERA Section 213: a study to
assess the need for asbestos regulations in public and commercial
buildings. Washington, DC: Price Associates. Prepared for the
Office of Toxic Substances, U.S. Environmental Protection Agency.


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 and
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 Federal 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~--

-1l-


to the AHERA schools regulations for the commercial sector. Air
monitoring would be utilized to evaluate the effectiveness of
asbestos control programs.

APPROACH: The objective would be met by an air monitoring study
which would be conducted over the next four years, the first
sampling period to be accomplished now with a followup period in
three years in order to compare prevalent levels and assess the
reduction in exposure, if any, aS a result of the asbestos
management programs taking effect.

COST ESTIMATE: $15,000,000
TIME ESTIMATE: 5 years

LIMITATIONS/DISADVANTAGES: Essentially the same as Study 5a
above.

STUDY 6: EXPOSURE-RISK INTERPRETATION

STUDY OBJECTIVE: To establish a standard method for using TEM
exposure estimates to calculate risks of lung cancer and
mesothelioma.

RATIONALE: The models for lung cancer and mesothelioma relating
risk to exposure were developed from data reflecting exposure
measurements based on PCM. A formal method for applying these
models directly to fiber concentrations measured by TEM has not
been developed. Previous risk calculations where TEM was used to
measure exposure have relied on a conversion from mass to fibers,
typically using 30 fibers per nanogram. The conversion factor
was developed using assumptions concerning the size distribution
of fibers visible by PCM and limited data directly comparing PCM
and TEM measurements. Differences between direct and indirect
filter preparation methods were not considered.

APPROACH: This study will consist of a thorough review of the
measurements used to establish current exposure-risk
relationships for lung cancer and mesothelioma. Special emphasis
will be placed on summarizing fiber size distributions. These
findings will be analyzed in conjunction with summaries of fiber
size distributions associated with Method 7400 (PCM), "direct"
TEM, and "indirect" TEM. The results of the analysis will be
summarized in a report that will indicate the assumptions
underlying risk calculations based on exposure measurements
obtained by different methods. The report will also suggest a
standard EPA approach for using asbestos exposure data to
evaluate risk.

COST ESTIMATE: $75,000

TIME ESTIMATE: 6 months

7-6


Use of these hazard categories allowed the use of the
response action timelines developed for the RIA. The timelines
shown in Figures One and Two present the types and timing of
response actions considered suitable for asbestos-containing
surfacing material and thermal systems insulation, respectively,
in different damage categories.

The term "project area" is used to denote a homogeneous
expanse of ACM, such that the ACM (and the space in which it is
enclosed) could be efficiently treated with one abatement
project. The sizes of the model buildings derived from the AIBS
are quite close to those of the model schools used in the final
schools rule's RIA. Thus, it was assumed that the range of model
asbestos projects developed for the RIA could also be used for
this study.

The AIBS noted that most buildings in the survey have only
one to two floors. To simplify the analysis, it was assumed that
all asbestos project areas would be based on one floor. Although
this is an accurate representation of most project areas, this
assumption tends to underestimate unit costs for a limited number
of abatement projects in multi-story buildings.


Table 4. Estimated percentage of buildings in the continental U.S.
with any asbestos-containing friable material with the
condition indicated, by condition of the asbestos-containing
friable material (ACFM) and by type of building. (See notes
below.)

(95% confidence intervals are shown in parentheses)

Condition of ACFM
Significantly
Building Type Any Damaged Damaged
Federal 39% 14% 1%
(29-48%)
(100%)
Residential 59% 23% 23
(10+ rental units) (45-74%)
(100%)
Commercial 16% 13% 10%
Nonresidential (9-238)
(100%)
All Buildings 20% 14% 9%
(14-27%) (6-22%) (<198%)
(100%)
Notes:
Asbestos-containing friable material has more than 1%

asbestos.
Damaged is defined by condition codes of 3, 4, or 5.
Significantly damaged is defined by a condition code of 5.

Missing condition codes have been imputed to get national totals.
Columns will not add.


APPENDIX 7
POSSIBLE STUDIES TO ADDRESS INFORMATIONAL DEFICIENCIES
The following studies are means for addressing the
informational limitations listed in Part 4 of Section III.A.

STUDY 1: EVALUATION OF THE IMPLEMENTATION OF AHERA SCHOOLS RULE

STUDY OBJECTIVE: To identify efficiencies and difficulties
experienced by schools in attempting to achieve full compliance
with AHERA regulations.

RATIONALE: Before proceeding with a regulatory program for
public and commercial buildings, technical implementation
problems and potential resource constraints associated with the
regulations promulgated for schools under AHERA should be
identified. The "lessons" learned in the program for schools
should provide a basis for proceeding with regulatory programs
for the public and commercial buildings sector.

APPROACH: This information would be obtained in a national
telephone survey of Local Education Agencies (LEAs) similar to
the EPA survey conducted previously to assess compliance with the
1982 Asbestos Identification and Notification regulation. On-
site quality assurance checks would be implemented at a subsample
of LEAs to verify the survey respondent information. The survey
would be planned during the last quarter of fiscal year 1988 and
conducted during 1989 and 1990. Interim results would be
available in March 1989, September 1989, and March 1990. Final
results would be available in September 1990.

COST ESTIMATE: $1,500,000
TIME ESTIMATE: 2.5 years

STUDY 2: OPERATIONS AND MAINTENANCE PROCEDURES EFFICACY

STUDY OBJECTIVE: To evaluate the efficacy of particular
operations and maintenance (O&M) procedures, such as special
cleaning techniques.

RATIONALE: Most of the information that exists regarding these
objectives is anecdotal in nature. A valid study would provide
careful evaluations of various O&M procedures and strengthen the
Agency's technical guidance and regulatory programs.

APPROACH: Air monitoring would be conducted over time in
buildings selected on the basis of function, construction and
engineering systems, and existing asbestos management/O&M/
abatement programs. Standard asbestos sampling and analysis
methods would be employed. It is anticipated that the study
might have to bear the costs of special cleaning operations in

7-1


also be evaluated after a fixed period, along with the AHERA
schools rule program, to provide a better context for future
regulatory assessment.

Feasibility

The General Service Administration (GSA), the Federal
government's primary building owner and manager, already has in
place a relatively comprehensive inspection and management
program. Further, the Federal building universe, including about
14,000 buildings which contain asbestos, is manageable and an
Executive Order might be sufficient to establish a mandatory
program. However, Federal departments or agencies could find a
Mandatory program difficult to implement within present budgets
since the costs could be high. GSA, for instance, has spent at
least $35 million on inspection and abatement activity, and since
1978, the U.S. Postal Service has spent $50 million for asbestos
abatement in about 800 buildings (Dietz, 1987). Also, Federal
workers might object to the use of their workplace as a "testing
ground" for experimental asbestos control and abatement
activities.

Risks and Costs

This option should result in some risk reduction for Federal
employees and other occupants of Federal buildings, particularly
if appropriate response actions were identified and implemented
in a timely manner. However, the extent of this risk reduction
is questionable. EPA's interim report, as discussed previously
in the Airborne Asbestos Levels part of Section II, did find very
low prevailing asbestos fiber levels in surveyed Federal
buildings and no significant difference between levels in these
buildings and those taken outdoors, although these results cannot
be considered representative of all Federal buildings (Hatfield
et al., 1987).

EPA's analysis for this scenario indicates that a full
regulatory program for approximately 35,000 Federal buildings
would cost under $4 billion (discounted at 10 percent over a 30-
year period). This estimate excludes costs for EPA analysis and
evaluation activities. It also leaves out ongoing costs
associated with GSA's current management program activities.

Policy Considerations

The scenario would provide additional exposure and risk
information on a specific sector of public and commercial
buildings, and deal with the practical difficulties of a
mandatory control program before deciding whether to impose
regulations on other public and commercial buildings. GSA's
existing asbestos management program provides a good foundation
on which to build. Analytic and evaluative activities in Federal
buildings should improve EPA's understanding of risk in such

-28-


B. SCENARIOS: FEASIBILITY, RISKS AND COSTS,
AND POLICY CONSIDERATIONS

Asbestos in public and commercial buildings is not a new
issue, and considerable attention is now being given to this
Matter by State and local governments, building owners, lenders,
and occupants. However, given the asbestos information detailed
earlier in this report, the question is whether additional
action, if any, is warranted at this time.

EPA examined six major risk reduction scenarios which go
beyond present activity. To the extent possible, given the
current data, the Agency analyzed the feasibility, risk
reduction, and costs of implementation of each scenario. These
scenarios are:

° Enhanced Technical Assistance

° Federal Buildings as a Management Model

° Inspection Rule

° Targeted Requlation

fo) Sequential Requlation

° Immediate Comprehensive AHERA-Type Regulation

The feasibility, risks and costs, and the major policy
considerations associated with each scenario for risk reduction
are discussed and assessed generally in the order of increasing
Federal government intervention and cost.

1. ENHANCED TECHNICAL ASSISTANCE

This scenario would increase the Agency's asbestos technical
assistance and guidance activities by targeting populations in
particular need of protection, such as service and maintenance
workers, and by concentrating Federal resources on key activities
which would benefit most from EPA direction. Individual techni-~
cal assistance and guidance activities that could be considered
are presented below in six major categories. One, some, or all
of the categories could be selected.

a. Protecting service and abatement personnel

Under this category, EPA could develop a model O&M program,
including guidance and training materials, in conjunction with
OSHA, unions, worker groups, building owners and managers. In
particular, the Agency could promote a voluntary inspection
program as well as the practice of testing suspect materials
prior to a scheduled maintenance activity, as is implied but not
explicitly required by the OSHA standards.

-24-


STUDY 5a: PRIVATE SECTOR ASBESTOS MANAGEMENT ACTIVITIES AND
STATE AND LOCAL GOVERNMENT PROGRAMS

STUDY OBJECTIVES: To characterize and document current asbestos
Management programs in public and commercial buildings (non-
school buildings owned privately or by State and local
governments).

RATIONALE: To determine the extent of the need for Federal
regulations regarding inspection and response actions to control
asbestos exposure in these buildings. For example, if voluntary
Management activities are successfully in place in the commercial
sector and if State and local government regulatory programs are
effective, EPA's regulatory risk management efforts could
emphasize technical assistance rather than requirements similar
to the AHERA schools regulations for the commercial sector.

APPROACH: A national survey of building owners and managers,
including State and local government officials, to identify and
characterize asbestos management programs that are in place. A
combination of survey methods would be employed (telephone,
personal interview, mail) with on-site followup visits to verify
respondents' report information.

COST ESTIMATE: $850,000

TIME ESTIMATE: 1.5 years

LIMITATIONS/DISADVANTAGES: This does not address the question of
risk in buildings without management programs. It is also very
difficult to determine the "before" situation necessary to
evaluate the impact of private sector programs. In addition,
buildings are likely to have different sets of circumstances and
control mechanisms which would not necessarily be reproducible.
For example, education/awareness training, O&M, and removal would
not necessarily be separable activities.

STUDY 5b: EVALUATE IMPACT OF PRIVATE SECTOR/STATE AND LOCAL
ASBESTOS MANAGEMENT PROGRAMS

STUDY OBJECTIVE: To determine the impact of private sector
asbestos management activities and State and local government
asbestos control programs on prevalent airborne asbestos levels
in these buildings.

RATIONALE: To determine the extent of the need for Federal
regulations regarding inspection and response actions to control
asbestos exposure in these buildings. For example, if voluntary
management activities are successfully in place in the commercial
sector and if State and local government regulatory programs are
effective, EPA's requlatory risk management efforts could
emphasize technical assistance rather than requirements similar


IV. RECOMMENDATIONS

The Administrator’s responses to the findings of this report
are contained in the following letter to the Honorable George
Bush, President of the Senate, and the Honorable James C. Wright,
Jr., Speaker of the House of Representatives:

-36-


Table 1. LIFETIME RISKS PER 100,000 MALES OF DEATH FROM MESOTHELIOMA AND LUNG
CANCER FROM CONTINUOUS ASBESTOS EXPOSURE OF 0.01 f/cc ACCORDING TO AGE AND
DURATION OF EXPOSURE. DERIVED FROM AIRBORNE ASBESTOS HEALTH ASSESSMENT
UPDATE, JUNE 1986, TABLE 6-3, PAGE 165. (USEPA, 1986) THE LEVEL OF

0.01 £/cc IS ARBITRARY.

Mesothelioma
Years of Exposure

Age of onset

of exposure 1 5 10 13 18 20 23 33 Life
0 11.2 51.0 91.1 107.5 134.8 145.7 147.6 153.9 192.8
5 9.1 41.1 74.7 86.8 107.1 115.2 116.7 121.6 149.8
10 7.0 31.2 58.2 66.2 79.4 84.7 85.7 89.1 106.8
18 4.7 20.2 35.7 40.8 49.2 52.5 53.1 54.9 62.7
20 4.1 17.5 30.1 34.4 41.6 44.5 44.9 46.2 51.7
30 2.1 8.8 14.6 16.3 19.2 20.4 20.5 20.9 22.3
50 0.3 1. 1.8 1.9 2.0 2.0 2.0 2.1 2.1
Lung Cancer
Years of Exposure
Age of onset
of exposure 1 5 10 13 18 20 23 33 Life
0 2.9 14.8 29.7 38.6 53.3 59.2 68.1 97.7 170.5
5 2.9 14.9 29.8 38.6 53.4 59.4 68.3 97.9 156.3
10 2.9 14.9 29.8 38.7 53.6 59.5 68.4 98.2 142.0
18 3.1 15.0 30.0 38.8 53.5 59.4 68.3 98.0 118.8
20 3.1 15.0 30.0 38.8 53.5 59.4 68.3 98.0 113.0
30 3.1 14.9 29.8 37.8 51.2 56.6 65.1 93.4 84.8
50 2.5 11.5 20.3 22.9 27.3 29.1 33.5 48.0 30.2

Note: The proportional risk analysis does not depend on absolute exposure
level, nor sex. The choice of males and 0.01 f/cc is arbitrary.


assessment tools for extensive testing in a variety of building
situations. There are a number of technical sampling and
analysis methods that would need to be further refined prior to
the field aspects of this study.

COST ESTIMATE: Precise estimates are impossible since it is an
exploratory study with an unpredictable likelihood of success.
However, due to the numerous technical complexities, it would
take a multi-million dollar effort to make worthwhile progress on
the problem.

TIME ESTIMATE: Uncertain, since the results from any phase of
the study are unpredictable.

LIMITATIONS/DISADVANTAGES: It is uncertain that such a mechanism
could be found. Limited and unsuccessful attempts have been made
in the past to predict exposures by virtue of the condition of
ACM and other subjective criteria, although these studies have
never been adequately funded. Further, no risk reduction
strategies would be obtained from this study even if it were
successful.



Once unit inspection costs were developed for buildings of
each building type and with different combinations of ACM, these
costs were multiplied by the appropriate number of buildings to
yield a total inspection cost. The total cost estimate of under
$2 billion is shown in Figure Six. Compared with the total cost
for all public buildings, the costs of only subjecting Federal
buildings or hospitals to the regulation are significantly
lower. The costs for Federal buildings and hospitals are about
$37 million and $31 million, respectively.

