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Prepared Statement of Laurie A. Westley, National School Boards 



Association 



The National School Boards Association (NSBA) is the Nationwide advocacy orga- 

 nization for public school governance, representing 97,000 elected and appointed 

 local school board members. The vast majority of school board members are not 

 paid for their service. Rather, they give their time because they care about the edu- 

 cation of their own children and the children in their community. The safety of 

 those children is a very real concern for these community leaders. They do not want 

 anything to harm the health of the children they work so hard to serve. 



NSBA wishes to use this hearing on whether EPA should become a cabinet-level 

 agency to raise concerns about the agency's risk assessment practices. This testimo- 

 ny will begin where the educational curve for schools and environmental issues 

 began — with asbestos. But it will begin with the postscript. 



In 1990, then-EPA Administrator William Reilly came close to admitting that his 

 organization was responsible for a significant environmental error. In a speech 

 before the American Enterprise Institute, Mr. Reilly admitted that much of EPA's 

 work on asbestos, at best, was riddled with errors and had proved unnecessarily ex- 

 pensive. 



This saga began in 1982 when EPA accepted the claims of professional environ- 

 mentalists "that there can be no safe level of exposure to a carcinogen" or in the 

 case of asbestos — "that one fiber can kill." There was not an accurate assessment of 

 the risks. The agency accepted a scientifically discredited four-year-old study pre- 

 dicting asbestos, as a low level carcinogen, would cause as many as 40,000 "excess 

 deaths" per year. The study was based on the experience of World War II shipyard 

 workers who worked with extremely high levels of asbestos, and those results were 

 extrapolated down to exposure in the general public. 



The EPA used this study despite evidence that the actual asbestos deaths of ship- 

 yard workers were no more than 520 at the highest point — and was falling sharply 

 as they died of natural causes. EPA also ignored its own scientific review of the 

 study. EPA's own scientific panel denounced the study as "unconvincing,"" greatly 

 overestimated," "scientifically unappealing," and "absurd." 



Further, scientific studies now show us that there are two kinds of asbestos and 

 the kind in schools and most public buildings is significantly less dangerous than 

 the other variety. 



The postscript to this strange tale is that asbestos removal is estimated to have 

 cost this country $150 to $200 billion. Schools have spent the lion's share of this 

 figure. And every one of those dollars was taken from the resources needed to 

 create the world-class schools this country says it wants. 



The reason this is important is by way of parable. We must determine the lessons 

 we should have learned from the asbestos experience. If we do not apply those les- 

 sons, we will be doomed to repeat the same errors. 



And lest you think this is a hypothetical possibility, the Congress has bills pend- 

 ing requiring mandatory school testing of lead, radon, and indoor air quality. 



To summarize, the formulation of public policy on the asbestos issue was ahead of 

 the scientific evidence to establish an accurate risk assessment; the result was that 

 millions of scarce educational dollars were wasted. 



Schools cannot afford to abate questionable environmental hazards, abate them in 

 an unnecessary way, or abate them down to a level that is beyond a meaningful risk 

 assessment. 



Here we are at the beginning of the 103d Congress, with the expectation that 

 well-meaning members of Congress will introduce bills to address environmental 

 hazards for which there is insufficient scientific basis and insufficient financial re- 

 sources. Last year NSBA wrote testimony opposing a radon bill because the scientif- 

 ic understanding of low-dose radon is inadequate, at this point, to support mandato- 

 ry testing paid for by local taxpayers. 



The similarities are striking as to how the asbestos issue began, when compared 

 to the radon issue. The basis for understanding the effects of radon is the extrapola- 

 tion of data from four studies of uranium miners in the 1950s. The work using these 

 studies as a basis is imprecise at articulating the degree to which the radon is a 

 contributing factor in the contraction of lung cancer in the general population. 



Further, this subsequent work has found it difficult to screen out the additional 

 harmful agents on the miners' lungs — the length and concentration of time they 

 were in the mine, the lack of effective ventilation, the percentage of heavy smokers, 

 the additional dust and mineral irritants — all of which contribute to lung cancer 

 and are not substantially prevalent in the average American home or school. 



