STATE OF CONNECTICUT
DEPARTMENT OF PUBLIC HEALTH
Phone: (860) 509-7740 Fax: (860) 509-7785
Telephone Device for the Deaf (860) 509-7191
410 Capitol Avenue - MS # 11EOH
P.O. Box 340308 Hartford, CT 06134
An Equal Opportunity Employer


TO: Superintendents of Schools
FROM: Mark K. McQuillan
Commissioner of Education
J. Robert Galvin, M.D., M.P.H., M.B.A.
Commissioner of Public Health
DATE: June 26, 2007
Subject: Potential Asbestos Hazard in Art Clay


The Connecticut Departments of Public Health (DPH) and Education (DOE) are writing to inform you about a
potential asbestos hazard in art clays used in schools. The DPH has learned that some clays sold to schools in
Connecticut may have asbestos contamination as a result of “talc” that is added to certain clays.
Talc is added to certain clays as a “flux” to lower the temperature at which the clay needs to be heated. The DPH has
become aware that the talc from at least one mine in the Northeast may be contaminated with a type of asbestos called
anthophyllite. Although there has been debate if the asbestos found in talc actually falls under the regulatory definition
of asbestos, there is enough uncertainty to warrant caution when using clays with added talc. A recent court case in
New Jersey found talc mined by the R.T. Vanderbilt Company of New York was responsible for an asbestos-related
cancer ( mesothelioma) in a pottery shop owner. The pottery shop owner had purchased talc (Nytal 100) in large bags
and mixed it in clays he used and sold.
DPH is concerned if such talc is used in Connecticut schools it could cause exposure to airborne asbestos in art rooms.
Exposure to airborne asbestos has been linked to disease, most notably an increased risk of lung cancer, mesothelioma,
and asbestosis. Although most clays are purchased and used in a wet form, and therefore are unlikely to become
airborne, pieces that fall off will dry and may create a dust in the room. Additionally, some dried clay pieces may also
be sanded or chipped. Presently, there is limited information available regarding exposure to asbestos found in talc
used in art clay and the health risk that it may present. Given these facts, the DPH and DOE are advising school
officials to inventory all art clays for the potential presence of talc.
The federal government has not made a final determination regarding the need to address the presence of asbestos in
art clay. The DPH has asked the U.S. Consumer Product Safety Commission (CPSC) to look into this question, but we
do not expect an answer in the short term. In the meantime, the DPH advises you to ask your art material supplier if
the clay they sell to your district contains talc. Since there are non-talc alternatives for most art clays, the DPH
recommends that you should consider using them until the CPSC arrives at a final conclusion on the nature of asbestos
in some talc. Further, the DPH recommends that you conduct a thorough wet wipe cleaning of art rooms or kilns where
talc added clays were used. Alternatively, a HEPA vacuuming of the area will also pick up any fibers left behind by
past activities.
We will keep you informed of any developments in this area.

If you or your staff have any questions, please
feel free to call Brian Toal, Supervising Epidemiologist 4, of the DPH, Environmental and Occupational
Health Assessment Program at (860) 509-7740.

Focus  on  Asbestos  in  Schools

The Asbestos-Containing Materials in-Schools regulation, Sections 19a-333-1 through 13 the management of asbestos in all elementary and secondary, public and not for profit private schools. This Department of Public Health (DPH) regulation contains requirements that are essentially the same as those mandated by the U.S. Environmental Protection Agency (EPA) under the Asbestos Hazard Emergency Response Act (AHERA) regulation (40 CFR, Part 763). Specific differences between the Connecticut and federal requirements are highlighted on the back page.

What are the responsibilities of the Local Education Agency (LEA) ?

> Note: EVERY school building must have an AMP and provide an annual notice regarding its availability, regardless of whether it is believed that the building is asbestos-free.

Inspect each school building to identify all asbestos-containing building materials (ACBM)Prepare an asbestos management plan (AMP) for each school buildingSubmit AMP to the DPH for review and approval prior to use as schoolMaintain complete and up-to-date AMP at each school and in the central administration building

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Each LEA must designate a person to ensure that regulatory responsibilities are carried out. This

individual is commonly referred to as the “Designated Person.” Questions concerning the school AMP

should be directed to the Designated Person. The person’s name, address and phone number must be

present in the AMP.

Additional LEA responsibilities include, but are not limited to, the following:

  • Provide asbestos training to custodial and maintenance staff: new employees must be trained within60 days of employment

**A response action is a method, including removal, encapsulation, enclosure, repair, operations
and maintenance, that protects human health and the environment from friable ACBM. **A friable
material is one that can be crumbled, crushed, pulverized or reduced powder by hand pressure.

These are the major differences between AHERA and CT regulations for regulating asbestos in schools:

Note 1: The Asbestos “National Emission Standards for Hazardous Air Pollutants” (NESHAP, 40
CFR, Part 61) is a federal regulation that requires a thorough inspection be conducted to
determine the presence of asbestos is present prior to commencement of any renovation or
demolition activity. In order to achieve compliance with the Asbestos NESHAP requirements,
an inspection that is destructive in nature is often needed to augment an inspection performed
under the Asbestos Containing Materials in Schools regulation.
Note 2: Asbestos abatement in school facilities requires the use of licensed and accredited contractors
and consultants. Check for DPH- issued worker/supervisor certificates in addition to annual
training certificates, licenses are not issued for these individuals.

WE’RE ON THE WEB:
dph.state.ct.us/BRS/Asbestos/asbestos_program.htm
For More Information from EPA:
http://www.epa.gov/asbestos/ asbestos_in_schools.html

Information for Your Local Education Agency Designated Person Asbestos in Schools
Fact Sheet [PDF] - August 2003
http://www.epa.gov/asbestos/aherarequirements.pdf
____________________________________________________________________________
Information for Parents, Teachers and Other School Employees
20 Frequently Asked Questions About Asbestos in Schools - September 2003
http://www.epa.gov/asbestos/ais20quests.pdf [PDF version]

http://www.epa.gov/asbestos/aherafaq.html HTML version

_____________________________________________________________________________
ABCs of Asbestos [PDF] - October 2003
http://www.epa.gov/asbestos/abcsfinal.pdf

Provide annual notification to parents/guardians, teachers and staff of the availability of the AMPSelect and implement appropriate response action, based upon assessment of ACBMAsbestos abatement may not be performed during regular school hours without prior written approval by the DPH • Documentation of Three- Year Reinspection must be submitted to the DPH within 30 days of reinspection • During the reinspection, samples must be collected on any newly friable ACBM that was already assumed to be ACBM • Warning labels shall be posted in routine maintenance areas in a bilingual form whenever it is determined that a significant student and/or employee population requires a translated formatEnsure short term workers are provided with AMP to determine ACBM locationConduct 6 month periodic surveillance to document changes in condition of ACBMConduct a re-inspection every 3 years following implementation of AMPDocument and update each copy of the AMP regarding all asbestos related activities