Figure Six
Costs for Inspection and Notification

All Bldgs.
Hospitals Fed Fes Comm Total

Bldg w/ SMSTST
* $Insp/Bldg $2,208 $3,354 $2,026 $1,904

#Bldg 208 0 11,000 11,000 22,000
** Subtotal $0.5 $0 $22.3 $20.9 $43.2
Bldg w/ SM
*  SInsp/Bldg $1,648 $2,626 $1,298 $1,176

#Bldg 2,098 5,000 53,000 111,000 170,000
** Subtotal $3.5 $13.1 $68.8 $130.5 $212.5
Bldg w/ TSI
*  $Insp/Bldg $1,104 $1,534 $1,237 $1,237

#Bldg 7,352 9,000 144,000 389,000 541,000
** Subtotal $8.1 $13.8 $178.1 $481.2 $673.1
Bldg w/ NFACM
*  $Insp/Bldg $540 $583 $359 $359

$B1ldg 25,816 14,802 98,804 1,363,023 1,476,629
** Subtotal $13.9 $8.6 $35.5 $489.4 $533.5
Bldg w/ no AM
*  $Insp/Bldg $180 $224 $135 $135

#B1ldg 25,509 6,198 43,196 1,346,977 1,396,371
** Subtotal $4.6 $1.4 $5.8 $181.8 $189.1
** Total $30.6 $36.9 $310.5 $1,303.9 $1, 651.4

* Includes Inspection and Notificatim
** In Millions


approximately 100,000 schools, has reached about 60 percent after
five years. While protocols for bulk sampling and analysis are
standard and costs are low ($35 per sample) for this option, the
availability of qualified inspectors, bulk sampling laboratories
and other support capabilities would be insufficient at least in
the near future to meet demands, in part due to the ongoing
implementation of the AHERA schools rule.

Risk and Costs

Risk is not reduced by virtue of an inspection alone.
Subsequent voluntary measures, such as management planning,
maintenance practices and scheduled abatement activities, would
have to follow in order to reduce risk in actuality. (OSHA and
EPA NESHAP rules would govern some of these activities.)

EPA'S cost analysis for this scenario indicates that an
inspection program, as outlined above, for public and commercial
buildings would cost nearly $2 billion. Inspection costs per
building range from $150 to more than $2,500, depending upon
building size and other factors.

Policy Considerations

An inspection, either voluntary or mandatory, is necessary
to set a proper foundation for management planning, O&M programs
and the selection and implementation of other appropriate
response actions to reduce exposure and risk. A prior inspection
rule, in association with private sector incentives, did compel
Many schools to identify asbestos hazards and implement appropri-
ate response actions. It is conceivable, therefore, that an
inspection rule alone might achieve a fair degree of activity.
Inspection documentation and worker/occupant notification enable
knowledgeable occupants to "enforce" responsible manager
behavior.

On the other hand, an inspection inventory program
appropriate for schools may not be appropriate for public and
commercial buildings. First, these buildings, unlike schools,
are often characterized by multiple managers and diverse,
individual occupant agreements. An inspection inventory would
involve negotiations and agreements with individual tenants
addressing issues such as notification, education, cost, lost
productivity, and liability for damage. Perhaps more important,
current NESHAP and OSHA rules already presume that suspect
buildings materials are identified, sampled and tested before
disturbance, although this presumption may not be supported by
actual practice.

4. TARGETED REGULATION
This scenario would have EPA promulgate a rule which would

go beyond requiring inspection but which would stop short of a
full AHERA-type regulation in public and commercial buildings.

-30-


be used as the clearance level in buildings after a response
action. Estimates are also shown for the assumption that workers
are exposed to an average of 0.2 f/cc, the OSHA PEL, and 0.1
f/cc, the action level under the OSHA regulation. All of the
fiber levels selected for the sensitivity analysis (displayed in
Table 3) are taken from the OSHA RIA of June 20, 1986.2 In
particular, the choice of 0.01 f/cc is similar to the weighted
average fiber level that OSHA estimated for routine maintenance
in commercial and residential buildings.

Additional assumptions are as follows:

°o Custodians are assumed to have the age, race, and
proportion smoking distribution of the population of
U.S. workers in the manufacturing sector (blue
collar). The sex distribution, derived from Census
data, is 80% male and 20% female. They are assumed to
be exposed for 8 hours a day, 250 days per year. Their
breathing rate is assumed to be 1 m?/hr.

° According to the 1980 Census, 1,846,000 persons are
employed as custodians or other cleaners in buildings,
not including education-related buildings. (Education-
related buildings include public and private elementary
and secondary schools, colleges and universities, and
libraries.)

° Assuming that the proportion of custodial personnel
exposed to airborne asbestos is the same as the
proportion of buildings which contain asbestos, i.e.,
20% or 369,200 custodians are exposed.

ro) The data source used to estimate custodians’ exposure is
different from, and consequently not necessarily
consistent with, the data source used to estimate the
exposures of non-custodial building occupants.

Iv. RISK ANALYSIS METHODOLOGY

The effects of the presence of airborne asbestos in public
and commercial buildings are estimated in terms of the number of
lung cancer, gastrointestinal (GI) cancer and mesothelioma deaths
avoided. These figures understate the effects since they exclude
statistical cases of cancer which do not result in death. The

10 ues. DOL, Occupational Safety and Health Administration.
Quantitative Risk Assessment for Asbestos-Related Cancers.
Washington, D.C., 1983.



For prevalent building levels (i.e., levels not directly
associated with maintenance or renovation activities) as measured
by transmission electron microscopy (TEM)*, the most
comprehensive data source is a recently conducted EPA study in 43
asbestos-containing Federal buildings (Hatfield et al., 1987).
These buildings, which are covered by an asbestos management
program, were selected to represent a range of material
conditions but were not necessarily representative of all Federal
buildings. Air samples were collected at sites containing the
most seriously damaged ACM within each building. Other data were
obtained from 35 buildings in the United Kingdom (Burdett and
Jaffrey, 1986), 13 buildings in Ontario (Pinchin, 1982) and 3
sets of readings from Chatfield (1985). As stated earlier, the
data from these 94 buildings are from diverse studies and do not
represent a random sample. The values derived from them
represent the best available estimates.

Direct TEM measurements are available for 6 schools studied
by EPA's Office of Research and Development, 7 Canadian schools
reported by Chatfield (1985), 4 British schools reported by
Burdett and Jaffrey (1986), 6 schools in Ontario (Pinchin, 1982),
and from reanalysis of samples collected from 18 schools in an
earlier EPA study (Lee, 1987).

b. Characteristics

Prevalent airborne asbestos levels measured in the 94 non-
school buildings containing ACM ranged from 0 to 0.2 fibers per
cubic centimeter (f/cc) with an arithmetic mean of 0.006 f/cc.**
Levels measured in the 41 schools ranged from 0 to 0.1 £/cc with
an arithmetic mean of 0.03 f/cc.

* pifferent analytical methods, in particular, lead to fiber
concentration values that are not directly comparable. This
Section's assessment is based on measurements developed using
only one analytical method ~- transmission electron microscopy
(TEM) with a direct filter preparation technique. This method
is currently recommended by EPA and has been specified, in
current regulations for schools under AHERA, for "clearance
testing" following a response action. A second analytical
method, phase contrast microscopy (PCM), was used frequently
in the past and is still in general use, although it lacks the
analytic capabilities of electron microscopy, such as TEM.

** Note: To put these numbers in some context, the OSHA
permissible exposure limit for occupational exposures (an
8-hour, time-weighted average) is 0.2 optical f/cc; a National
Academy of Sciences study estimated that the average
"background" level of airborne asbestos in the U.S. was
0.00007 optical f£/cc.

-ll-


The second activity adds to the inspection requirement an
additional requirement that building owners have asbestos
Management plans developed for their buildings. As was done with
the inspection cost estimates, the cost of developing a
management plan for a public building was determined using a
procedure quite similar to that used for the schools rule RIA.
Appendix G of the RIA presents further details on this work.

First, the model public buildings were once again matched
with model schools on the basis of size. The hour estimates from
the matched model schools were used as a baseline estimate of the
public building's management plan hours. Second, the hour
estimates were decreased to reflect the fact that public building
models were smaller than their school matches. Third, the hour
estimates were adjusted to reflect the differences between the
project mixes in model schools and in model public buildings.

To illustrate, the public secondary school (using an outside
consultant) required 19 hours to prepare a management plan. The
Federal building, with its smaller size and different project
mix, was estimated to require 15.9 hours.

The estimated cost of developing an asbestos management plan
ranges from $1,080 to $1,350 per building with ACFM. (These
costs are rounded off to the nearest ten dollars.) The plan
development costs for buildings with only NFACM are considerably
lower, between $540 and $720.

The total cost is estimated to be over $3 billion for all
public buildings. The cost for the class of Federal buildings is
about $67 million. The cost is roughly $62 million if only
hospitals must meet this requirement. Figure Seven presents the
costs for inspection and management plan development for all
public buildings.

The third activity adds to the preceding approach a
requirement for the use of operations and maintenance (O&M)
programs. Once again, O&M costs developed for the schools rule
RIA were adjusted for the public buildings study on the basis of
model building size and model project mix.


The costs shown in Figure Ten incorporate the cost of
asbestos-containing waste disposal. This cost was based on the
proposed revisions to the NESHAP asbestos disposal standards.
This cost assumed that asbestos waste would be disposed of in
regular landfills as well as some hazardous waste landfills.
Should only hazardous waste landfills accept asbestos-containing
waste, the total discounted cost would increase by under
$2 billion. Thus, the total cost would be an estimated
$53 billion.

2. Federal Buildings As A Management Model

The first regulatory scenario considered in the report would
establish an asbestos management model of Federal buildings. A
variety of activities were considered as possible components of
this model. The economic analysis estimated costs for those
activities included in the full regulatory approach used for the
final AHERA schools rule. (The activities were inspections,
management plans, periodic surveillance, reinspection, response
actions, O&M, and transport and disposal of asbestos waste.)

These costs, shown in Figure Eleven, are discounted at
10% over 30 years. If Federal buildings were used as a
Management model, the total estimated cost would be under
$4 billion. The GSA and U.S. Postal Service have already
undertaken some asbestos identification and abatement
activities. The expenses for these activities have not been
subtracted from this cost estimate.

In addition, Figure Eleven does not present cost estimates
for such activities as relocation and reoccupancy studies,
evaluation of the efficacy of different abatement techniques, or
the development and analysis of new abatement and respiratory
protection schemes. It was not possible to precisely determine
costs for these activities. However, the preceding section on
enhanced, targeted technical assistance provides at least
approximations of the cost of some of these activities.

3. Inspection Rule

The second regulatory scenario discussed in the report would
require that all public buildings inspect for ACM and notify
occupants of any discoveries. This scenario would be modeled
after the 1982 Asbestos~In-Schools Rule. In the economic
analysis, the costs were estimated by multiplying the expected
unit inspection cost per building type by the number of buildings

5-20


In assessing exposure, building occupants may be categorized
into two groups. The first group consists of service and
maintenance personnel ("service workers") who, without an
awareness of the presence of ACM and adherence to special work
practices and controls, are subject to peak episodic exposures if
and when they disturb ACM. The second group ("other occupants")
consists of office workers, visitors and anyone else not involved
in renovation, repair, maintenance, or cleaning. Peak episodic
exposure for this group is likely to be less than for service
workers.

Whenever possible, public and commercial buildings are
compared with school buildings since most of EPA's experience
with asbestos in buildings to date has been with schools.
Comparisons, however, are limited. EPA has been advised, in its
discussions with school officials, building owners and managers,
and other affected groups, that types of public and commercial
buildings may differ from schools, as well as among themselves,
in several important ways (Price, Price, 1987). For instance,
the potential for damage or disturbance in schools might be
greater than in many other buildings, given the nature of the
occupants (children) and higher expected level of activity. In
addition, schools usually have centralized ownership and
Management, a common activity in all areas of the building, and a
period each summer when the building is vacant and available for
Major abatement activity. Further, schools represent a more
distinct building type or category, in relation to all other
public and commercial buildings. Because of these differences,
it is difficult to make comparisons between schools and nonschool
buildings with regard to exposure and risk.

2. PRESENCE
a. Data Sources

The estimates of presence of friable ACM in public and
commercial buildings are derived primarily from data obtained in
a statistically valid national survey (USEPA, 1984a). The target
population consisted of Federal government buildings, rental
apartment buildings with 10 or more dwelling units, and privately
owned buildings used primarily for nonresidential purposes.
Estimates for most types of nonfriable asbestos were excluded
from the survey. The estimates provided below are for friable
ACM only. Friable ACM refers to material which, when dry, may be
crumbled, pulverized, or reduced to powder by hand pressure.

The estimates of the presence of asbestos in schools were
obtained in 1983 from a national telephone survey which was
conducted in a statistically valid manner (USEPA, 1984b). Local
education authorities provided information about the presence and
amount of asbestos in schools based on inspections which they
conducted to comply with the Asbestos in Schools Identification
and Notification Rule, promulgated in 1982.

-7-


COST ESTIMATE: $75,000
SIME ESTIMATE: 8 months

STUDY 8b: SURVEY OF POPULATIONS EXPOSED TO AIRBORNE ASBESTOS IN
PUBLIC AND COMMERCIAL BUILDINGS

STUDY OBJECTIVE: To determine the number, sex, and age
distribution of people exposed to ACM in public and commercial
buildings. Ancillary information on occupation, smoking habits,
etc., would also be collected, if possible.

RATIONALE: The risk model for mesothelioma depends on time from
onset of exposure and cumulative exposure. The risk model for
lung cancer depends on cumulative exposure and age. Numbers of
people and age distributions in different types of buildings are
needed to estimate risk using these models.

APPROACH: This can be accomplished in several ways with various
levels of accuracy and cost.

A survey similar to EPA's 1984 survey would be conducted.
Buildings would be inspected for asbestos and information on
building occupants and visitors would be obtained through on-site
interviews. Approximately 1,250 buildings would have to be
inspected to identify 250 with ACM for the survey.

COST ESTIMATE: $4,000,000
TIME ESTIMATE: 2 years

STUDY 9: DEVELOPMENT OF A DECISION TOOL FOR DETERMINING WHETHER
A RESPONSE ACTION IS WARRANTED FOR A PARTICULAR BUILDING

STUDY OBJECTIVE: To develop an assessment tool for use by
building owners and managers in the context of an asbestos
Management progam that would allow them to determine what, if
any, abatement activities are appropriate for a particular
building.

RATIONALE: Due to a variety of technical sampling and analysis
considerations, air monitoring has not been demonstrated to be a
valid exposure assessment tool. In addition, none of the
Agency's previous efforts to develop and validate quantitative
and non-quantitative assessment methods have been successful. A
research study could be undertaken to address this need and
attempt to develop such a tool.

APPROACH: This study would consist of obtaining expert input
from the scientific community on current assessment methodologies
including short-term air monitoring. Several possible overall
assessment approaches would be identified and tested through
long-term air monitoring. Several phases of testing would
probably be necessary before identifying one or two specific

7-11


Figure Nine
Qosts for Inspections and O&M Programs

All Bldgs.
Hospitals Fed Res Comm ‘Total

Bldg w/ ACEM
* S$Insp/Bldg. $1,592 $1,959 $1,297 $1,239

SOBM/Yr. 1 $12,537 $13,191 $11,650 $11,228

$O&M, each later yr $4, 186 $4,612 $3,792 $3,333

$Per. Surv. $45 $45 $45 $45

$Reinsp. $80 $80 $48 $48
#Bldg. 9,675 14,000 208,000 511,000 733,000
**Subtotal $378 $1,068 $8,776 $19,975 $29,819
Bldg w/ NFAQM
* S$Insp/Bldg. $540 $583 $359 $359

SoRM/Yr. 1 $0 $0 $0 $0

$Per. Surv. $45 $45, $45 $45

$Reinsp. $80 $80 $48 $48
#Bldg. 25,816 14,802 98 , 804 1,363,023 1,476,629
**Subtotal $14 $10 $58 $758 $826
Bldg w/ ro AM
**Insp Subtotal $4.6 $1.4 $5.8 $181.8 $189.0
**Total $395.3 $1,079.3 $8,840.0 $20,915.1 $30,834.4

* Includes Inspectign and Notification
** In Millions

Figure Ten presents the possible costs of this approach.
Discounted at 10%, the total cost is over $51 billion. This
analysis assumed that all buildings will be used for 30 more
years. The timing and number of response actions assumed to
occur in this time period was based on the model response action
timelines developed for the final AHERA schools rule RIA. The
discounted cost for this scenario is under $4 billion for Federal
buildings, $674 million for hospitals, over $12 billion for
residential buildings, and almost $36 billion for commercial
buildings.

