Public Hearing held by the task force in sacramento on April 27, 1989, and in Los Angeles on May 5,
1989, and
Written materials went to DHS as part of the public record of the two public hearings..
II Research Findings
In preparing a report to the legislature mandated by the California health and safety code (CHSC)Chapter 2.5, Section 24275., DHS had convened a workshop of expert witnesses to testify on the use of air monitoring for determining the funding of abatement in schools. The meeting participants name their recommendations were included in DHS report, which was submitted to the legislature in 1987. This report concluded that “air monitoring should be done only to aid in determining if the building is clean enough to be should be funded.” Although this report did not explicity state which method should be used to determine whether abatement was warranted and, if so what type of the art methos should be used, viz, visual inspection supplemented by bulk material sampling and analysis. Because chapter 116 requires the development of methods and standards to assess the potential for exposure to asbestos in public buildings, the task force had to consider whether public buildings were
sufficiently different from schools to render the conclusions of the report mandated by sec. 24275. Of the GHSC invalid for public buildings. The task force concluded that the report’s conclusions are indeed applicable to public buildings other than schools. However, because the expert testimony presented at the DHS meeting was two years old, DEI was asked to supplement it by conducting telephone interviews of experts in the field to ascertain their current opinions. DEI also assisted DHS in conduction a literature review. The results of these two activities are described in Volume V of the Contract Report, and can be summarized as follows: Little reliable data are available on exposure to public building occupants and users. Most of the studies to date have found that higher than outdoor levels of airborne asbestos can sometimes be found in building which contain asbestos. None of the studies is detailed enough to allow prediction of the levels expected in any particular circumstance in a building. However, the limited data available suggest that exposure to building occupants are likely to be substantial extrapolation of occupational risk data would be necessary even if exposure were well known. The fact that the limited data suggest that everyday levels in buildings with asbestos containing materials are somewhat elevated from outdoor levels, which themselves are not zero, and are predicted to be responsible for a few deaths per million population, supports the contention that asbestos in building may pose a small but non zero risk of lung cancer and mesothelioma to occupants. Most of the authors reviewed agree that maintenance activities are
probably the cause of the most severe exposure to asbestos in building, and that maintenance and janitorial staff are at most risk due to their frequent participation in these activities. Many experts assert that non friable asbestos in good condition is not likely to be the source of significant exposure to airborne fibers, but that physical contact between occupants and AGM should be prevented. From this review, the task force concludes that ACM often pose no danger to building occupants if the
ACM are identified and properly maintained. It find no scientific basis for establishing a specific conctration of airborn asbestos as a standard level, since even ambient levels as asbestos can be assumed to pose some risk. Furthermore, air monitoring can only give an indication of current exposure in a way that is extremely limited both in time and in space, and cannot predict future exposure due to maintenance or remodelling activities or to occupant activities that might damage ACM. AIR monitoring using TEM, the only method sensitive enough to analyze building air is prone to large uncertainties and high costs. This cost would be especially onerous if public agencies were to attempt to ascertain levels of
airborne fibers on an ongoing basis with reasonable certainty in large buildings.
III. Public Hearings
Hearings were held on April 27, 1989 in Sacramento and on may 5, 1989 in Los Angeles to allow
testimony on method and standards to assess the potential for employee and public for employee and
public to asbestos in public buildings in California. Prior to the hearings, DHS provided notice to the
public through newspaper, public service announcement on the radio and a notice in the asbestos
control report, a national publication. Notification letters were sent to all cities, counties, air pollution
control districts, state departmental safety coordinators, state department asbestos coordinators, public
employee unions, industry representative and approximately 4000 people on a mailing list obtained
from the national asbestos council. Several experts in the field were also requested to attend and testify
at the hearings, and two of these, Kyle bishop and Dr Gustavo Delgado. Did so.
Transcripts of the hearings are included in appendix B of this report. Three consensus opinions emerged
from these hearings: 1) the speakers expressed the opinion that air monitoring is not appropriate or cost
effective for determining the course of abatement in public building, although some advocate its use on
a limited basis after a building had been thoroughly inspected and ACM found. 2) Many speakers
expressed concern that asbestos was sometimes being abated by unqualified firms, and that
considerable exposure of the workers, and possibly building occupants, could occurs. 3) Finally many of
those testifying urged the task force to recommend that any public building containing ACM be required
to establish a detailed O&M program to prevent exposure of occupants and maintenance workers.
As part of the hearing process, DHS also solicited written comments, which were entered into the record
if postmarked by May 12, 1989. On May 12, written comments were received from the safe building
alliance (SBA), an organization of former manufacturer of ACM used in building construction. Arguments
advanced in this document are similar to those advanced by SBA to the EPA during its negotiated
rulemaking process for asbestos in schools (see Section 4, subsection VI below), and which were
rejected by the EPA. In the conclusion to its arguments, the SBA urged that task force to recommend
program options, including establishment of an objective air quality standards, that protect against
indiscrimination removal of asbestos in state building is further asserted that “ (s)pecification of an
action level will help to assure cost-efficient and complete health protection for state employees and
visitors to state buildings, and will promote responsible management of asbestos containing materials
by public and private building owners.
