Info

The Environmental Information Association (EIA) is grateful for the opportunity to offer comments to the Public Peer Review Meeting on the Alternative Asbestos Control Method (AACM) demonstration project reports #2 and #3. EIA would like to begin by thanking EPA, specifically Roger Wilmoth and Adele Cardenas-Malott, for working with EIA and our membership to keep us updated and informed of the progress of the AACM series of projects. They have both been gracious and generous with their time and expertise, they have been candid in discussions and they have been extremely approachable when our members have had questions or misunderstandings. I would be remiss if I did not also recognize the significant efforts of Glenn Shaul on behalf of EPA. Glenn was a long-time supporter of the Environmental Information Association and our mission to collect, generate and disseminate information regarding environmental issues in buildings. Glenn was always eager to put on his body armor and attend our meetings to take the questions and barbs from our members. Glenn and his contributions will be sorely missed. As a bit of background information, I would like to note a little of the history of EIA, and why we as an association are here to offer comment. EIA was founded as the National Asbestos Council in 1983. Our mission upon founding was to "collect, generate and disseminate information regarding asbestos in buildings." As our membership became involved in other indoor pollutants, the association changed our name in 1992 to the Environmental Information Association. Our mission, however, stayed the same; to collect, generate and disseminate information regarding environmental issues in buildings and facilities. EIA, and formerly NAC, have always taken great pride in distributing accurate, balanced information regarding asbestos in buildings. We have worked hard to be impartial in fulfilling our mission, since our membership is multi-disciplinary, consisting of contractors, consultants, laboratories, training providers, building owners, regulators, researchers, policy makers and so forth. To take a position on any particular matter might have benefited one class of our membership, while presenting concerns for another class. So, for this reason, EIA has always sought to give our membership all of the accurate, truthful information available, and allow each member to develop their own opinions and positions regarding the information that has been disseminated. In the case of the AACM, all classes of our membership, from contractors to building owners, have grave concerns about the implementation of AACM into the range of possibilities for asbestos abatement. This has placed EIA into an interesting position that we have never really faced before - - that is to "take a position" on a matter concerning asbestos in buildings. This is a place that EIA has never been, and we are reluctant to go there on the AACM issue. We have enjoyed a great relationship with EPA, OSHA and other regulatory agencies over the years because we have never come to the table with a pre-conceived agenda, or representing one certain interest group. With that said, after careful consideration, the Board of Directors of EIA has worked diligently to develop comments on the AACM process that we believe fall into the areas of inconsistencies, oversights and technical concerns, rather than taking a position on the efficacy of AACM. My comments will fall into two categories. The first category will be the inconsistencies, oversights and technical concerns, and the second category of EIA's comments will be to reinforce what our members have been saying not only to our association headquarters office, but also to the docket concerning these reports.