5-18


STUDY 7a: PREVALENT LEVELS OF AIRBORNE ASBESTOS FIBERS IN PUBLIC
AND COMMERCIAL BUILDINGS

STUDY OBJECTIVE: To establish national estimates of prevalent
airborne asbestos levels in nonschool buildings.

RATIONALE: Valid national estimates of prevalent airborne
asbestos levels in these building populations would allow EPA and
other Federal agencies to have an exposure basis for Federal
regulatory programs. These estimates would allow EPA to better
determine whether there is a need for regulations or other
programs to control exposure levels experienced by typical
building occupants in public and commercial buildings, and
whether these activities should be similar to those for schools.

APPROACH: Select a probability sample of U.S. public and
commercial buildings for air monitoring. The survey design will
be similar to the EPA 1984 survey and will include residential
apartment buildings, office buildings and other public facilities
(theaters, airports, restaurants, sports facilities). Federal
buildings are excluded from this project description and cost
estimates. It is anticipated that approximately 1,250 public and
commercial buildings would be inspected in order to select
buildings for air monitoring. Air monitoring would be conducted
in 250 public and commercial buildings. An average of 10 indoor
and 2 outdoor samples would be collected over a one-week period
in each of the 250 buildings. The samples would be analyzed by
TEM. The data collected would be used to estimate prevalent
levels in public and commercial buildings.

COST ESTIMATE: $14,000,000
TIME ESTIMATE: 2 to 3 years

LIMITATIONS/DISADVANTAGES: Although this study will help
determine whether or not there is a "problem" in the building
types (i.e., it will allow for risk estimates to be calculated),
it will not suggest specific regulatory or other program options
if a "problem" is found. That is, the efficacy of any potential
regulatory options would not be explicitly addressed by this
study. Also, it would only indirectly suggest how many buildings
have an airborne asbestos problem and would not necessarily
suggest which particular buildings present a significant hazard.

STUDY 7b: SERVICE WORKERS' EXPOSURE TO AIRBORNE ASBESTOS IN
PUBLIC AND COMMERCIAL BUILDINGS

STUDY OBJECTIVE: To estimate exposure to airborne asbestos
levels experienced by service workers during maintenance, repair
and cleaning activities, and to compare service worker exposure
levels to prevalent building levels.


TABLE 1

SEX, RACE, AND AGE DISTRIBUTION OF EXPOSED POPULATIONS

Proportion of Population (Decimal Share)

Characteristic Occupational Nonoccupational
SEX
Male 79 +49
Female +21 51
RACE
White +88 +88
Nonwhite +12 12
AGE
0-9 0 ~146
10 - 19 ol 174
20 - 29 +205 +176
30 - 39 +210 +139
40 - 49 +193 +108
50 - 59 +175 +099
60 - 69 +117 +083
70 - 79 0 +055
80 - 89 0 -020

Sources: For occupational: Research Triangle Institute, 1985
(August). Regulatory Impact Analysis of Controls on Asbestos and
Asbestos Products. Prepared for the Office of Pesticides and
Toxic Substances, USEPA, Washington, D.C., Appendix B. For
nonoccupational: U.S.DOC. 1980. U.S. Department of Commerce.
Statistical Abstract of the United States. Washington, D.C.:
Bureau of the Census. Table taken from "Regulatory Impact of
Controls on Asbestos and Asbestos Products. Volume I: Technical
Report." Draft report prepared for the Office of Toxic
Substances, USEPA, Washington, D.C., August 1987.

B. Non-custodial Occupants of Residential Buildings

Since it is not possible to determine whether, on average,
different levels of airborne asbestos are prevalent in the
various types of buildings, it is assumed that non-custodial
occupants of residential buildings are exposed to the same level
of airborne asbestos fibers as are occupants of nonresidential
buildings. As in the previous section, it is assumed in this
analysis that these residential structures have a 30-year
remaining life and that, in the absence of abatement activity,
the average airborne asbestos fiber level will more than double
from the current level, during the remaining useful life of the
building.


proportion of total risk attributable to exposure in public and
commercial buildings would be 18 percent (18/99).

RESULTS

Table 2 shows that the percentage of total mesothelioma risk
attributable to exposure in public and commercial buildings
ranges from 61 percent for a lifetime post-school exposure at
levels twice those in schools, to 2 percent for a 5 year post-
school exposure at levels one tenth those in schools. When
airborne asbestos levels in public and commercial buildings are
no higher than those in schools, exposure in public and
commercial buildings contributes less than half of the
mesothelioma risk. This finding is consistent with the risk
model for mesothelioma since incidence increases with time from
onset of exposure, placing additional weight on exposures early
in life.

Exposure in public and commercial buildings contributes more
to lung cancer risk than to mesothelioma risk. A lifetime
exposure in public and commercial buildings at twice the exposure
level in schools contributes 87 percent of the risk. The
contribution is reduced to 5 percent for a 5 year post-school
exposure at levels one tenth those in schools. The risk model
for lung cancer depends only on total exposure (concentrations
multiplied by duration), therefore long post-school exposures
dominate the 13 years of exposure in schools.

The results in Table 2 do not consider exposure in
residential buildings which could occur concurrently with
exposure in schools and/or nonresidential public and commercial
buildings. Residential exposure is discussed separately below.


Occupational Exposure to Asbestos: Occupational Safety and
Health Administration Title 29 CFR 1910.1001 (General
Industry Standard).

The general industry standard, which affects all private
sector workers in occupations other than construction,
establishes provisions similar to those of the construction
standard.

The standard also became effective on July 20, 1986.


addressed. First, the existing Federal requlations set accept-
able exposure levels in order to protect public health. If these
levels are indeed adequate for their purposes, are the mandates
stringent enough to ensure that the regulated parties actually do
comply with them? Since asbestos is a human carcinogen and EPA
risk models (based upon National Academy of Sciences findings)
assume there is no safe level of exposure, there is inevitably
some residual risk even if all the regulatory standards are

met. In this instance, OSHA determined that its rules
"substantially reduced" risks associated with earlier

standards. At the same time OSHA acknowledged that, given
considerations of feasibility, workers exposed to asbestos at the
PEL level "remain at significant risk." EPA has not attempted to
revisit this determination, which was promulgated by OSHA in 1986
after nearly three years of consultation, comment, and public
hearings.

The second way to address this question of adequacy is to
ask what the actual exposure is to workers and the public with
these regulations in effect. No regulation is self-executing.
What is especially difficult with regard to asbestos exposure is
its episodic nature. People can go for years with little or no
exposure to asbestos and then receive a significant dose because
of a major disturbance to asbestos-containing material that may
result from either ignorance or negligence.

To prevent many of these episodes, asbestos identification
and control is required by those who are subject to these
rules. Education of the regulated parties or some other means of
inducing compliance with identification and control is necessary
if full protection is to be achieved under the OSHA standards,
and EPA worker protection and NESHAP rules.

3. THE EFFICACY OF AN "ACCEPTABLE LEVEL" STANDARD

Under the traditional approach to addressing a chemical
hazard, EPA might identify and publish an "acceptable level"
standard of exposure to asbestos-containing materials in
buildings, based on a process such as air monitoring. The Agency
would assess the risks, establish acceptable levels of exposure,
require periodic monitoring, and identify proper engineering
controls which would be implemented if those limits were
exceeded.

Such an approach would target abatement and removal actions
in those situations where such actions are clearly necessary,
based on information which approximates actual exposure
information. However, such an approach appears not to be
practical at this time for the problem of asbestos in buildings,
for the following reasons:

First, some of the exposure of persons to asbestos in

buildings may result from episodic events, such as repair work,
or the accidental jarring of the asbestos material by activities

-20-


Table 2. Estimated percent? of buildings with asbestos-containing
friable materials by type of material and type of building
(95 percent confidence limits in parentheses)

Type of asbestos-contain

nq friable material

Type of building Sprayed- or Ceiling Pipe/boiler Any
trowelled-on tile insulation©® | material
Federal 16% 2.0 25% 39%
government (<33%) (0.3-3.6%) (8-41%) (28-48%)
Residential (10+ 18% 0.5% 44% 59%
rental units) (10-27%) (<1.7%) (26-62%) (45-748)
Private 43 ob 12% 168
nonresidential (<9%) (2-22%) (9-23%)
All buildings 5% 0.1% 16% 20%
combined (0.5-10%) (<0.2%) (7-25%) (14-27%)

amay not equal percentages calculated directly from Table 1 due
to rounding in Table 1 and in this table.

Pot 110 sampled buildings in this category, none had asbestos-

containing ceiling tile.

Csampled damaged or exposed material.

However, some small number of buildings
in this category may have asbestos-containing ceiling tile.


Table 3. Estimated number of buildings (in 1,000's) in the
continental U.S. with any asbestos-containing friable
material, by condition of the asbestos-containing
friable material (ACFM) and by type of building. (See
notes below.)

(95% confidence intervals are shown in parentheses)

Condition of ACFM
Significantly
Building Type Any Damaged Damaged
(Total in 1,000's)
Federal 14 5 <0.5
(8-20)
(35)
Residential 208 80 7
(10+ rental units) (119-297)
(350)
Commercial 511 416 310
Nonresidential (274-748)
(3,221)
All Buildings 733 501 317
(499-966) (201-801) (<679)
(3,606)
Notes:
Asbestos-containing friable material has more than 1%

asbestos.
Damaged is defined by condition codes of 3, 4, or 5.
Significantly damaged is defined by a condition code of 5.
Missing condition codes have been imputed to get national totals.
Columns may not add due to rounding.
<0.5 indicates few or no occurrences in the sample; the actual
value in the universe is small and cannot be estimated from
the survey data.


Periodic surveillance and reinspection of ACM are generally
viewed as part of an O&M program. However, these activities must
also be conducted for buildings with only nonfriable ACM, i.e.,
those buildings that do not require O&M cleaning. Therefore,
costs for periodic surveillance and reinspection were considered
separately from O&M expenses in this analysis. The final schools
rule requires that periodic surveillance occur semi-annually. It
was estimated to cost $45 per public building. Reinspection of
the ACM is to take place every three years. One-time costs vary
from $48 to $80. It was assumed that the timing of periodic
surveillance and reinspections was the same for all buildings.

A variation of the preceding activity includes only
requirements for inspections and operations and maintenance
programs. It does not require management plans. Figure Nine
presents the costs for inspections and O&M programs. Once again,
the analysis assumed that O&M programs would continue for thirty
years. The estimated cost, discounted at 10%, is under
$31 billion for all public buildings with friable ACM. Federal
buildings and hospitals would incur a cost of over $1 billion and
$395 million, respectively. Residential buildings and commercial
buildings would incur costs of approximately $9 billion and
$21 billion, respectively.

The final activity requires that building owners perform the
same actions that are required of schools under the final AHERA
schools rule. In other words, this activity incorporates
inspections, management plans, O&M, and all appropriate abatement
actions.

The abatement activity that is appropriate for a given area
of ACM depends on the type and condition of that ACM. Those
activities considered in the final schools rule include repairs,
encapsulation, enclosure and removal. The distribution of ACM by
type (surfacing material (SM) and/or thermal systems insulation
(TSI)) was estimated with information from the AIBS. The
proportion of ACM in each possible condition, or "damage",
category was also estimated with information gathered from the
AIBS.

5-17


a. Approach

Lifetime risk estimates are developed representing a total
exposure to asbestos in schools from age 5 to age 18 followed by
exposure in public and commercial buildings for periods ranging
from five years to lifetime. Risk attributable to exposure only
in public and commercial buildings is calculated separately and
expressed as a percentage of the risk from the total exposure.
This analysis evaluates the risk attributable to exposure in
public and commercial buildings that occurs after school age and
obviously simplifies a complicated situation. (For instance, it
is assumed that children of school age are not exposed to
asbestos in any public and commercial buildings before they are
18 years of age.)

b. Results

Risk is analyzed first under scenarios in which airborne
asbestos levels are assumed to be the same in public and
commercial buildings as in schools. In these scenarios,
elimination of asbestos exposures in schools would substantially
reduce risk for populations later exposed in public and
commercial buildings. For example, for mesothelioma, the
proportion of total risk attributable to exposure in public and
commercial buildings ranges from 19 percent for 5 years' exposure
to 43 percent for lifetime exposure -- less than half the total
risk. The remaining risk is attributed to exposure in schools.
The analysis suggests that the elimination of asbestos exposure
in schools could have a particularly pronounced effect on the
risk of contracting mesothelioma. Public and commercial
buildings contribute proportionately more to the total risk of
lung cancer (28 percent for 5 years' exposure, 76 percent for
lifetime exposure). The different results for mesothelioma and
lung cancer reflect the underlying risk models. In the
mesothelioma model, risk depends on the time since onset of
exposure and places additional weight on exposures early in
life. The relative risk model for lung cancer depends only on
total exposure (concentrations multiplied by duration); therefore
long post-school exposures overwhelm the effect of the 13 years
of exposure in schools.

The proportion of risk attributable to exposure in public
and commercial buildings declines if airborne asbestos levels in
these buildings are lower than in schools. If such scenarios are
realistic, controlling exposures in schools may have an even
greater impact on total risk than when airborne levels are the
same. Under the scenario that prevailing airborne asbestos
levels are one half those in schools, a lifetime exposure in
public and commercial buildings contributes 28 percent of the
mesothelioma risk and 62 percent of the lung cancer risk. If
levels are as little as one-tenth those in schools the
contribution is 7 percent for mesothelioma and 24 percent for
lung cancer. Conversely, if airborne asbestos levels in public
and commercial buildings are twice those in schools, exposure in

-15-


APPENDIX 3
EXISTING FEDERAL REGULATIONS

Four Federal asbestos regulations bear primary responsi-

bility for protecting the general public and abatement personnel
during renovation or demolition of buildings:

°

National Emission Standard for Hazardous Air Pollutants
(NESHAP): Asbestos Regulations, U.S. Environmental
Protection Agency Title 40 CFR Part 61.

The NESHAP applies to building renovation and demolition
involving friable asbestos-containing materials. The
building owner or operator must provide written notice of
intention to renovate or demolish to EPA and follow basic
asbestos emission control procedures (i.e., use wet methods,
handle carefully). Transport and disposal practices prohibit
visible emissions into the air.

The NESHAP, first published in 1973, was amended last on
April 5, 1984, and is currently being revised.

Occupational Exposure to Asbestos: Occupational Safety and
Health Administration Title 29 CFR Part 1926.58 (Construction
Standard).

The construction standard applies to private sector workers
engaged in demolition or salvage of structures, asbestos
abatement, renovation, emergency cleanup and transportation
and disposal. It establishes a permissible exposure limit
(PEL), currently 0.2 fibers per cubic centimeter; defines a
"regulated area"; and provides standards for exposure
monitoring, achieving compliance with the PEL, proper
respiratory protection, protective clothing, hygiene
facilities and practices, communication of hazard to
employees, medical surveillance and recordkeeping.

The construction standard became effective on July 20,
1986, after a lengthy rulemaking process.

Toxic Substances; Asbestos Abatement Projects, U.S.
Environmental Protection Agency Title 40 CFR Part 763 Subpart
G (Worker Protection Rule).

The worker protection rule essentially extends the
protections of the OSHA construction standard to public
sector employees.

The current rule became effective on March 27, 1987,

replacing a prior rule first effective on July 12, 1985, and
issued as final on April 26, 1986.