1989, and
Written materials went to DHS as part of the public record of the two public hearings..
II Research Findings
In preparing a report to the legislature mandated by the California health and safety code (CHSC)Chapter 2.5, Section 24275., DHS had convened a workshop of expert witnesses to testify on the use of air monitoring for determining the funding of abatement in schools. The meeting participants name their recommendations were included in DHS report, which was submitted to the legislature in 1987. This report concluded that “air monitoring should be done only to aid in determining if the building is clean enough to be should be funded.” Although this report did not explicity state which method should be used to determine whether abatement was warranted and, if so what type of the art methos should be used, viz, visual inspection supplemented by bulk material sampling and analysis. Because chapter 116 requires the development of methods and standards to assess the potential for exposure to asbestos in public buildings, the task force had to consider whether public buildings were
sufficiently different from schools to render the conclusions of the report mandated by sec. 24275. Of the GHSC invalid for public buildings. The task force concluded that the report’s conclusions are indeed applicable to public buildings other than schools. However, because the expert testimony presented at the DHS meeting was two years old, DEI was asked to supplement it by conducting telephone interviews of experts in the field to ascertain their current opinions. DEI also assisted DHS in conduction a literature review. The results of these two activities are described in Volume V of the Contract Report, and can be summarized as follows: Little reliable data are available on exposure to public building occupants and users. Most of the studies to date have found that higher than outdoor levels of airborne asbestos can sometimes be found in building which contain asbestos. None of the studies is detailed enough to allow prediction of the levels expected in any particular circumstance in a building. However, the limited data available suggest that exposure to building occupants are likely to be substantial extrapolation of occupational risk data would be necessary even if exposure were well known. The fact that the limited data suggest that everyday levels in buildings with asbestos containing materials are somewhat elevated from outdoor levels, which themselves are not zero, and are predicted to be responsible for a few deaths per million population, supports the contention that asbestos in building may pose a small but non zero risk of lung cancer and mesothelioma to occupants. Most of the authors reviewed agree that maintenance activities are
probably the cause of the most severe exposure to asbestos in building, and that maintenance and janitorial staff are at most risk due to their frequent participation in these activities. Many experts assert that non friable asbestos in good condition is not likely to be the source of significant exposure to airborne fibers, but that physical contact between occupants and AGM should be prevented. From this review, the task force concludes that ACM often pose no danger to building occupants if the
ACM are identified and properly maintained. It find no scientific basis for establishing a specific conctration of airborn asbestos as a standard level, since even ambient levels as asbestos can be assumed to pose some risk. Furthermore, air monitoring can only give an indication of current exposure in a way that is extremely limited both in time and in space, and cannot predict future exposure due to maintenance or remodelling activities or to occupant activities that might damage ACM. AIR monitoring using TEM, the only method sensitive enough to analyze building air is prone to large uncertainties and high costs. This cost would be especially onerous if public agencies were to attempt to ascertain levels of
airborne fibers on an ongoing basis with reasonable certainty in large buildings.
III. Public Hearings
Hearings were held on April 27, 1989 in Sacramento and on may 5, 1989 in Los Angeles to allow
testimony on method and standards to assess the potential for employee and public for employee and
public to asbestos in public buildings in California. Prior to the hearings, DHS provided notice to the
public through newspaper, public service announcement on the radio and a notice in the asbestos
control report, a national publication. Notification letters were sent to all cities, counties, air pollution
control districts, state departmental safety coordinators, state department asbestos coordinators, public
employee unions, industry representative and approximately 4000 people on a mailing list obtained
from the national asbestos council. Several experts in the field were also requested to attend and testify
at the hearings, and two of these, Kyle bishop and Dr Gustavo Delgado. Did so.
Transcripts of the hearings are included in appendix B of this report. Three consensus opinions emerged
from these hearings: 1) the speakers expressed the opinion that air monitoring is not appropriate or cost
effective for determining the course of abatement in public building, although some advocate its use on
a limited basis after a building had been thoroughly inspected and ACM found. 2) Many speakers
expressed concern that asbestos was sometimes being abated by unqualified firms, and that
considerable exposure of the workers, and possibly building occupants, could occurs. 3) Finally many of
those testifying urged the task force to recommend that any public building containing ACM be required
to establish a detailed O&M program to prevent exposure of occupants and maintenance workers.
As part of the hearing process, DHS also solicited written comments, which were entered into the record
if postmarked by May 12, 1989. On May 12, written comments were received from the safe building
alliance (SBA), an organization of former manufacturer of ACM used in building construction. Arguments
advanced in this document are similar to those advanced by SBA to the EPA during its negotiated
rulemaking process for asbestos in schools (see Section 4, subsection VI below), and which were
rejected by the EPA. In the conclusion to its arguments, the SBA urged that task force to recommend
program options, including establishment of an objective air quality standards, that protect against
indiscrimination removal of asbestos in state building is further asserted that “ (s)pecification of an
action level will help to assure cost-efficient and complete health protection for state employees and
visitors to state buildings, and will promote responsible management of asbestos containing materials
by public and private building owners.