The Smart Way to Manage Hazardous Building Materials in Schools


Imagine the following situation, then ask yourself one question: “Could this happen in my school?”

The school’s new Athletic Department administration has received a donation to improve the weight room used by the school’s student-athletes, starting with removal of the tile flooring. The Athletic Department hires a flooring contractor to remove the existing tile flooring and polish the concrete floor below.

To help with efficiency and to save on costs, the coaches have the student-athletes help move the weight lifting equipment out of the space before the contractor arrives the following week. As part of this movement, many of the tiles become pulled off the floor; in other areas, exposed tiles are found to be crushed from weights falling on them over the course of the years. The contractor then mobilizes to the site, and the workers begin using a ride-on floor scraper to remove the remaining tile flooring from the space.

When a longer-tenured instructor at the school walks past the weight room and sees the work taking place, he asks if the flooring contains asbestos as he seemed to recall it was asbestos-containing. The flooring contractor says they only address abatement of flooring when notified by an owner before the job starts and assume since they were not told beforehand it was not present in the work area. They decide to alert administration and isolate the space. The word spreads quickly among parents, staff, and the teacher’s union, and the school now has a major problem to address.

We hope you can say, “No, that would never happen in my school.” Unfortunately, an incident just like that did occur. It’s a case of something being simple to prevent, but quite complex once it happens. In this article, we will show you how even the smallest school district can easily manage hazardous building materials (HBMs) in their school — and, yes, there is a good chance your schools are at least partially constructed of HBMs.

Hazardous Building Materials in Schools: An Overview

The good news is that HBM problems in schools are typically limited to asbestos and lead. While many people believe these substances were declared illegal to use in building materials years ago, this is a common misconception. The problem was addressed decades ago and strict guidelines on which materials can contain HBMs were developed, but chances are high that older school sites still have asbestos-containing tile flooring, drywall, and ceiling materials. Painted surfaces may contain lead. Along with pipe wrapping, these are examples of where problems most often arise.

The Asbestos Hazard Emergency Response Act (AHERA) requires all public and non-profit schools to perform an asbestos survey at the school to determine where the substance is found, to create a plan for preventing it from becoming a health problem for occupants, and to prevent or reduce the associated hazard. No inspection to identify lead is required at this time by the Environmental Protection Agency (EPA), but other regulations require all painted surfaces to be treated as if they contain lead in the absence of a survey — and that can boost the price of paint removal substantially.

The bottom line: if your school contains hazardous building materials and you are not taking the proper steps to acknowledge them and protect your people, they can deliver consequences you want to avoid. They can include litigation, public outcry, union action, and the realization that you are responsible for an oversight that could severely impact the health of the students, teachers, and other site staff members who depend on you for guidance and protection.

The Three C’s of Hazardous Building Material Management in Schools

The proper management of HBMs is a process, and it does require the expenditure of both time and money. Many times, school administrators have a misunderstanding of the issue. They either don’t believe HBMs are present in the school (with no data to back it up), don’t understand that the materials can pose a serious threat, or are so understaffed they don’t have the awareness to worry about it. The Three C’s of HBM management in schools (listed below) will show you how to display exemplary leadership in this very serious matter — even if you are in a smaller school district and resources are limited.

Collect the data

Proper HBM management begins with a survey of your school to identify areas where asbestos and lead are present. AHERA requires you to maintain onsite proof of the survey, your written asbestos management plan, and your actions regarding asbestos threats. Those regulations require both the initial survey and an onsite re-inspection every three years by accredited, and for many states licensed or certified, individuals.

Lead isn’t governed by AHERA, but other regulations are in place concerning the toxic substance. Not only does paint often contain lead, but even the pipes that serve drinking water can be an issue.