3-1


II. RISK ASSESSMENT
A. HAZARD

Several life-threatening or disabling diseases, including
lung cancer, mesothelioma, gastrointestinal cancer and
asbestosis, can be caused by exposure to airborne asbestos,
particularly at the high exposure levels experienced historically
in occupational settings. In contrast to many toxic substances
for which health effects are inferred from animal studies, the
health effects of exposure to asbestos have been directly
substantiated in epidemiological studies. The studies have been
conducted for the most part on populations occupationally exposed
to high airborne concentrations of asbestos for relatively long
periods of time (CPSC, 1983).

Lung cancer has been associated with exposure, at
occupational levels, to all of the commercial asbestos fiber
types. It is responsible for the largest number of deaths from
exposure to asbestos. Excess lung cancer has been documented in
groups involved with the mining and milling of asbestos and the
Manufacture and use of asbestos products (See NRC (1984) and
USEPA (1986) for summaries of studies and literature
references). Cigarette smoking and asbestos have a strong
synergistic interaction in the development of lung cancer; i.e.,
asbestos exposure appears to multiply the risk of lung cancer in
smokers. Exposure to asbestos increases the lund cancer rate in
non-smokers by a factor of about 5; risk is increased by a factor
of about 50 for smokers exposed to asbestos (Hammond et al.,
1979).

Mesothelioma, a rare cancer of the membrane that lines the
chest and abdominal cavities, has been strongly associated with
exposure to asbestos. An estimated 1600 cases of mesothelioma
occurred in the United States in 1980 (NRC, 1984). This estimate
corresponds to a cumulative mesothelioma incidence of less than
0.08 percent. Other data suggest a mesothelioma risk as low as
0.0002 percent. However, the incidence of mesothelioma is much
greater among asbestos workers, approaching as high as 2 percent
among asbestos miners and textile workers and as high as 10
percent among workers who manufactured asbestos-containing gas
masks (Berry, 1986; NRC, 1984). The risk of contracting
mesothelioma appears to be independent of smoking. Mesothelioma
is usually fatal within two years of diagnosis.

Asbestosis is a serious chronic disease involving fibrosis
of the lung and pleural tissues. There is no effective treatment
and the disease is often disabling or fatal. Asbestosis has been
observed mainly after high occupational exposures to asbestos.

Short-term occupational exposures (e.g., between one and two
years) also have been shown to increase the risk of lung cancer
and mesothelioma (USEPA, 1980; Seidman et al., 1979; Seidman,
1984). In addition, excess incidence of mesothelioma has been

-4-


The costs in Figure Five and in the following text are costs
incurred by the Federal government only. Costs incurred by State
and local governments, and by building owners and managers, are
not presented for several reasons. Most important, these costs
were not estimated due to a lack of reliable data with which to
quantify these costs.

The first type of assistance attempts to ensure that building
maintenance and asbestos abatement personnel are better protected
when working with or around asbestos. Developing model O&M
practice programs and providing and promoting guidelines for the
sampling of suspect materials for asbestos is estimated to cost
approximately $500,000 in total. Funding case studies of
asbestos management plans for various building types would cost
roughly $150,000 for every four case studies. Finally, helping
various groups establish and offer approved training courses
would cost roughly $50,000 per course. Costs were not estimated
for a voluntary inspection program or for additional compliance
enforcement activities.

Figure Five
Costs of Providing Technical Assistance

Assistance Categories and Tasks Estimated Cost

1. Protect Service Personnel

° develop model programs $500,000 each

° publish case studies $150,000 for 4 studies
2. Advise Building Owners

° develop voluntary standards $250,000 each
3. Improve Public Understanding

fo) publish citizen's guide $100,000 each

° conduct symposia $50,000 each
4. Facilitate State and Local Activity

° set up contractor certification

and other models up to $100,000 each

5. Improve Asbestos Control Information

° conduct new studies up to $61 million

° establish and run clearinghouse up to $5 million/year
6. Increase Abatement Training

° set up extra training centers up to $550,000 per

center
° set up extra courses $50,000 each

5-9


buildings and help identify appropriate control strateqies for
other public and commercial buildings.

On the other hand, EPA's air monitoring study indicates that
relatively low prevailing airborne asbestos levels exist in
sampled Federal buildings. Further, some Federal agencies, like
some public and commercial building managers, might resist a
Mandatory program, particularly without better information on
exposure and risk, especially if costs are high. Finally, the
Federal government could be criticized for protecting Federal
employees before other public and private employees or the
general public.

3. INSPECTION RULE

This scenario would have EPA promulgate an inspection
inventory and notification requirement for public and commercial
buildings that is similar to EPA's 1982 Asbestos-In-Schools
Rule. Under this rule, building owners would be required to
inspect for friable and nonfriable asbestos materials, sample and
analyze suspect materials, document results and provide
notification.

An inspection component (locating and testing suspect
materials) is the first critical step in a proper asbestos
Management plan. The location of ACM must be determined before
appropriate worker protection and work practices can be
implemented or before appropriate response actions can be
identified to control or eliminate exposure. To inspect, one may
either:

° Conduct a complete inspection of the building to develop
an inventory of ACM at the time the management program
is initiated, as is contemplated by this option; or

Test suspect material prior to a scheduled activity
(such as maintenance, repair, renovation) that may
disturb the material.

A comprehensive building inspection inventory consists of
four components: (1) reviewing building records for references
to asbestos used in construction or repairs; (2) inspecting
materials throughout the building to identify those which may
contain asbestos; (3) sampling suspect materials for laboratory
confirmation that asbestos is present; and (4) mapping the
locations of all confirmed or suspected asbestos. Relevant
documents should be retained. If asbestos is not present, no
action beyond proper documentation is necessary.

Feasibility

The scale of the undertaking would be considerable, as an
estimated 3.6 million buildings are involved. For comparison,
compliance with the 1982 school inspection rule, which included

-29-


Microscopy (PCM) or Transmission Electron Microscopy (TEM). The
per sample cost using PCM analysis is roughly $30, while the cost
using TEM analysis is about $400 per sample. These costs were
established by EPA during the final AHERA schools rule
preparation. (It should be noted that PCM does not actually
measure asbestos fibers, but rather all fibers. Furthermore, it
does not measure thin or small fibers.) The analysis recognized
that TEM analysis of an air sample makes up almost all of the
cost of collecting and analyzing an air sample.

The second step was to determine the number of air samples
taken per building. No data were available to allow an empirical
estimate of the reguired number. Based on expert judgment, it
was concluded that five air samples per project area per building
was the most reasonable sampling rate to use. In order to
estimate the cost of alternate sampling rates, it was also
decided to use sampling rates of one sample per project area and
one sample per building.

The three sampling rates were then multiplied by the number
of project areas per model building (shown in Figure Three) to
yield the total number of samples per building. Using the
highest sampling rate as an illustration, a Federal building,
with twelve project areas, would require 60 air samples. A model
residential building, with seven project areas, would require
35 air samples. A model commercial building, at seven ACM
project areas, would require 35 samples.

The resulting sample counts per building were then multiplied
by the PCM- and TEM~based unit costs to estimate the cost per
building. The per building costs were then multiplied by the
estimated number of public buildings, by building class, with
friable asbestos-containing materials. This yielded the total
estimated cost of a one-time air sampling and analysis effort.
Depending on whether PCM or TEM is used, the total cost of a
one-time sampling effort would be either $25 million or
$336 million for all Federal buildings, $218 million or just
under $3 billion for all residential buildings, and $537 million
or just over $7 billion for all commercial buildings. These
estimates are rounded to the nearest unit.

Figure Four shows the estimated cost of this analysis: some
$780 million using PCM and over $10 billion using TEM. The total
cost of sampling all buildings with ACM (friable or nonfriable)
would be three times as high. Should air sampling occur
semi-annually, with five samples per ACM area, costs for each
type of analysis would be doubled. Reducing the sampling rate to
one sample per ACM area would yield one-time and annual TEM
analysis costs of $2 billion and $4 billion, respectively, for


Table 3. THE PROPORTION OF LIFETIME RISK ATTRIBUTABLE TO
EXPOSURE IN PUBLIC AND COMMERCIAL BUILDINGS RELATIVE

TO TOTAL RISK FOR INDIVIDUALS WHO HAVE A LIFETIME
EXPOSURE IN RESIDENCES FROM AGE 5, AN EXPOSURE IN

SCHOOLS FROM AGE 5 TO AGE 18,
IN NONRESIDENTIAL BUILDINGS FROM AGE 18.

Airborne Asbestos Levels in
Nonschool Buildings Relative

AND A LIFETIME EXPOSURE

Percent Risk Attributable to
Nonschool buildings

to Schools
Mesothelioma Lung Cancer
Twice 89 96
Same 81 92
One half 68 85
One sixth 41 65
One tenth 30 52



or for determining the efficacy of actions taken. Specifically,
more information would be useful in:

1.

Developing improved assessment tools for use by
building owners and managers in the context of an
asbestos management program that would allow them to
determine what, if any, abatement activities are
appropriate for a particular building. The Agency's
previous efforts to develop and validate quantitative
and non-quantitative assessment methods have not been
successful. A research study could be undertaken to
address this need and to attempt to develop a valid
assessment tool. However, due to the complexities
involved and technical sampling and analysis
considerations, it is impossible to estimate the cost
or duration of such a study or to predict its success
at the present time.

Assessing the difference in risk between (indoor)
public and commercial building exposure and outdoor
ambient air exposure, which includes:

Oo The levels of prevalent airborne fibers in public
and commercial buildings; and

© The number and age distribution of persons exposed
to ACM in public and commercial buildings.

This information would be needed to determine whether
exposure to air in public and commercial buildings
poses risk from asbestos exposure that is measurably
greater than that posed by outdoor ambient levels,
and if so, to what extent. (Studies 6, 7a, 8a and 8b
in Appendix 7 address this limitation.)

Assessing whether exposure differentials exist across
different types of buildings (e.g., highrises versus
garden apartments) or among different areas within
buildings (e.g., boiler rooms versus office space).
This would allow for different technical assistance
or regulatory actions to be taken for different
buildings types or areas within buildings. (Study 6,
study 7a and its variations, 7c, 7d, and 7e address
this limitation.)

Assessing the presence, range and significance of
elevated exposures to service workers while doing
maintenance, repair, and cleaning activities as
compared to prevalent level exposures for office
workers and other building occupants. This would
provide information on the service worker population
to determine whether separate control programs should
be developed for that group. (Studies 6 and 76
address this limitation.)

-22-


3

to divert the limited supply of these professionals from the
implementation of AHERA, we need to encourage an increase in the
supply of these qualified professionals.

Assistance to building owners could shape, guide, and
enhance the present private sector activity. For instance,
identification of proper operations and maintenance activities
should result in immediate risk reduction for that segment of the
population which may be receiving the largest exposure--the
custodial staffs in these buildings. It may also prevent
accidental damage or extensive deterioration which could expose
other building occupants. Guidance on how to avoid imminent
hazard conditions should greatly reduce the risks from asbestos
in these buildings.

Based on our experience with a variety of activities
conducted under the Asbestos School Hazard Abatement Act and
AHERA we believe that $2 million a year for three years would be
sufficient to complete this goal.

(2) Focus attention on thermal system insulation
asbestos.

This report indicates that more public and commercial
buildings contain thermal system insulation asbestos than other
kinds of friable asbestos. In addition, this thermal system
insulation is generally in worse condition and in higher
concentrations than the other asbestos found in public and
commercial buildings. This asbestos represents a potentially
serious health hazard to the custodial and maintenance staff, who
work with and around this material on a regular basis. Finally, in
contrast to other kinds of asbestos, thermal system insulation is
usually easier to repair, encapsulate, or, where appropriate,
remove. A $698,008 investment for each of three years should be
sufficient to complete the task of developing and providing proper
guidance for dealing with thermal system insulation.

(3) Improved integration of activities to reduce imminent
hazards.

More can be done to avoid high peak exposures associated
with improper or poorly timed asbestos removal activities. It is
clear that the recent attention on asbestos in buildings has
increased the number of removals, the number of resulting NESHAPs
notifications, and the need for additional compliance assistance.

There is a need to develop additional ways to coordinate
asbestos-related programs in order to increase the effectiveness
and efficiency of our existing asbestos control efforts and
address legitimate imminent hazards. In particular, we could
institute a field program in which notification and inspection


APPENDIX 4
CALCULATION OF PROPORTIONAL RISK
METHODS

This appendix presents a model which formulates and compares
the percentage of total risk which might be attributed to
asbestos exposure in nonresidential public and commercial
buildings with the percentage which might be attributed to
exposure in schools. Arbitrarily selected levels of airborne
asbestos fibers are applied to illustrate the sensitivity of the
model.

The percentage of mesothelioma and lung cancer risk
attributable to exposure to asbestos in public and commercial
buildings is estimated from Table 6-3 of the Airborne Asbestos
Health Assessment Update (USEPA, 1986). Using an arbitrarily
chosen exposure level, Table 6-3 gives the lifetime risks per
100,000 persons of death from mesothelioma and lung cancer from
continuous asbestos exposures according to age and duration of
exposure. These lifetime risks were calculated using a lifetable
approach with U.S. general population death rates and the
absolute risk model developed by Nicholson (USEPA, 1986) for
mesothelioma and relative risk model for lung cancer.

The Health Assessment Update table was expanded here (Table
1) to include two additional ages at onset of exposure (age 5 and
age 18), and three additional durations of exposure (18, 23, and
33 years). The new values, which are approximations obtained by
linear interpolation, were plotted with the original tabulated
values to check that they were sufficiently accurate for the
proportional analysis.

Proportional risk is calculated by determining the risk due
to exposure in public and commercial buildings and dividing it by
the total risk due to the combined exposure in schools plus
public and commercial buildings. The resulting percentage
represents the proportion of total risk that would remain if
exposure in schools were completely eliminated and exposure
occurred only in public and commercial buildings. The result
does not depend on the absolute level of airborne asbestos, only
on the level in public and commercial buildings relative to the
level in schools. Proportional risk does not measure the
absolute magnitude of the risk (i.e., number of deaths).
Instead, it indicates which exposure sources contribute most to
total risk. Proportional risk may be useful in helping to
determine priorities for reducing exposure.

Using this sensitivity analysis, if exposure levels in
public and commercial buildings are the same as exposure levels
in schools, then the values needed for the proportional risk
calculation can be read directly from Table 1. (See the example
below.) If exposure levels in public and commercial buildings

4-1


Increased compliance with existing Federal regulations
(OSHA, NESHAP and EPA worker protection) might be achieved
through additional education, enforcement and coordination
activities (Price, Price, 1987). EPA could fund and publish O&M
case studies or model management plans for major types of public
and commercial buildings, such as hospitals, airports and
highrise office buildings.

In addition, the Agency might provide incentives for
encouraging asbestos information and training centers and other
instructional programs across the Nation to offer O&M training
courses, and might increase its support of O&M training programs
among unions, professional associations and training
organizations.

b. Advising the building owner and manager

EPA could develop and publish guidelines for inspection,
management planning, hazard assessment, the completion of
response actions, and other appropriate control activities,
perhaps using relevant aspects of the AHERA schools rule as a
model or as voluntary standards for building owners and
Managers. Further, EPA could establish a voluntary control
program in cooperation with building owner/manager associations
and provide additional grants to States for inspection and
management planning programs.

c. Improving public understanding

EPA could publish a citizen's guide on asbestos hazard and
risk and encourage or sponsor symposia, teleconferences, national
meetings, and other similar media activities to increase public
understanding of asbestos hazards and relative risks.

d. Facilitating State and local activity

EPA could develop and distribute administrative models for
various types of State control programs, including inspection and
management planning. (The EPA's model contractor certification
program for States has provided the basis for many current State
and local programs.) The Federal government could help States
implement voluntary asbestos management programs which utilize
existing mechanisms such as building permits or tax credits. The
Agency might also help States create and implement programs which
train and accredit asbestos control personnel, which support
regulatory or voluntary asbestos management programs, or which
provide technical or financial assistance to building owners and
Managers.

e. Promoting new technology and research

At this time, the Agency lacks adequate information on: the
number of persons exposed to ACM in public and commercial
buildings and the levels of exposure in these buildings; the

-25-


the main body of this study are fiber counts derived using direct
Transmission Electron Microscopy (TEM). This method counts
fibers much smaller than those counted using light (optical)
microscopes, and thus produce a much higher total fiber count.
The risk models were developed from optical fiber data, which
counts only the larger fibers, and at present there is no
accepted method for converting direct TEM measurements into
optical fiber data. The data from EPA's school study were
collected by a particular method (indirect TEM), which can be
converted into light microscope units.® this allows us to use
the fiber levels generated in the school study as input to the
previously developed health models, which enables us to predict
mortality.

Despite the paucity of the data on fiber levels, this
sensitivity analysis was considered a useful exercise, since both
the health models and population estimates are well developed.

III. ESTIMATES OF TOTAL POPULATION EXPOSED

A. Non-custodial Occupants of Government and Nonresidential
Buildings

In this analysis it is assumed that non-custodial occupants
of government and nonresidential buildings are exposed to the
same levels of airborne asbestos. The range of airborne
concentrations currently in nonresidential public buildings with
ACFM prior to abatement are adjusted here to account for the
deterioration of asbestos-containing building materials caused by
vibration, vandalism, age, and moisture damage over time. Using
the standard economic assumption that a building has a useful
life of fifty years before requiring major renovation or
replacement, and further assuming that no major cycles have
occurred in building construction, the average age of public
buildings can be assumed to be 20 to 30 years. On average these
buildings_can be expected to last an additional 20 to
30 years. For this analysis, a remaining building life of
30 years has been assumed.

Assuming that building materials deteriorate proportionately
with building age,° by the end of the building life, the airborne

6 op. Cit. USEPA 1986 (June).

7 This assumption is consistent with the assumption made for
the asbestos-in-schools rule. U.S. EPA, Office of Toxic
Substances. Final Schools Rule: Asbestos Hazard Emergency
Response Act Regulatory Impact Analysis. September 1987.

8

This assumption of proportional deterioration with building
age has been used in other EPA reports. See Op. Cit. USEPA
1984 (August). ———


means that there is only a five percent chance that actual values
fall outside of this range.

fo)

About 20 percent (14-27 percent) of all buildings have
some type of asbestos-containing friable material. This
represents 733,000 (499,000-966,000) buildings.

Five percent (0.5-10 percent) of buildings have asbestos-
containing sprayed- or trowelled-on friable material,
accounting for 192,000 (18,000-365,000) buildings.

Sixteen percent (6-25 percent) of buildings, or 563,000
(239,000-888,000) buildings have asbestos-containing pipe
and boiler insulation. This material is generally
limited to closed, restricted-access areas rather than
offices or other highly-used space.

The amount of sprayed- or trowelled-on asbestos-
containing material is estimated at 1,184 million square
feet (406-1,961 million square feet).

The average percent of asbestos content (weighted by
square footage of material) in asbestos-containing
sprayed- or trowelled-on friable material was 14 percent
(7-21 percent). For asbestos-containing pipe and boiler
insulation material, the average percent asbestos content
was 70 percent (66-74 percent).

Rental residential and Federal government buildings had a
higher incidence of asbestos-containing friable materials
than private nonresidential buildings. These two types
of buildings account for 11 percent of the total
population of buildings.

very few buildings had asbestos-containing ceiling tile
(less than 0.5 percent of buildings). The square footage
of asbestos-containing ceiling tile is also low, an
estimated 3.6 million square feet (less than 7.8 million
square feet), and the average asbestos content of the
asbestos-containing ceiling tile that was found was quite
low, averaging three percent (less than 8 percent).

Buildings built in the sixties are more likely to have
asbestos-containing sprayed- or trowelled-on friable
material (15 percent of such buildings do), than other
buildings. It appears that the extensive use of
asbestos-containing sprayed-on friable material would
have continued and perhaps increased in the 1970's had
not the EPA banned the use of those materials for all but
decorative purposes in 1973. In 1978, the EPA banned all
other uses of these materials. Older buildings are more
likely than newer ones to have asbestos-containing pipe
and boiler insulation.

1-3


4. Targeted Regulation

As discussed in the report, this scenario would allow EPA to
selectively issue regulations to address the key ACM areas or
materials where exposure and risk are greatest. The Agency could
effectively issue regulations on any combination of asbestos
activities and/or building types shown in Figure Eleven. One
possible rule would be the inspection rule discussed immediately
above.

Another rule, requiring the performance of O&M work, would
cost an estimated $29 billion if all public buildings with
friable ACM performed O&M for the next 30 years. If this rule
applied only to residential buildings, for example, the cost
would be an estimated $9 billion. These costs are taken from
Figure Nine, and are derived by subtracting the inspection costs
from the total costs.

5. Sequential Requlation

As opposed to the targeted regulation scenario, the
sequential regulation scenario involves a gradual extension over
time of the types of public buildings subject to an asbestos
regulation. As an illustration, Federal buildings could be the
first building set required to act under a new rule. As
described earlier in this appendix, the estimated Federal
building cost of a full regulatory response to asbestos, i.e.,
from inspection through removals, would be just under $4 billion.

The next building set to be regulated could perhaps be
hospitals. The total count of these buildings is relatively
small, so it would be fairly easy to determine the long-term
effect of the regulations. The cost of a full regulatory program
for hospitals would be roughly $700 million.

6. Immediate AHERA-Type Requlation

This scenario is identical in nature to the final AHERA
schools rule in terms of the requirements made of building owners
and managers. Such a scenario would require the full set of
activity items shown in the first column of Figure Eleven and
would cost an estimated $51 billion. This cost does not attempt
to subtract the value of ongoing Federal building abatements or
the value of ongoing private sector abatement work. The costs of


RESIDENTIAL EXPOSURE

The preceding analysis does not consider exposure to
asbestos in residences. AHERA defines public and commercial
buildings to include residential buildings of 10 units or more.
The number of people who are exposed to asbestos in residential
buildings and the level and length of exposure are not known.
U.S. Census data indicate that residential buildings of 10 units
or more house approximately 7 percent of the population. Schools
and nonresidential public and commercial buildings are occupied
by a much larger proportion of the population.

For individuals who are exposed to asbestos in residences in
addition to schools and nonresidential buildings, the proportion
of total risk attributable to nonschool buildings is increased.
The extreme case is an individual who is exposed throughout life
to asbestos in residences. Table 3 shows the proportion of total
risk contributed by nonschool buildings when an individual is
exposed in both residence and school from age 5 to 18, and in
both residence and nonresidential public and commercial buildings
from age 18 until death. The time spent per day in residences is
assumed to be twice the time spent per day in schools or in
nonresidential public and commercial buildings. For
mesothelioma, the contribution from nonschool buildings ranges
from 89 percent, if airborne asbestos levels in nonschool
buildings are assumed to be twice those in schools, to 30 percent
if airborne asbestos levels in nonschool buildings are assumed to
be one tenth those in schools. For lung cancer the corresponding
contributions are 96 percent and 52 percent.

The percentages in Table 3 do not include exposure in the
period from birth to age 5 because, as stated above, the
proportional risk calculations are based on risk estimates for
constant exposure levels. The calculations in Table 3 already
rely on an approximation to incorporate a change in exposure
level from the period of age 5 to age 18 to the period after age
18. A second approximation to incorporate birth to age 5 would
provide estimates of questionable validity. The special case
where exposure levels are assumed to be the same in all types of
buildings does not require additional assumptions. In this case
including exposure in residences from birth to age 5 increases
the proportion of total risk of mesothelioma attributable to non-
school buildings from 81 percent to 85 percent. For lung cancer,
the proportion of total risk remains at 92 percent.


this regulatory approach, by both building type and type of
activity, are shown in Figure Eleven. The derivation of these
costs is described above in the General Cost Estimation Scheme
section.

Iv. Limitations of the Analysis

Data limitations of many different types somewhat restrict
the confidence in this analysis. This section briefly describes
those data most likely to yield substantial changes in the
results of this analysis, given a change in the data themselves.

The first data limitation concerns the number of public
buildings with ACM, the quantity of ACM, and the level of damage
of the ACM. The AIBS-supplied estimates for the first two items
are probably low. The AIBS building data set does not account
for buildings constructed after 1979, some of which are likely to
contain ACM. The AIBS and its revisions also failed to estimate
the amount of thermal systems insulation and such types of
miscellaneous ACM as vinyl-asbestos floor tile. It is possible
that the TSI estimate developed for this analysis on the basis of
schools data is high. However, any overestimate of costs based
on this estimate may be overshadowed by an underestimate caused
by the lack of data on miscellaneous ACM types.

The AIBS damage estimates are not directly comparable to
those used in the schools rule RIA; thus, the cost estimates
derived by using the RIA's response action timelines may be
off. It is not possible to determine if this caused an
underestimate or overestimate of costs for public buildings.

The second limitation is the paucity of data on the current
level of market-driven asbestos identification and abatement
activities in public buildings. Because the level of currently
ongoing identification and abatement activities was not estimated
in this analysis (due to a lack of data), the costs developed in
this analysis may be somewhat high.

The third limitation concerns the estimates of hours required
to perform such activities as an asbestos inspection. It is
likely that the estimates developed in this analysis are low.
These estimates were derived from, and are often somewhat lower
than, the estimates developed in the schools rule RIA. (This is
because the public building models are smaller than most of the
school models.) However, in terms of scheduling and performing
asbestos-related work, many classes of public buildings are
likely to require more time than schools. This is due to a
variety of factors ranging from a more complex tenant mix to a
more varied tenant work schedule mix. Unfortunately, the data do
not yet exist that would allow a revised estimate of both the

5-23


S. SEQUENTIAL REGULATION

This scenario would have EPA promulgate a rule or series of
rules which would, through a sequential process, gradually extend
the Agency's regulatory reach to appropriate categories of public
and commercial buildings, with Federal buildings as a potential
pilot program. Because of current gaps in information, EPA would
need to study representative building types so that an
appropriate ranking system could be developed.

In this scenario, EPA would publish a schedule identifying
and designating, by category, type, or class, public and
commercial buildings that would be subject to AHERA-type
regulations. Procedures would need to be established for
revisions and regular additions to the schedule. In making the
determination of any such category, type, or class of building
for inclusion on a schedule, EPA could consider, among other
items or matters --

- the typical size of a building;

- average building age and condition;

- likelihood that the building contains ACM;

- availability of technical experts and personnel and
analytical resources;

- whether the determination is likely to adversely affect
or impede the inspection for, or response to, hazardous
asbestos in school buildings;

- number of occupants and visitors utilizing such
buildings; and

- likelihood of use by children.

Essentially, regulatory scope would be gradually expanded
from one category of buildings, such as Federal buildings,
airports, highrises or shopping malls, to others on a scheduled
basis, based upon criteria such as those listed above. Gradual
additions to the category of buildings regulated by EPA could
allow the EPA to assess the marginal impact and effects of
regulation without full, immediate application of a rule to all
buildings.

Feasibility

Again, scope and timing are critical considerations. EPA
would be able to schedule building inclusions based upon
feasibility considerations. However, the lack of information on
the decision criteria listed above might pose serious practical
problems for EPA to accomplish building selection, ranking and
scheduling.

Risks and Costs

Risk reduction would presumably increase with regulatory
scope, as greater levels of regulatory controls were reasonably
applied to new categories of buildings.

-33-


3. CONDITION
a. Data Sources

Each area of friable material in EPA's 1984 national survey
of public and commercial buildings was classified into one of
three categories: good condition, moderate damage, and
significant damage. This information, which did not appear in
the original survey report, is tabulated in Rogers (1987). The
data provide estimates of the condition of asbestos in public and
commercial buildings.

b. Characteristics

Of all public and commercial buildings, an estimated 14
percent (501,000) contain damaged ACM. Five percent of all
buildings (184,000) have moderately damaged ACM only, while 9
percent of all buildings (317,000) have at least some
significantly damaged ACM. Overall, the incidence and severity
of damaged thermal system insulation appears to be greater than
the incidence and severity of damaged surfacing material.

The results of the 1984 survey are summarized below.


fable 1.

Estimated number of buildings with asbestos-containing
friable materials by type of material and type of

building (in 1,000's) (95 percent confidence limits are
provided for each estimate)

Type of asbes

os-containing friable material

Type of building Sprayed- or Ceiling | Pipe/boiler Any
(universe total) trowelled-on tile insulation material
Federal 5 1 9 14
government (<10) (<2) (<18) (8-20)
35
Residential (10+ 64 2 155 208
rental units) (34-94) (<6) (66-243) (119-297)
350
Private 122 04 400 511
nonresidential (<275) (76-724) (274-748)
3,221
All buildings? 192 2 563 733
combined (18-365) (<6) (239-888) (499-966)
3,606

aof 110 sampled buildings in this category, none had asbestos-

containing ceiling tile.

However, some small number of buildings

in this category may have asbestos-containing ceiling tile.

Duay not equal sum of the columns due to rounding.

Csampled damaged or exposed material.


b. Characteristics

The 1984 building survey sampled buildings from a target
population of approximately 3.6 million public and commercial
buildings. It is estimated that friable ACM is present in 20
percent (733,000) of all public and commercial buildings covered
by the survey. Five percent (192,000) of all buildings have
sprayed- or trowelled-on asbestos surfacing material representing
a total of approximately 1.2 billion square feet. A larger
number of all buildings, 16 percent (563,000), contain asbestos
in thermal system insulation. On the average, there appears to
be a greater percentage of asbestos content in thermal system
insulation than in surfacing material. Detailed tables of the
results of this survey are presented in Appendix 1 and include
the confidence intervals for the estimates.

Of the estimated 733,000 public and commercial buildings
with friable ACM:

208,000 (28%) are residential apartment buildings with 10 or
more units;

511,000 (70%) are private nonresidential buildings; and
14,000 (2%) are Federal government buildings.

The estimated 208,000 residential apartment buildings (with
10 or more units) which contain friable ACM represent
approximately 59 percent of all such buildings (350,000)
identified by the survey -- the highest percentage among the
three categories. By comparison, Federal buildings with friable
ACM represent about 39 percent of all Federal buildings (35,000)
estimated by the survey, and private nonresidential buildings
with friable ACM represent approximately 16 percent of the 3.2
million buildings estimated in the final category.

The results of an informal poll of members of building
owners and real estate organizations conducted in 1987 are
generally consistent with the results of the 1984 survey. The
informal poll indicated that at least 20 percent of buildings
that had been inspected contained some type of ACM.

In comparison, the national telephone school survey
estimated that 35 percent (35,000) of schools in the survey
contain friable ACM. From the local education agencies’
inspection records, it is estimated that schools contain
approximately 169 million sguare feet of surfacing material.

According to these data, a lower percentage of public and
commercial buildings contain friable ACM than do schools (20
percent versus 35 percent).


6
I hope that you will find these recommendations useful, and
look forward to a constructive dialogue with the Congress in the
days ahead.
Sincerely,

(DO nee

Lee M. Thomas


inside or outside the building. For air monitoring to reflect
these episodes, it must continue long enough to record a
"representative" period of time during which such episodes might
occur. Since these types of episodes may vary widely and are
hard to predict, the representative period would have to cover
several days if not weeks or months. Unfortunately, EPA has
insufficient data to determine whether such episodic releases
contribute significantly to total risk. In addition, current
exposure levels may not be representative of future levels. ACM
can become damaged or deteriorated over time under certain
circumstances so that an "acceptable" reading on the air monitor
this year does not mean that one would get the same "acceptable"
reading two years from now.