Here’s what happened at one school:

The maintenance staff cut a hole in the wall to install equipment for an elementary school classroom. The location happened to be in the area of the room used for reading time by the children. The workers never gave a thought to the possibility of lead in the paint and asbestos in the drywall wall material. Since they needed to rush to complete the job before the end of their shift, they failed to properly gather the fallen paint chips and dust that covered the desks and carpet. They planned to have someone bring a vacuum cleaner to remove the mess early the next morning before the teacher and students arrived.

That never happened, and the teacher failed to notice the problem until she saw children drawing pictures in the dust, then dragging the dust along their clothes and faces. The teacher notified the office, and the maintenance supervisor received the news with a grimace. The paint did contain lead, and the drywall contained asbestos. Parents were notified, and the students underwent blood testing to determine the extent of their exposure to lead.

There is no immediate medical examination to determine the lasting impact to health from asbestos exposure. Think of the nightmare one seemingly small job can unleash when school administrators fail to take HBMs seriously.

Communicate the data

Your HBM survey will show you exactly where HBMs are located and will identify any areas needing immediate attention. The next step is to communicate the information to those who need to know and train them on how to access and apply it. Schools often ask FACS teams to present their findings to a gathering of school employees as a launch for the training.

Depending on the position held, some employees will (by law) need more education on HBMs than others. Custodians, for example, must know how to identify potential problems and exposures. Operations and maintenance staff will also need to know how to work with the HBMs when disturbance of the materials or a degraded covering makes it necessary. All staff members should know the hazards exist and when to alert administration to a potential trouble spot.

Had the maintenance workers who cut the hole in the wall and HBMs on children’s desks undergone the required training, the situation would likely never have occurred, and the school would not have suffered the consequences that followed.

Make sure all data is readily available by all concerned and remember that any outside contractors working at the school will need to review it as well. Don’t make the mistake of putting one person in charge, then forgetting about the plan. We’ve seen cases where the guardian of the HBM records retires or otherwise leaves the school — then nobody else knows where the records are or even that they exist.

Consider these two examples:

After severe flooding last year, a FACS client called to say water gained entrance to several of the rooms and significant work needed to be performed there. The FACS expert checked the records for those rooms (from a FACS HBM survey the previous year) and told them exactly which HBMs were present and exactly where they were located. The school had qualified contractors on the job within hours.

During that same flood, another school called with a similar issue. They had not worked with FACS before, but we were referred by the contractor who normally handles their construction projects. The school representative had no idea where HBM records might be or even if a survey had yet been performed — but they needed to get started immediately and the contractor needed the data. The FACS team arrived the next morning to conduct the HBM survey and sent the samples to the lab for processing right away. Even though we pushed the clock as hard as we could for them, the school was unable to proceed for several days while awaiting the necessary data. Not only did the unprepared school need to pay more for the work than did the prepared school, but they lost considerable time during the process.

Continue the process

HBM management in schools is not a one-time event. It is a cycle. The aim is to catch any mistakes now being made, correct them, then continue to monitor for additional issues. In addition, current regulatory standards for asbestos and lead paint require a person to assume materials (including newly-installed materials) contain asbestos and/or lead until performing their own due diligence, i.e. a survey by a properly accredited and certified individual, to verify if asbestos or lead is present in a material. AHERA requires a re-inspection every three years, but your custodial and maintenance staff should be properly trained and constantly on the alert. They should perform their own inspections every six months to comply with the law.

AHERA also requires you to notify organizations representing parents, teachers, and employees yearly about how to access your asbestos management plan and any actions taken or planned during the year. You can find all AHERA obligations on the EPA website.

Exposure to asbestos or lead can lead to serious health problems. When hazardous building materials in your school are disturbed you have an urgent situation to address. You’re not only risking your finances and reputation, but you are subjecting anyone exposed to those materials to unnecessary danger.

Get a hazardous building materials survey from a licensed and trained inspector. You don’t know if you have HBMs if you don’t test. Collect the data, communicate the data, and continue the process. FACS experts are ready to collaborate with your internal teams to provide turn-key solutions to managing your HBMs. You can reach us at (888) 711-9998.