Second, the most accurate monitoring would be by
transmission electron microscopy (TEM) since phase contrast
microscopy (PCM) cannot distinguish between asbestos fibers and
other kinds of fibers (e.g., textile fibers). The costs of a TEM
monitoring program would be extremely high. At current costs of
$200 to $400 per sample, a one-time monitoring program for a
single commercial office building could cost several thousand
dollars. For all public and commercial buildings with friable
ACM, EPA estimates that the costs could exceed $10 billion for a
one-time monitoring program. Clearly a one-time monitoring
program would not satisfy the need to protect against
deteriorating ACM which may not be releasing fibers today, but
may sometime in the future.

In the face of these constraints the Agency has
traditionally relied on another approach to determine when
abatement and removal action is appropriate. This approach to
the problem involves laboratory identification of ACM and visual
assessment of its condition by trained personnel. Visual
assessment of ACM also has its drawbacks because visual
assessment is a subjective process. While trained raters appear
to give more consistent evaluations than untrained raters,
inconsistent evaluations by trained raters still occur. As
techniques are developed for monitoring and determining the
likelihood of exposure, EPA will continue to address how to
advance the state of the art. In the meantime, the options for
risk reduction in this report do not include the setting of an
acceptable level of exposure to asbestos with accompanying air
monitoring.

4. INFORMATIONAL DEFICIENCIES

In examining a framework for risk reduction, EPA recognizes
important deficiencies in the information base which limit the
Agency's present ability to assess options, draw conclusions and
make recommendations concerning the regulation of asbestos in
public and commercial buildings. Basic information on exposures
to airborne asbestos in buildings is not fully available on key
considerations which include measurements of exposure levels and
validated assessment schemes for determining when to take action

-21-


nonschool buildings contributes up to 61 percent of the
mesothelioma risk and 87 percent of the lung cancer risk in the
model.

Nonschool exposure will comprise a greater share of the
total risk for individuals who are exposed to asbestos in their
residence as well as in schools and in public and commercial
buildings.

3. ABSOLUTE RISK

The absolute number of deaths attributable to the presence
of asbestos-containing materials in public and commercial
buildings cannot be estimated with certainty because of limited
information on airborne asbestos levels in these buildings, vari-
ability among measured values, and the difficulty of quantifying
the number of people exposed. An estimate has been obtained
based on one exposure scenario. The scenario uses airborne
asbestos fiber levels from one school system analyzed by EPA;
this level was selected based on the limited data that are
available and the judgment of experienced EPA personnel. In the
absence of abatement activity, fiber levels are assumed to
increase during the remaining useful life of the building.
Details are provided in Appendix 6.

Summary

A proportional risk model developed by the Agency suggests
that the elimination of asbestos exposures in schools might
significantly reduce residual risk for populations later exposed
in public and commercial buildings, assuming equal or higher
exposures in schools. Even though the elimination of asbestos
exposures in schools may significantly reduce risk, there may be
significant residual risk resulting from exposure in public and
commercial buildings. Service workers may encounter higher
episodic exposures, particularly if their activities disturb
ACM. They appear to be equally at risk, whether employed in
public or commercial buildings or in schools.

Estimates of absolute risk are subject to great uncertainty
primarily due to limited data on prevailing fiber levels.

-16-


found in persons living in the households of asbestos workers
(Selikoff et al., 1982) or living near asbestos mining areas,
asbestos product factories, or shipyards where there was heavy
use of asbestos (USEPA, 1980; NRC, 1984). As is typically done
for other carcinogens, health effects associated with low level
nonoccupational exposure to airborne asbestos fibers in public
and commercial buildings have been inferred by extrapolating data
from laboratory and occupational studies (USEPA, 1986). However,
as with many other environmental pollutants, the validity of
extrapolating from high level exposure to low level exposure has
never been demonstrated empirically.

Summary

Asbestos is known to be extremely hazardous, based upon
studies of both laboratory animals and asbestos workers and their
families. Several life-threatening diseases, such as lung cancer
and mesothelioma, can be caused by exposure to airborne
asbestos. No safe threshold has been established for asbestos.
Effects at low levels of nonoccupational exposure have been
estimated by extrapolation from higher levels although the
validity of this approach has not been empirically demonstrated.


STUDY Je: PREVALENT LEVELS OF AIRBORNE ASBESTOS FIBERS IN
SCHOOLS

STUDY OBJECTIVE: To establish national estimates of prevalent
airborne asbestos levels in schools to compare to levels in non-
school buildings and help determine the need for AHERA-type
regulation of nonschool buildings.

RATIONALE: Valid national estimates of prevalent airborne
asbestos levels in these building populations would allow the EPA
and other Federal agencies to have an exposure basis for Federal
regulatory programs.

APPROACH: Select a probability sample of U.S. school buildings
for air monitoring. It is anticipated that approximately 250
schools would be inspected in order to select buildings for air
monitoring. Air monitoring would be conducted in 50 schools. An
average of 10 indoor and 2 outdoor samples would be collected
over a one-week period in each building. The samples would be
analyzed by TEM. The data collected would be used to estimate
prevalent levels in schools and to compare to levels in non~
school buildings.

COST ESTIMATE: $4,000,000
TIME ESTIMATE: 2 to 3 years (can be done concurrently with 7a)

LIMITATIONS/DISADVANTAGES: This does not directly assess
absolute risk due to airborne asbestos levels in schools, but
rather provides only a relative risk and would only be done to
provide reference for study 7a of prevalent levels of asbestos in
public and commercial buildings. Further, it will not suggest
specific regulatory or other program options or efficacy of
options already in place.

STUDY 8a: CHARACTERIZATION OF POPULATION EXPOSED TO AIRBORNE
ASBESTOS IN PUBLIC AND COMMERCIAL BUILDINGS

STUDY OBJECTIVE: To determine the number, sex, and age
distribution of people exposed to ACM in public and commercial
buildings. Ancillary information on occupation, smoking habits,
etc., would also be collected, if possible.

RATIONALE: The risk model for mesothelioma depends on time from
onset of exposure and cumulative exposure. The risk model for
lung cancer depends on cumulative exposure and age. Numbers of
people and age distributions in different types of buildings are
needed to estimate risk using these models-

APPROACH: This can be accomplished in several ways with various
levels of accuracy and cost. One method, a “paper analysis”
based on existing data (e.g., census information, results of EPA
surveys), would be used to estimate the number of people exposed
to asbestos in public and commercial buildings.

7-10


The cost estimates developed for this analysis were based on
the assumption that outside consultants and contractors would be
used for all work except training, recordkeeping, and O&M
cleaning. Unless otherwise noted, the costs shown in the
following figures are weighted averages of the costs estimated
for buildings with only friable TSI, buildings with only friable
SM, and buildings with both friable TSI and SM. Generally, costs
are lowest for buildings with only TSI and highest for buildings
with both types of ACM. Based on AIBS data, it was estimated
that 76.8% of all public buildings with friable ACM have TSI,
26.2% have SM, and about 3% have both types.

B. Appendix Format

The remainder of this appendix presents the cost estimates
developed for most of the asbestos assessment and control
scenarios considered in the report. All of the major scenarios,
regulatory and non-regulatory, presented by the report were
addressed in the economic analysis. However, some specific
action items listed in such scenarios as enhanced, targeted
technical assistance do not have cost estimates, as data
limitations prevented the estimation of a cost.

This appendix presents a set of figures containing the
results of the various cost estimation scenarios considered in
the report. Most of the figures present separate cost columns
for the three building types (Federal, residential, and
commercial). In addition, the figures present a distinct cost
column for hospitals for use in the sequential regulation
scenario. This illustrates the possible cost of various asbestos
control scenarios on a specific building set. The total cost
column on the far right of all figures is the sum of the costs in
the Federal, residential, and commercial columns. The hospital
case is actually a subset of the population of commercial
buildings, so these costs should not be double counted when
reading the data in the figures.

The final section of the appendix presents a summary of the
limitations of the economic analysis.

III. Cost Estimates

A. Air Monitoring Cost Estimation

Several steps were followed to cost out air sampling as a
risk management tool. The first step was to establish a unit
cost for the collection and analysis of a sample. Sample
analysis can currently be performed by either Phase Contrast

5-6


effects of special O&M and other abatement activities on
exposures; the extent of marketplace/private sector actions and
their impacts on exposure and risk; and other factors that are
important in determining what future actions are appropriate.
Research in these areas would improve EPA's ability to help quide
future decision-making.

EPA could also serve as a clearinghouse for evolving
asbestos technical information. The Federal government could
accelerate research in key developmental areas, such as air
monitoring, replacement materials, sampling techniques and abate-
ment technologies, and conduct studies of asbestos in public and
commercial building situations (highrises, abatement in occupied
areas, etc.). EPA could also conduct supplemental surveys to
fill specific information gaps. A formal risk assessment and
quantitative cost-benefit analysis of the leading regulatory
scenarios for public and commercial buildings may also be useful.

f. Increasing abatement training and performance

EPA could promote the extension of accreditation programs in
the States, along the lines set by the AHERA Model Accreditation
Plan for schools, to persons who inspect, develop management
plans, or design or conduct response actions in public and
commercial buildings. The Agency could continue to support the
concept of information and training centers at universities and
other facilities across the Nation. The Federal government could
cooperate with training organizations and professional
associations to sponsor or promote training activities.

Feasibility

EPA's technical assistance programs have been well received
and relatively successful in providing guidance to decision
makers (Price, Price, 1987; Dietz, 1987). Further, EPA already
has the framework in place to deliver increased assistance
through Regional asbestos coordinators and support staff under
the American Association of Retired Persons (AARP) Senior
Environmental Employment Program.

Risks and Costs

Technical assistance would likely influence existing private
sector incentives (market value concerns and litigation) and help
guide the actions of the marketplace toward greater risk reduc-
tion. This scenario also allows the Agency to target scarce
resources on the groups which may be at higher risk, such as
service workers. Costs to the Federal government could range
from two to three hundred thousand dollars to as much as $74
million, depending upon what elements are included in the
program. Details on costs are provided in Appendix 5.

-26-


Included among the data on the 94 nonschool buildings noted
above are data which were collected in a 1987 EPA study of
prevailing air levels in 43 Federal buildings, located in six
cities across the Nation (Hatfield et al., 1987). The study's
interim report indicates mean fiber concentrations in these
buildings which are very low. Even in areas with significantly
damaged asbestos-containing material (ACM), the mean levels
measured only 0.00073 f/cc by TEM. Further, preliminary results
appeared to indicate no difference between levels found in
buildings with ACM and outdoor ambient levels, when compared at
the 0.05 level of statistical significance. EPA is now
completing its peer review of the interim report.

These data on airborne asbestos levels provide an indication
of prevalent levels which may be found in schools and in non-
school buildings. However, they are insufficient to support
generalizations about the total population of buildings or the
relative airborne concentrations in schools as contrasted with
public and commercial buildings.

In addition, maintenance and cleaning activities that
disturb ACM can result in elevated airborne asbestos levels of
exposure for service workers (Pinchin, 1982; Sawyer, 1977;
versar, 1984).

5. LOCATION OF ACM

Information on the location of ACM was collected in the 1984
national survey (USEPA, 1984a) and reported in Rogers (1987).

An estimated 13 percent (462,000) of public and commercial
buildings have friable ACM in fan and boiler rooms. These areas
are frequented primarily by service and maintenance personnel.
Ten percent (360,000) of buildings have some damaged material and
8 percent (282,000) have at least some significantly damaged
material in these areas.

An estimated 13 percent (454,000) of public and commercial
buildings have friable ACM in public areas. fight percent of
buildings (272,000) have some damaged material in public areas,
and 2 percent (85,000) have at least some significantly damaged
material, primarily TSI, in public areas.

summary

Based on the results of EPA's 1984 national survey,
approximately 733,000 or 20 percent of the 3.6 million public and
commercial buildings in the survey contain friable asbestos.
Approximately 501,000 of these buildings contain damaged
material. About 317,000 of the 3.6 million buildings contain at
least some significantly damaged material.

Significantly damaged material is commonly thermal system
insulation (TSI), often found in nonpublic building areas, such

~12-


The major activities, in order of normal precedence, which might
be part of a targeted regulation are:

° Inspection Inventory, as described and discussed in
Option 3 above.

° Management planning. Management planning is a decision
process which includes an assessment of the need, timing and
method of any control or abatement action required beyond O&M.

It generally involves the coordination and documentation of all
steps in the asbestos control process, from initial inspection to
the completion of response actions. Policies and procedures for
establishing an O&M plan, ensuring worker protection and safe
work practices, training in-house staff, conducting reinspection
and periodic surveillance, offering notification, and keeping
records can also be considered aspects of management planning.

° Operations and maintenance (O&M) activities. An O&M
program is designed to (1) clean up asbestos fibers previously
released; (2) prevent future release by minimizing asbestos
disturbance or damage; and (3) monitor the condition of
asbestos. The training of service and maintenance workers is
necessary. A good program consists of both worker protection and
safe work practices. O&M should be continued until all asbestos
is removed from a building.

Examples of targeted regulation follow:

- EPA might promulgate a rule which would reauire
inspection and management planning in public and
commercial buildings. In this case, buildings owners and
Managers would be free to determine the appropriateness
of O&M activities and response actions for themselves.
The focus of such a rule would be on identification and
planning rather than control or abatement activities.

- The Agency might instead require O&M programs as well as
inspections and management plans, leaving only the
selection of other proper response actions to the
responsible persons. This approach would mandate an
active control program for keeping materials in place, as
well as identification and comorehensive planning.

- A third approach might be a requirement for inspection
and O&M programming. In this instance, greater emphasis
would be placed on asbestos control (as opposed to
asbestos management planning) than in the first
approach. With this approach, EPA would place a premium
on O&M and allow building owners and managers to make
their own judgments on whether to implement a management
plan or take additional actions.

-31-


Although the risk posed by substitute materials appears to be
lower than the risk posed by asbestos, the substitutes are
unlikely to be completely risk free.

B. Custodians

Table 3 presents estimates for the number of deaths among
custodians working in asbestos-containing buildings. The first
column assumes pre-OSHA rule fiber levels and that over the 30-
year remaining life of the buildings, the airborne concentration
will rise to an average level of 0.46 f/cc. The estimated number
of deaths among this group, 3,730, out of an exposure popylation
of 369,200, implies a lifetime risk to individuals of 10°* if no
OSHA rule had been implemented.

The second column assumes that the OSHA PEL of 0.2 f/cc is,
on the average, just met in each and every building. The
resulting 1,665 deaths out of 369,200 exposed implies a lifetime
risk to individuals of 1073. This differs from the OSHA reported
risk of 1072 because OSHA has estimated mortality from asbestosis
and included these deaths with the cancer deaths. EPA has not
estimated asbestosis deaths in this report.

TABLE 3

SENSITIVITY ANALYSIS: CUSTODIANS (ALL
ASBESTOS-CONTAINING BUILDINGS)

At At At
Pre average average average
OSHA of of

of
Rule 0.2 £/cc 0.1 £/cc 0.01 f/cec

CASES (1988 - 2118) 4060 1810 905 91
DEATHS (1988 - 2118)

Lung Cancer 2055 920 460 46
G.I. Cancer 205 90 45 5
Mesothelioma 1470 655 327 33
TOTAL* 3730 1665 832 84

* Columns may not add exactly due to rounding. All numbers have
been rounded to the nearest ten.

The third column assumes that all custodians are exposed to
an average of 0.1 f/cc, the action level under the OSHA


asbestos concentration will slightly more than double from
today's level. Therefore, this analysis assumes that the mean
airborne asbestos level over the remaining building life would be
about 60 percent above the current estimated airborne
concentration.

Additional assumptions are listed below.

° Non-custodial occupants of nonresidential public
buildings are assumed to have the age, race, and sex
distribution of the U.S. occupational population. This
distribution is reported in Table 1. The proportion of
smokers by age, sex, and race is assumed to be the same
as the current distribution of U.S. smokers. For this
analysis, the proportion of the U.S. population who
smoke is held constant over time, although the actual
proportion may be declining. The population is assumed
to be exposed to airborne asbestos for 8 hours a day,
250 days per year and to have a breathing rate of 1
m?/hr.

o The "average" nonresidential building is assumed to be
an office building. This assumption probably provides
reasonably close results for the population of
government (GSA) buildings but may be inaccurate for the
population of non-GSA buildings. Non-GSA buildings
would include churches, hospitals, and stores, in
addition to more office buildings.

° using Census-derived estimates of 30 occupants per
office building, 637,000 persons are assumed to occupy
Federal buildings which contain asbestos and
23,250,500 persons are assumed to occupy other
nonresidential public buildings which contain asbestos.


as boiler and machinery rooms. Because these are limited access
areas for the general public or building occupants, asbestos
exposures in these areas would be limited primarily to a
relatively smaller number of service and maintenance workers.

Limitations in the exposure data prevent quantitative
conclusions, or comparisons between schools and public and
commercial buildings. Estimates of the number of persons
exposed, the level of airborne asbestos exposure, the frequency
or influence of episodic events which disturb asbestos, or the
relative exposure levels of service workers in comparison with
members of the general public are highly uncertain.

-13-


sixty year remaining building life. Alternatively, this is
equivalent to between 3 and 66 deaths per year over the 130 years
that these deaths may occur. The distribution of these deaths is
not uniform so that in any one year more or fewer than the
average number of deaths may occur. No deaths are estimated to
occur beyond 130 years. This estimate of the number of deaths
assumes that no medical advances are made over the next 130 years
to reduce cancer mortality.

If the airborne concentrations of asbestos fibers can be
brought down to the median fiber concentration in ambient air,
2-3 nanograms per cubic meter or 0.00007 fibers per cubic
centimeter+4 then most of these deaths could be avoided.

Assuming that this could be accomplished in a relatively short
period of time (i.e., most of the abatement occurs in the first 5
years), the number of deaths resulting from 60 ygars of occupancy
in these buildings could be kept to around 100.

The issue of abatement is a complicated one. At the present
time EPA does not have information which allows the Agency to
assess the efficacy of abatement techniques. Sufficient data
regarding post-abatement fiber levels are not available. EPA has
anecdotal evidence which indicates that not all abatement actions
are conducted in a manner that would preclude the release of
asbestos. Improperly conducted abatement actions may cause an
increase, rather than a decrease, in the fiber levels to which
building occupants are exposed. Even well-conducted abatement
actions may increase exposure in the short term for an unknown
length of time. For the purposes of this analysis, no assumption
is made that abatement activities will reduce building fiber
levels to average ambient fiber levels.

Finally, this appendix has not attempted to assess the risk
to building occupants from exposure to materials which are used
as replacement materials for the asbestos. A report issued by
the National Research Council states, "In the studies conducted
to date, man-made mineral fibers have not presented the same
magnitude of health hazard to humans as has asbestos." 6

The median asbestos fiber concentration of the air of U.S.
cities is reported to be 2.3 ng/m3 or 0.00007 £/cc using a
conversion factor of 30 fibers per nanogram. See Asbestiform
Fibers: Nonoccupational Health Risks. National Research
Council, Washington, D.C. 1984.

15 this calculation used the timing of abatement action used in

Appendix 5 for estimating the costs of an AHERA-type
regulation. It is beyond the scope of this appendix to
speculate whether in fact an AHERA-type regulation would
achieve such an airborne concentration level.

16 op. Cit. National Research Council (1984) p. 145.

6-10


some of the study buildings to ensure uniformity and to provide
incentives for cooperation and participation. It is proposed
that a few O&M procedures be evaluated at a unit cost of
approximately $1,000,000 for each special study.

COST ESTIMATE: $2,000,000 (two procedures @ $1,000,000 each)
TIME ESTIMATE: 2 years

LIMITATIONS/DISADVANTAGES: This study does not directly
determine absolute airborne concentrations without O&M, but

rather examines potential for reducing levels in certain
buildings.

STUDY 3: LONG-TERM EFFICACY OF ASBESTOS CONTROL

STUDY OBJECTIVE:

Phase 1: To monitor airborne asbestos levels after a
removal action and determine the need for and
effectiveness of special cleaning procedures or
followup O&M.

Phase 2: To compare the reduction in airborne asbestos
levels after asbestos removal to the reduction
through implementation of special operations and
maintenance procedures.

RATIONALE:

Phase 1: Anecdotal evidence indicates that the removal of
ACM may not completely eliminate asbestos
exposures due to residual contamination of the
building. Since increased EPA regulatory activity
(i.e., AHERA) will undoubtedly result in
additional asbestos removal activities, it is
important to collect information on how well they
are being conducted and whether or not long-term
O&M procedures are necessary.

Phase 2: This study option would supplement Phase l by
collecting information to document the efficacy of
leaving ACM in place and implementing special O&M
procedures as opposed to the removal of the ACM.
There is no information on the relative
effectiveness of special O&M versus ACM removal.
If O&M is as effective in controlling airborne
asbestos levels as properly conducted removal
actions, then building managers/owners could defer
costly removal jobs and factor them into planned
changes in building use.

7-2


The AIBS did not provide estimates of the amounts of most of
the ACM types found in public buildings. The revised versions of
the AIBS provided estimated amounts for only the asbestos-
containing surfacing materials and ceiling tiles. No firm
estimates were provided for the amount of thermal systems
insulation (TSI) or other, miscellaneous forms of ACM.

To calculate the amount of thermal systems insulation in
public buildings, model public buildings were matched with model
schools that were close in size. For example, the model
residential building, at 27,601 square feet, was matched with the
model public primary school (at about 31,000 square feet). The
amount of thermal systems ACM per model school was then applied
to the matched model public building. Thus, the model
residential building was estimated to have 472 square feet of
TSI. These TSI amounts per model building were then multiplied
by the number of public buildings (of each building type)
estimated by the AIBS to have friable asbestos-containing TSI.
This yielded an estimate of some 280 million square feet of
friable TSI in public buildings.

This analysis did not estimate costs for asbestos-containing
ceiling tile or miscellaneous types of ACM. Costs for both ACM
categories are expected to be quite small. Consequently, their
exclusion is expected to result in only a minor underestimate of
costs. Asbestos-containing ceiling tile was found in very few
buildings, and total amounts were guite small, especially for
friable tile. No data were presented on the quantities of
miscellaneous ACM, but the nonfriable, sturdy nature of most
miscellaneous ACM implies that few costs beyond an inspection
would be incurred. Thus, aside from an inspection cost, any
costs incurred for these ACM will be likely be the result of
NESHAPS and other existing regulations, and not the scenarios
considered in this report.

The AIBS used a set of five condition codes to illustrate the
level of damage to friable ACM (ACFM). Condition code 1 was for
ACM in the best condition, and condition code 5 was for ACM in
the worst condition. Damaged ACFM was defined as having
codes 3, 4, or 5, and significantly damaged ACFM had condition
code 5. Even though some of the damage labels were not mutually
exclusive with respect to condition codes, this analysis assumed
that these condition codes were roughly comparable to the
damage/hazard categories used in the final schools rule RIA. The
categories used in the RIA were: significant damage, moderate
damage, good condition with the potential for significant damage,
and good condition with the potential for damage.


public and commercial buildings. At these low sampling rates,
the resulting data would be statistically unreliable and still
extremely expensive.

Figure Four
Costs of One-Time Air Monitoring Effort

Fed Res Comm All Bidgs
#Bldgs. 14,000 208,000 511,000 733,000
#Samples/Bldg. 60 35 35
$/PCM Sample $30 $30 $30
$/Bldg. (PCM) $1,800 $1,050 $1,050
*Total Cost $25 $218 $537 $780
$/TEM Sample $400 $400 $400
$/Bldg. (TEM) $24,000 $14,000 $14,000
*Total Cost $336 $2,912 $7,154 $10,402

* In Millions

B. The Cost of Acquisition of Needed Information

A good deal of the basic information required for the Agency
to best address the asbestos hazard in public buildings is
presently unavailable. Better risk reduction decisions would be
possible if the information were acquired by EPA. The report
discussed several useful data collection efforts that EPA could
undertake. Appendix 7 describes in detail a number of studies
designed to collect this information and the costs associated
with each.

Cc. Cost of Enhanced, Targeted Technical Assistance

One approach to risk management would be non-~regulatory in
nature: providing enhanced technical assistance to target
populations with the greatest needs. The report presented six
Major categories of technical assistance, all of which are
briefly discussed below. These estimates are based on the most
recent experience of EPA in providing schools with technical
assistance quite similar to that under consideration in the
report. Estimates of the approximate costs of providing enhanced
technical assistance are presented in Figure Five.


EPA's National Emission Standard for Hazardous Air Pollutants
(NESHAP) for Asbestos. These Federal regulations, which have
been recently revised or are currently being revised, afford
protections to the general public and abatement personnel from
exposure to asbestos during building renovation and demolition
activities. The AHERA schools rule is also now part of the
baseline and may provide voluntary guidelines for public and
commercial building owners.

In addition, EPA's asbestos technical assistance program,
initiated in 1979, has developed various guidance materials for
controlling and managing asbestos in buildings. It also provides
technical experts in the field to advise building owners, and
offers funds to develop State programs, to promote proper
training, to advance control and abatement technologies, and to
improve work practices. The Agency has established asbestos
information and training centers at a number of universities
across the nation and developed model training materials for
these centers and other training providers. As a result,
thousands of abatement project supervisors and workers have
received instruction on proper abatement practices and
procedures.

In recent discussions, EPA has been advised by building
owners and managers in the commercial sector that since 1983 the
number of buildings inspected, placed under management plans, and
scheduled for asbestos abatement has increased significantly, and
removals have decreased the amount of asbestos remaining in
public and commercial buildings (Price, Price, 1987).

In sum, States and localities are increasingly taking the
initiative in establishing asbestos control programs to the
extent they believe it is appropriate for their jurisdictions.
Federal regulatory and technical assistance activities have
increased public awareness and understanding, supported
responsible marketplace action, and facilitated State and local
activities.

However, this increased activity does not guarantee risk
reduction in every case. Some actions may result in unnecessary
or improperly conducted removals, which may increase asbestos
risk rather than reduce it. In other cases no action will be
taken even when abatement is necessary to protect human health
and the environment.

In mandating this report on asbestos in public and
commercial buildings, Congress directed the Agency to address the
need for regulatory action. Any such regulatory action would be
intended to provide risk reduction over and above that which
would occur without regulation. In other words, is additional
risk reduction necessary and appropriate?

Unfortunately, the Agency does not have the data to produce
a scientifically acceptable estimate of risk due to asbestos

-18-


regulation, and the fourth column assumes an exposure at 0.01
f/cc, the practical limit of detection for PCM.

The resulting deaths out of 3694200 exposed implies a
lifetime risk to individuals of 107%. I£ the levels in these
buildings could be brought down over a reasonably short time to
the ambient air concentration of 0.00007 f/cc, these deaths could
be held to near zero.

VI. LIMITATIONS OF THE ANALYSIS

Any analysis is only as strong as the data which support
it. As mentioned at the beginning of this appendix, many data
which would have improved this analysis simply do not exist. In
addition to the limitations discussed in each section, several
other assumptions should be pointed out.

smoking and exposure to asbestos react synergistically to
produce lung cancer. That is, persons who both smoke and are
exposed to asbestos have lung cancer rates that are 50 times
those of persons who neither smoke nor are exposed to asbestos.
Smoking multiplies one's chance of developing lung cancer by a
factor of 10, regardless of whether one is or is not exposed to
asbestos. Thus, the majority of the cases of lung cancer
described in the report will occur to smokers.

For the relative risk (lung cancer) portion of this analysis,
U.S. 1977 lung cancer rates were assumed. Because lung cancer
rates have been increasing at approximately three percent per
year since the 1950's, this assumption, taken by itself, will
understate lung cancer rates. Smoking rates, however, are
currently declining. We can therefore expect that lung cancer
rates will also decline, with a 30 or 40 year lag. The choice of
1977 lung cancer rates is an attempt to select a rate which
represents the average rate over the 130-year period of
analysis. Whether or not this choice is indeed the appropriate
average, the deaths predicted by the model will occur later in
time than will the actual deaths.

As mentioned earlier, deaths from asbestosis are not included
in this analysis. OSHA estimates that at the PEL of 0.2 f/cc, a
lifetime exposure will result in five deaths from asbestosis out
of every thousand lifetime exposures.

17 this calculation used the timing of abatement action used in
Appendix 5 for estimating the costs of an AHERA-type
regulation. It is beyond the scope of this appendix to
speculate whether in fact an AHERA-type regulation would
achieve such an airborne concentration level.

6-12


5. Assessing the effect of remedial action on exposure
(such as O&M and other abatement activities,
including removal). EPA has limited data to indicate
if certain actions actually reduce exposure/risk to
airborne asbestos. (Studies 2, 3, and 6 address this
limitation.)

6. Assessing the full extent of private sector and State
and local governmental asbestos management programs
and their actual impacts on exposure and risk. This
information would help develop technical assistance
or regulatory programs where they are most needed.
(Studies 5a and 5b address this limitation.)

This information is currently unknown and would have to be
acquired through subsequent studies by EPA or other parties. It
would improve the Agency's ability to estimate exposure, identify
risks and recommend responsible technical assistance and
regulatory options to address hazards. Any such research is
complex, expensive, and time-consuming. Furthermore, serious
technological difficulties may need to be overcome if some of
these major asbestos research programs are undertaken.

Further descriptions and costs of possible studies to fill
these gaps are provided in Appendix 7.

-23-


ACFM

The ACFM in public areas occurs mostly in private non-
residential buildings with one or two floors, reflecting the
overall distribution of buildings.

Buildings with friable material in public areas are more
likely to be highrises rather than buildings with one or two
floors.

in Fan and Boiler Rooms

The percentage of buildings with asbestos-containing friable
Material in fan/boiler rooms by condition of material is:

All material 13% (4-22%)
Damaged material 10% (1-198)
Significantly damaged material 8% (<18%)

Taller buildings are more likely to have asbestos-containing
friable material in fan/boiler rooms regardless of condition
of the material.

Most of the buildings with asbestos-containing friable
material in fan/boiler rooms have three or more floors,
unlike the overall distribution of buildings.

Often ACFM in fan/boiler rooms is significantly damaged.

Most friable material (damaged or not) in fan/boiler rooms
contains asbestos.

Percentage of buildings with asbestos-containing friable
material by condition of material is:

All material 20% (14-278)
Damaged material 14% (6-22%)
Significantly damaged material 9% (<19%)

Most buildings with asbestos-containing friable material are
private nonresidential buildings or have one to seven
floors, following the distribution of all buildings.

Taller buildings are more likely to have asbestos-containing
friable material regardless of condition of the material.


cure rates assumed for this paper are approximately 10% for lung
cancer and GI cancer, and approximately 2% for mesothelioma.

The Nicholson relative risk model is used to estimate the
number of lung cancer cases avoided, and Nicholson's absolute
risk model is used to gstimate the number of mesothelioma cases
avoided (uspon, 1983)11. he Gr cancer rate is assumed to be 10%
of the lung cancer rate, which is the lower end of the range
found in studies, and the value adopted by OSHA in its
rulemaking. Dose-response constants used in these models were
estimated by Selikoff in 3 study of asbestos insulation workers
(Selikoff et al., 1979).1 These models are also being used to
estimate deaths and cases of lung cancer, GI cancer and
mesothelioma for other EPA asbestos (proposed) regulations and

have been used in prior rulemaking by both OSHA and the Consumer
Product Safety Commission.

A number of epidemiological studies have estimated
dose-response constants for asbestos-related diseases. Estimates
vary by as much as an order of magnitude. The Selikoff estimates
fall approximately in the middle of the ranges of dose-response
estimates for lung cancer and mesothelioma. In addition, the
Selikoff estimates have the lowest variance among all of the
estimates. These models and dose-response constants are those
recommended by the Chronic Hazard Advisory Panel on Asbestos and
were used by OSHA in doing asbestos risk assessment. The risk
analysis methodology is discussed in more detail in Appendix 4 of
"Cost and Effectiveness of Abatement of Asbestos in Schools."13

V. RESULTS

The results derived from the assumptions ouctined in the
previous sections are presented in Tables 2 and 3. In each
table, the illustrative number of cases and deaths assumes that
no additional regulations are promulgated for public buildings.
As mentioned earlier in this Appendix, ongoing activities to
abate asbestos in public and commercial buildings have not been
estimated, so that the number of cases for each exposure level
may be overstated.

A. Non-custodial Occupants

In Table 2, the exposure level is based on a weighted average
concentration found by EPA in one school district. This value

11 op. cit. usDoL 1986 (June).

Op. Cit.

12 Selikoff, et al. "Mortality Experience in Insulation Workers
in the United States and Canada." Annals of the New York
Academy of Sciences. 330:91-116. New York, 1979.

13 op. cit. USEPA 1984 (August).

6-8


The scope of the regulation would require a substantial
public mobilization, greater than for any other scenario
discussed in this section. Support capabilities, such as
accredited experts and TEM labs, are not now available to meet a
demand of this scale.

Risk and Costs

This scenario has the potential to reduce the greatest risk,
as it would require, unlike most other scenarios, appropriate
abatement activities by building owners across the nation. EPA's
cost analysis for this scenario estimates that full regulation of
public and commercial buildings, on the scale of the AHERA
schools rule, would cost approximately $51 billion (discounted
over a 30-year period).

Policy Considerations

This scenario is assumed to be most protective of public
health, since it responds to the risks of asbestos exposures in
essentially all buildings. The regulation would provide a
uniform comprehensive national standard and require that public
health hazards are abated.

On the other hand, practical obstacles associated with the
regulatory scale appear so substantial that the intended results
might be jeopardized. The scenario requires the nation to apply
its asbestos control resources equally among all building
categories regardless of possible differences in exposure and
risk reduction. Costs are extremely high and the private sector
resources required for proper inspection, management planning,
O&M programs, and the conduct of response actions do not appear
available to meet demand in the near term. Further, the Agency's
compliance assistance and enforcement capabilities would be
severely strained by the demands of such an option.

-35-


exposure in public and commercial buildings, let alone to
quantify the risk reduction now underway in public and commercial
buildings as a result of private, State and local government
actions. In addition, the Agency is unable to estimate how risk
reduction activity might increase in coming years in the absence
of further Federal intervention. Additional survey and research
would be necessary to determine the level of current activity and
to estimate its possible growth in future years.

2. THE ADEQUACY OF EXISTING FEDERAL REGULATIONS

Several Federal regulations serve to protect the general
public, particularly abatement personnel, from exposure to
asbestos during renovation and demolition. These are the OSHA
asbestos standards, the EPA worker protection rule (which
essentially affords OSHA-type protections to public sector
abatement workers), and the EPA NESHAP for asbestos.

OSHA's worker protection program is based on numerical
exposure standards: an action level and a permissible exposure
level (PEL). If airborne fiber levels, measured as an eight-hour
time-weighted average by phase contrast microscopy (PCM), exceed
0.1 f/ee (the action level), employee information and training,
and eventually medical surveillance programs must be initiated.
If the eight-hour time-weighted average measured by PCM exceeds
0.2 f/cc (the PEL), a complete workplace protection program,
which includes respiratory protection, must be implemented.
OSHA's standards apply to general industry and construction. The
contruction standard covers abatement workers, while most of the
private sector workers are covered under the general industry
standard. Service workers may be protected by either the general
industry or construction standard, depending on their work
activities. These standards are enforced both by random inspec-
tions of workplaces and by response to worker complaints. In
1986, OSHA conducted a total of 64,100 inspections. A total of
856 citations for violation of the asbestos standards were issued
during that same period. The EPA worker protection rule includes
essentially the same provisions as the OSHA standards, but it
currently applies to public sector abatement workers only.

The NESHAP applies to building renovation and demolition
involving friable asbestos-containing materials. The building
owner or operator must provide written notice to EPA of intent to
renovate or demolish, and must follow basic asbestos emission
control procedures (i.e., use wet methods, handle according to
regulatory specifications). Transport and disposal provisions
prohibit visible emissions. In 1986, EPA conducted a total of
15,060 NESHAP asbestos inspections and found 2,179 violations.
EPA is currently revising the NESHAP regulation to make it more
effective.

The Congressional mandate for this report directed EPA to

assess whether or not the existing Federal regulations are
adequate. There are two ways in which this question can be

-19-


Table 2. THE PROPORTION OF LIFETIME RISK ATTRIBUTABLE TO EXPOSURE TO
AIRBORNE ASBESTOS IN PUBLIC AND COMMERCIAL BUILDINGS RELATIVE TO TOTAL
RISK FROM EXPOSURE IN BUILDINGS FOLLOWING 13 YEARS OF EXPOSURE IN SCHOOLS

Exposure Experience Airborne Asbestos Levels in Public and
Commercial Buildings Relative to Levels
in Schools

Twice Same One half One sixth One tenth

Percent Risk Attributable to
Public and Commercial Buildings————
Mesothelioma

13 years at school plus:

lifetime in other buildings 61 43 28 11 7
20 years in other buildings 61 43 28 11 7
10 years in other buildings 47 31 18 7 4

5 years in other buildings 31 19 10 4 2

Lung Cancer

13 years at school plus:

lifetime in other buildings 87 76 62 35 24
20 years in other buildings 75 60 43 20 13
10 years in other buildings 61 44 28 12 7
5 years in other buildings 44 28 16 6 4


Rogers, J., 1987. Final Report: Additional analysis of data
collected in the asbestos in buildings survey. Rockville, MD:
Westat. Prepared for Office of Toxic Substances, U.S.
Environmental Protection Agency.

Sawyer, R.N., 1977. Asbestos exposure in a Yale building:
analysis and resolution. New Haven, CT: Preventive and
Occupational Medicine, Yale Health Service.

Seidman, H., Selikoff, I.J., Hammond, E.C., 1979. Short-term
asbestos work exposure and long-term observation. Annals of the
New York Academy of Science, 338:61-89.

Seidman, H., 1984. Short-term asbestos work exposure and long-
term observation - July 1984 updating. Testimony presented at
the OSHA hearing on a proposed standard on occupational exposure
to asbestos.

Selikoff, I.J., Anderson, H.A., Seidman, H., 1982. "Asbestos
disease among household contacts of asbestos workers" in
Disability compensation for asbestos-associated disease in the
U.S. Edited by I.J. Selikoff. Environmental Sciences
Laboratory. Mount Sinai School of Medicine of the City
University of New York. 73-76.

USDOL, 1983. Quantitative risk assessment for asbestos-related
cancers. Washington, DC: Occupational Safety and Health
Administration.

USEPA, 1980. U.S. Environmental Protection Agency. Support
document: Asbestos-containing materials in schools--health
effects and magnitude of exposure. Washington, DC: Office of
Pesticides and Toxic Substances, USEPA. EPA-560/12-80-003.

USEPA, 1984a. U.S. Environmental Protection Agency. Asbestos in
buildings: a national survey of asbestos-containing friable
materials. Washington, DC: Office of Toxic Substances, USEPA.
EPA 560/5-84-006.

USEPA, 1984b. U.S. Environmental Protection Agency. Evaluation
of the asbestos~in-schools identification and notification

rule. Washington, DC: Office of Toxic Substances, USEPA. EPA
560/5-84-005.

USEPA, 1986. U.S. Environmental Protection Agency. Airborne
asbestos health assessment update. Washington, DC: Office of
Health and Environmental Assessment, USEPA. EPA/600/8-84/003F.

Versar, Inc. 1984. Exposure assessment for asbestos. Draft
final report. Washington, DC: Office of Toxic Substances,
USEPA. Contract No. 68-01-6271.


B. EXPOSURE
1. INTRODUCTION

To analyze the degree of risk from asbestos in public and
commercial buildings one must understand not only the inherent
health hazards associated with asbestos but also the likelihood
that people will actually be exposed to asbestos in these
buildings. This likelihood, in turn, depends on the presence of
airborne asbestos fibers and the tendency for fibers to be
released into occupied areas. It must be emphasized that the
presence of ACM alone does not imply exposure; fibers must be
released from the material and must be inhaled. Four indicators
of possible exposure are used in this report to shed light on the
likelihood of actual exposure in public and commercial
buildings. These indicators are:

° Presence (summarized as the amount and type of ACM)
° Condition of the ACM
° Estimated airborne asbestos concentrations
° Location of the ACM
Each of these four indicators is discussed in this section.

In the discussion which follows, asbestos-containing
Materials are classified as:

(1) surfacing material - ACM sprayed on or trowelled on
surfaces, such as acoustical plaster on ceilings,
fireproofing on structural members. Surfacing
Materials are usually friable (i.e., can be reduced
to powder by hand pressure).

(2) thermal system insulation (TSI) - ACM applied to
pipes, boilers, tanks, ducts or other structural
components to prevent heat loss or gain, or water
condensation; and

(3) "other" ACM - miscellaneous ACM such as ceiling and
floor tiles, wallboard, or cement pipe. These
Materials are usually nonfriable and do not generally
release fibers as readily as do friable materials,
unless damaged.

Materials in the first two categories are of particular
interest in determining the likelihood of exposure since they
tend to be friable and may release fibers more readily than
nonfriable materials in category (3). The data presented in this
section refer to ACM in categories (1) and (2). Very little
information is available on "other" ACM.

~6-


Additional assumptions are as follows:

° Non-custodial occupants of residential buildings of 10
Or more units are assumed to have age, race, sex, and
proportion smoking distribution of the U.S. population
as a whole. They are assumed to be exposed to building
asbestos fiber levels for 14 hgurs a day, 365 days a
year. A breathing rate of 1 m’/hr is assumed. The
population distribution is presented in Table 1.

o According to the 1980 census, there are 19,815,448
occupants of such buildings.

° Assuming that the proportion of residents of buildings
of ten or more units who are exposed to airborne
asbestos is the same as the proportion of such buildings
which contain asbestos, 59%, or 11,691,114 persons,
would be exposed.

Cc. Custodians of Public and Commercial Buildings

This analysis assumes that custodians of buildings
potentially face a higher level of exposure to fibers than do
other occupants of the same buildings. This assumption is based
on the facts that much of the asbestos is located in areas
frequented by custodians, such as boiler rooms, and that
custodians are engaged in activities, e.g., changing light bulbs
or dry sweeping, which disturb asbestos in their vicinity.

The OSHA regulation on occupational exposure found that
routine maintenance in commercial and public buildings produced a
mean exposure of 0.29 f/cc on an eight-hour, time-weighted
average”. Finding that this level presented an unacceptable
risk, OSHA promulgated a Permissible Exposure Limit (PEL) of 0.2
fibers per cubic centimeter. It is not always a straightforward
task for a building owner to comply with this OSHA PEL.
Consequently, to bound the estimates of risk to custodians, this
analysis assumes for the high end of the range that custodians
are exposed to the 0.29 f/cc today, and that conditions
deteriorate over the 30-year remaining life of these buildings,
so that the average exposure level over the 30-year period is
0.46 f/cc. For the low end of the range, this analysis assumes
that workers are exposed to an average concentration of 0.01
f/cc, the lowest level measured by Phase Contrast Microscopy
(PCM) that is used in practice. This level, in practice, would

3 Department of Labor, Occupational Safety and Health
Administration. 29 CFR Parts 1910 and 1926, Occupational
Exposure to Asbestos, Tremolite, Anthophyllite, and
Actinolite; Final Rules. June 20, 1986, Washington, D.C.


4

information is regularly integrated across EPA programs and
perhaps OSHA. Further, the NESHAP notification procedure can be
utilized to provide guidance and direction on good work practices
to building owners and contractors BEFORE work commences. Within
our own Agency, a regional pilot project to better coordinate
various asbestos programs--NESHAP, technical assistance, the ASHAA
and AHERA schools programs--can be expanded.

A combination of additional Federal inspection personnel and
increased State grant money in States with delegated enforcement
programs could dramatically improve compliance with existing
regulations. Limited increases in Regional staff devoted to
coordinating programs, and delivering technical assistance and
guidance to building owners and other affected parties, would
provide the critical mass to eliminate duplication and
inefficiencies. The total cost of this increased program would be
approximately $4 million per year. After three years the
effectiveness of these efforts should be assessed and future needs
determined at that time,

(4) Objectively assess the effectiveness of the AHERA
school rules and other current activities.

There are approximately 35,698 school buildings which
contain friable asbestos, as compared to more than 730,800 public
and commercial buildings. The total cost of the AHERA program is
about $3 billion compared to approximately $51 billion for a
similar regulatory program in public and commercial buildings.
Federal agencies, States, localities, and the private sector are
already active in the assessment and control of asbestos in many
of these buildings. These facts emphasize the need to assure that
the Federal government's intervention in society on behalf of
public and commercial buildings is a sound one based on an
objective assessment of activities which have only recently been
begun.

I do not believe that a comprehensive regulatory inspection
and abatement program such as was recently implemented for the
Nation's schools under the AHERA school rule is appropriate at
this time. I do recommend that studies be conducted on a priority
basis, focused on the effectiveness of the AHERA school rule, and
the level and effectiveness of the current activities of the
States and private sector.

It would be foolish for the country to consider a large new
program of asbestos control without first asking basic questions
which could improve our response to asbestos in public and
commercial buildings and probably provide public health protection
at a lower cost. The nation's study and research program should
be proportional to the magnitude of the public investment in
controlling the problem which is contemplated, especially when so


For every population group modeled, the assumption was made
that the proportion of people exposed to asbestos (out of total
persons potentially exposed in that building type) was equal to
the proportion of buildings of that type which contained
asbestos. If large buildings are more likely to contain asbestos
than small buildings, the number of people assumed exposed will
be understated by the methodology employed here. Conversely, if
the asbestos-containing buildings are smaller than average, this
methodology will overestimate the number of people exposed.

One final assumption which requires discussion is the
derivation of average fiber levels. For the purposes of
estimation, buildings were not 'retired' until the end of the 30-
year estimation period. If buildings which contain asbestos are

taken out of service within the 30-year estimation period -- for
example, if they are replaced with non~asbestos-containing
buildings -- the fiber levels will not increase as rapidly as

projected by this appendix. This failure to retire buildings,
however, is balanced by the fact that although the average age of
buildings is assumed to be 25 years, so that in this analysis all
asbestos-containing buildings will be out of service in 30 years,
approximately one-half of the buildings are in fact newer and
will continue to expose the inhabitants to asbestos for 50 to 60
years. Since the analysis uses a linear, no-threshold model, as
long as total fiber emissions have been adequately captured, the
resulting mortality estimates will be approximately accurate. As
in the case of the lung cancer rates, however, the timing of
modeled deaths will differ from the timing of actual deaths.

VII. SUMMARY

This appendix demonstrates a method of estimating the deaths
which can be attributed to the presence of airborne asbestos
fibers in public and commercial buildings. A wide range of
estimates is used because of limited data on the actual airborne
asbestos levels in this set of buildings.


APPENDICES
1984 EPA Asbestos In Buildings
National Survey
Summary of Other Major Support Studies
Existing Federal Regulations
Proportional Risk Assessment
Summary Economic Analysis
Absolute Risk Sensitivity Analysis
Possible Studies to Address Informational Deficiencies

References